7. Anti-money laundering Policy

APPLICATION

Anti-money laundering (hereinafter „AML“) refers to the laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

This Policy has been developed by Aluminij Industries (hereinafter “Aluminij” or “we”) to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its products. We do not assist, support, participate in or permit money laundering or terrorist financing.

Aluminij strongly upholds all laws relevant to preventing money laundering in all of the jurisdictions in which Aluminij operates.

This Policy applies to Aluminij and all employees, and officers. It provides information and guidance on how to recognize and deal with money laundering issues.

All Aluminij’s business partners are requested to follow the same principles and commitments regarding anti-money laundering and to adhere to the provisions of this Policy at all times while conducting business with Aluminij.

PROHIBITED ACTIVITIES

The following types of activities are prohibited under this Policy:

1. the conversion or transfer of property (including money), knowing or suspecting that such property is derived from criminal or certain specified unlawful activity (“criminal property”), for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
2. conducting a financial transaction which involves criminal property;
3. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;
4. the acquisition, possession or use of criminal property;
5. promoting the carrying on of unlawful activity; and
6. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

INDICATORS FOR SUSPICION OF MONEY LAUNDERING ACTIVITIES

The examples of possible indicators of suspicion for money laundering activity:

1. transactions which have no apparent purpose, and which make no obvious economic sense;
2. where the client/business partner refuses to provide the information requested without reasonable explanation;
3. A client/business partner refuses to proceed with a transaction when asked for identification;
4. where cash payment been offered by the business partners/clients;
5. business activities that contradict core values;
6. suspiciously close ties to government officials, previous allegations of corruption or unethical behavior or a lack of proportionality between the proposed work and fees;
7. engage in any activity that might lead to a breach of this Policy.

The above is not intended to be an exhaustive list.

POLICY BREACHES

Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.
Any uncertainties as to whether a particular act constitutes money laundering, or any other queries, should be raised with Aluminij’s Compliance Officer.

Aluminij is committed to ensuring that no one suffers any detrimental treatment as a result of their good faith reporting of their suspicion under this Policy.

POLICY REVIEW

This Policy shall be updated from time.