Anti-Money Laundering (AML) & Anti-Bribery And Corruption (ABC) Policy

Anti-Money Laundering (AML) Policy#

1. Purpose#

The purpose of this AML policy is to establish and maintain effective measures to prevent and detect money laundering activities within our organization. Money laundering poses a significant risk to the integrity of our business operations, reputation, and regulatory compliance. This policy outlines the principles and procedures that employees, contractors, and other relevant parties must follow to identify and mitigate the risk of money laundering.

2. Prohibited Conduct#

• ❌ DO NOT engage in any activity that facilitates money laundering. This includes knowingly providing false information or aiding and abetting in such activities.

3. Reporting Suspicious Activity#

• ✅ DO promptly report any transactions or activities that seem unusual, suspicious, or inconsistent with the normal business of the customer to help@thesoftwarepractice.com

• We do not retaliate against individuals reporting in good faith, and we take all reports seriously by investigating them promptly.

Anti-Bribery and Corruption (ABC) Policy#

1. Purpose#

The purpose of this ABC policy is to establish guidelines and procedures to prevent bribery and corruption in our organization. Bribery and corruption undermine trust, integrity, and fair competition, and they are strictly prohibited. This policy outlines our commitment to complying with anti-bribery laws and conducting business ethically.

2. Prohibited Conduct#

• ❌ DO NOT offer, promise, give, receive, or solicit any bribes, kickbacks, benefits, or corrupt payments in any form, whether directly or indirectly, with the intent to influence the actions or decisions of any internal or external individual (e.g. colleagues, supervisors, client’s staff), business entity (e.g. clients, vendors), or government official.

• ❌ DO NOT engage in any conduct that could be interpreted as bribery, even if it seems customary in a particular business or cultural context.

3. Gifts and Hospitality#

• ❌ DO NOT accept or offer gifts or hospitality that could compromise integrity or be perceived as an attempt to gain an improper advantage in business decisions. Exceptions are food-related items of the value of not more than SGD 50 e.g. snacks, drinks, meals.

• Whenever you are unsure of what to accept or offer, kindly write to help@thesoftwarepractice.com for advice.

4. Reporting Violations#

• ✅ DO report any suspected violations of the ABC policy through help@thesoftwarepractice.com

• We do not retaliate against individuals reporting in good faith, and we take all reports seriously by investigating them promptly.

Consequences of Violation#

Violation of any clause in this AML and ABC policy may result in disciplinary action, up to and including termination of employment, and legal action as deemed appropriate by the company.