Precision-engineered biodegradable natural fibres for consistent, reliable performance.
Precision-engineered biodegradable natural fibres for consistent, reliable performance.
1.1 This Policy establishes a comprehensive and enforceable anti-money laundering (“AML”) framework governing all operations of Salike Limited (the “Company”). It is intended to ensure that the Company, its officers, employees and associated persons do not engage in, facilitate or otherwise become involved in money laundering or terrorist financing.
1.2 This Policy is designed to ensure compliance with applicable legislation including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Fraud Act 2006 and the Money Laundering Regulations 2017 (as amended), together with any equivalent legislation in jurisdictions where the Company operates.
1.3 This Policy forms part of the Company’s Corporate Governance Framework and shall be read alongside all associated compliance policies.
1.4 The Company shall adopt a risk-based approach and take all reasonable steps to prevent financial crime, including implementing proportionate controls, training and oversight.
2.1 “Money Laundering” means any act which constitutes an offence under applicable law, including concealing, disguising, converting or transferring criminal property.
2.2 “Criminal Property” means any benefit derived from criminal conduct, whether directly or indirectly.
2.3 “Suspicion” includes circumstances where a person has knowledge or reasonable grounds to suspect money laundering.
2.4 “SAR” means Suspicious Activity Report submitted to the National Crime Agency.
2.5 “MLRO” means Money Laundering Reporting Officer responsible for AML compliance.
3.1 This Policy applies to all directors, employees, contractors, consultants and associated persons.
3.2 It applies to all Company operations including procurement, sales, logistics, international trade and financial transactions.
3.3 Where local law differs, the higher standard shall apply where legally permissible.
4.1 The Company shall assess AML risks by reference to customer profile, geography, transaction type and delivery method.
4.2 Risk assessments shall be documented and reviewed annually.
4.3 Enhanced controls shall be applied in higher-risk scenarios, including cross-border transactions and use of intermediaries.
5.1 The MLRO shall have overall responsibility for AML compliance and reporting.
5.2 The MLRO shall receive internal disclosures, assess suspicion, determine SAR submission, maintain records and report to the Board.
5.3 The MLRO shall ensure training, monitoring and audit of AML procedures.
6.1 Prior to entering into any business relationship, the Company shall verify identity using reliable documentation.
6.2 The Company shall identify beneficial ownership and understand the purpose of the relationship.
6.3 No transaction shall proceed where identity verification is incomplete or unsatisfactory.
7.1 Enhanced due diligence shall be applied where higher risk is identified.
7.2 This includes politically exposed persons, high-risk jurisdictions and unusual transactions.
7.3 Additional measures include verification of source of funds, senior management approval and enhanced monitoring.
8.1 Business relationships shall be continuously monitored.
8.2 Transactions must be consistent with the customer profile and business activity.
8.3 Any anomalies shall be escalated immediately.
9.1 Staff must report suspicions immediately to the MLRO.
9.2 The MLRO shall log, assess and determine SAR submission within defined timeframes.
9.3 Staff must not investigate independently or disclose suspicions (tipping-off is prohibited).
10.1 Upon escalation, a structured investigation shall be initiated including evidence collection, documentation and reporting.
10.2 Decisions shall be escalated to senior management or Board level where appropriate.
10.3 External authorities shall be notified where required.
11.1 Records must be retained for a minimum of five years.
11.2 Records must include identification data, transaction data and SAR records.
11.3 Records must be secure, auditable and retrievable.
12.1 Cash payments above £200 require MLRO approval.
12.2 Unusual cash transactions shall be treated as high risk and investigated.
12.3 The Company reserves the right to refuse suspicious transactions.
13.1 Staff shall receive regular AML training appropriate to their role.
13.2 Training shall be documented and refreshed periodically.
14.1 Breach of this Policy may result in disciplinary action, including dismissal.
14.2 Serious breaches may constitute criminal conduct and be reported externally.
15.1 The Board retains ultimate responsibility for AML compliance.
15.2 The MLRO shall report regularly to the Board.
15.3 This Policy shall be reviewed annually.
