Gift

A gift can be an item, but it also can include event tickets or the provision of services when the gift provider is not otherwise involved in the event or service (e.g. the giver provided the tickets but does not accompany the recipient to the event).

APPLICABLE LAWS

Applicable laws and regulations For the purpose of this Policy, ORSIIDA will use the standards set forth in the THE PREVENTION AND SUPPRESION OF MONEY LAUNDERING AND TERRORIST FINANCING LAWS OF 2007-2018, Directive 2015/849 of European Union, International Convention for the Suppression (Ratification and Other Provisions) Law and by sections 5 to 13 of the Combating the Terrorism Act as a basis for its compliance efforts. The reason for using these regulations as a base is that not only will these regulations be directly applicable to certain ORSIIDA ers but they are also seen as being the highest global ABC standard. In each jurisdiction in which ORSIIDA operates there are laws and regulations outlawing the above mentioned issues. Where these conflict, ORSIIDA will take a decision on the appropriate course of action on a case by case basis.

Compliance risk

Compliance risk (also referred as Financial Crime risk) is an indispensable part of ORSIIDA ’s overall risk. It is a risk ORSIIDA may suffer in failure to comply with applicable laws, rules and standards including Anti-Money Laundering regulations, sanctions and embargo programs, applicable to ORSIIDA ’s activities. Compliance risk must be identified, assessed, advised on, monitored and reported timely to protect ORSIIDA from any damage or losses such as legal or regulatory enforcement or sanctions, material financial losses, reputational losses, financial crime and corruption (destroying shareholders’ value).

Protect Confidentiality

ORSIIDA ers have to maintain the confidentiality of information which may be related to ORSIIDA and its clients (and entrusted to them) except when disclosure is authorised or required by law; even when they leave ORSIIDA.

Compliance "Red Flags"

There are many signals that require special attention from ORSIDA or that a particular transaction or relationship must be inspected to detect potential bribery issues. Signs or "Red Flags" that require additional attention include, but are not limited to:
unusually high fees and fee payments;
cash payment request;
payment requests through other companies and other countries;
if a Tax Center / Tax Haven requests an overseas payment for no good reason, an undefined or undeclared payment made to a third party on behalf of the company;
payments without written agreements;
payment that has an unusually close relationship with civil servants;
payment’s sender refuses to prove compliance with this policy.

It is the responsibility of each ORSIIDAer to comply with the ORSIIDA’s policies and principles of all applicable laws, rules and regulations.

Risk-based approach

Our risk assessment strategy

ORSIIDA takes a financial crime-independent approach at any time. You can find it in some way.
It provides information for assessing the risk of financial crime and developing control measures.

If you are associated with a business partner or broker involved in unethical or illegal activity, your reputation may be damaged or you may face legal liability. The depth of the follow-up due diligence process is based on an assessment of the risk status of the operation, including the following risk factors: industry; Third-party backgrounds and identities. Contact with government officials or entities. The proposed settlement amount and compensation scheme. To provide other elements related to the scope of service. and Third Party Choices.

ORSIIDA has zero tolerance for financial crime, wherever and in whatever form that may be encountered. ORSIIDA performs assessment of financial crime risks that will inform the development of controls.

ORSIIDA may suffer reputational damage or face legal liability if associated with business partners and intermediaries that engage in unethical or illegal conduct. The depth of subsequent due diligence procedures is based on an assessment of the risk profile of the engagement, including the following risk factors: geographic location; industry; background and identity of the third party; connection with government officials or entities; amount and Compensation structure of the proposed arrangement; additional factors related to the scope of the services to be rendered; and selection of the third party.

Anti-Bribery and Corruption

Gifts, Entertainment and Hospitality

ORSIIDA ers must not provide or accept gifts, hospitality or entertainment that seeks to influence or reward any business activity, including the anticipation of further business. It is important to remember that excessive or otherwise inappropriate gifts and/or hospitality can lead to the appearance of improper influence (including bribery) or conflicts of interest.

Critical Contributions and Appointments

Political contributions or donations in cash or kind on behalf of ORSIIDA are not permitted.

Charitable Donations and Sponsorship

Charitable donations and sponsorship may only be provided to recognized non-profit charitable organisations. Any charitable donations will not be made in recognition or anticipation of a business relationship with ORSIIDA . Charitable donations should not: be made to individuals or in cash; and be made at the request of a public official as an inducement to or reward for acting improperly.

Anti-Money Laundering

Money Laundering and Terrorist Financing Regulations

People and organisations that are involved in criminal activity such as bribery, fraud or trafficking narcotics may attempt to launder money through apparently legitimate businesses in order to use the funds from their criminal activity and reduce suspicion. ORSIIDA will not accept or process money gained through criminal activity; we will only deal with reputable clients who are involved in legitimate business activities and whose funds are derived from legitimate sources.

Suspicious Activity Reporting

Any external reporting requirements will be handled on a case by cases basis at request of a respective government authority.

Potentially Suspicious Circumstances

Situations which may cause a suspicion of illegality include, but are not limited to:

• A client whose identity or ultimate beneficial ownership cannot be verified easily;
• The source of a payment which is difficult to identify, or a payment which is received from a third party with no obvious connection to a customer client;
• A customer wanting to pay for services in cash;

Payments made from (or a request for a refund to) a foreign bank account or branch (particularly if the client does not have an obvious reason for conducting business within that country);

Sanctions

6.1. Third Parties that are registered in countries having high levels of trade and commercial sanctions, such as but not limited to, Iran, Sudan and North Korea, are subject to particularly high levels of scrutiny and decisions on whether to engage with a third party registered or located in (or whose beneficial owners are citizens or residents of) such a jurisdiction. These decisions should be taken on a case-by-case basis, with consultation and approval of Director where necessary.

Working with Third Parties

Prohibited Relationships

ORSIIDA will only establish business relationships with reputable third parties who derive their income, wealth, funds, and assets from legitimate sources. ORSIIDA must not knowingly establish business relationships with individuals or entities who are subject to legal restrictions (including sanctions).

Due Diligence Requirements

To ensure that ORSIIDA does not enter into any prohibited relationships and to ensure compliance with all legal and regulatory requirements. Third Party Due Diligence (“TPDD”) will be completed before the initiation of any business relationship and will seek to verify the true identity of potential third parties, the expected nature of their relationships and transactions with ORSIIDA , and their reputation.

Politically Exposed Persons

Any dealings with government agencies and government officials present an increased risk of bribery and corruption.

Communication with Third Parties

When dealing with third parties, employees must make it clear that ORSIIDA has a zero tolerance approach to financial crime.. Where appropriate, this Policy should also be communicated to third parties. Where any suspicion exists that a third party may be behaving unethically this should be reported to Compliance.

Monitoring

ORSIIDA will monitor third party relationships on an ongoing basis. The frequency and extent of ongoing monitoring will be determined by the third party’s risk rating.

11. Policy

Ownership and Review

The Director is responsible for owning and maintaining this Policy. The Policy must be reviewed and updated on as-needed basis by the Director. New operational, legal and regulatory developments and emerging risks may trigger review and update of the Policy.

Breaches

All breaches of this Policy or related standards and procedures must be immediately reported to the Director. The Director is responsible for determining whether the breach is material and requires further escalation.

Where laws have been violated, we will cooperate fully with the appropriate authorities.