Anti-Money Laundering and Counter Terrorism Financing Policy

This document is produced on behalf Zinc Work Limited (“Zinc”) a company incorporated and registered in England and Wales (company number is 10961635) with a registered address at Eastcastle House, 27-28 Eastcastle Street, London, United Kingdom, W1W 8DH on behalf of itself and any affiliates. 

This document is intended for all current employees, workers or contractors at Zinc.

Please make sure you read it carefully and if  you have any questions or concerns regarding this policy then please contact hamraj@zincwork.com. 

Zinc is a legal, ethical and transparent company, and it takes the responsibility to ensure and maintain that its assets and resources are not being used for corruption, irregularities, or money laundering. The company has taken it upon itself to detect frauds, irregularities, abuse of position, and institutional gains. Zinc is committed to ensuring compliance, amongst all of its staff, with the relevant regulations and frameworks which includes (but is not limited to): the Money Laundering Regulations 2017 (ML Regs) (as amended by the MLR 2019), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000 (TACT). 

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Policy

Money laundering refers to those assets that are money that is acquired in exchange for money or assets gained unlawfully. It also includes money spent for terror purposes, regardless of the means it was obtained.

Under this policy, money earned by using the following means is considered money laundering, and it is prohibited;

1. Money or assets received in exchange for criminal or unlawful acts. Money whose origin is not explicit or earned by assisting any activity in evading lawful means.
2. Property gained after any criminal activity and its origin, location, and disposition are not transparent.
3. Property which is promoting any unlawful activity
4. Terrorism financing

Zinc’s ISMS Governance Council takes responsibility for ensuring this policy is implemented and adhered to. 

All Zinc employees are required to undergo training in respect of this policy during their onboarding and then annually thereafter. 

Zinc works constantly to identify any irregularity on behalf of any stakeholder under this policy. Zinc makes sure to: 

1. Identify all the financiers of the company and verify their identity
2. Take special care where stakeholders want anonymity
3. Maintain proper records of the stakeholders
4. Regularly review our customer base against this policy

If any employee at Zinc knows or suspects that a person is involved in money laundering or terror financing, it is their responsibility to report such a person to Hamraj Gulamali at hamraj@zincwork.com. If this is not, for any reason, appropriate or if Hamraj Gulamali is unavailable then please report it to another member of the ISMS Governance Council 

Once reported Zinc will: 

1. Take the details of the people involved
2. Verify the type of transactions
3. Reason for suspicion
4. The amount involved

Following the detection of a money laundering event the ISMS Governance Council will conduct detailed Root Cause Analysis to mitigate any future risk.

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