1.  Purpose

The purpose of this Policy is to explain the risk of financial crime to which EXPEND LIMITED (“The Company”) may be exposed in the conduct of its business, and the policies and procedures used to combat financial crime.

The Financial Crime Policy aims to:

• Educate staff on financial crime and fraud.

• Establish and implement policies and procedures that can reasonably detect and cause the reporting of suspicious transactions as required by Company guidance and regulations.

• Encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

• Provide staff with guidance as to how to raise those concerns.

• Reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

2.  Scope

The procedures and principles set out herein must be followed at all times by the Company and all employees or staff working for or on behalf of the Company.

When an employee is working with one of our clients they may be asked to read and agree to follow client policies relating to financial crime. Employees are expected to follow those policies as long as they are aligned with EXPEND LIMITED policies and principles. If there is any doubt employees should discuss the client policy with their manager.

Unlike many of our financial service customers EXPEND LIMITED is not involved in cash management activities and staff are not typically exposed to sensitive financial information therefore the risk of the company or our employees being involved with or utilised in financial crime is currently considered low.

3.  Money Laundering

Money laundering is the process by which criminals make the proceeds of their criminal activities appear to be funds to which they are entitled. The Company is committed to following all applicable laws and regulations to ensure that the Company’s business is not used to facilitate money laundering.

Generally, money laundering occurs in three stages.

1. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveller’s cheques, or deposited into accounts at financial institutions.

2. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.

3. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

3.1.  Deter - Know Your Client

EXPEND LIMITED employs a risk-based approach when carrying out client due diligence. This means that the Company determines the appropriate client due diligence measures to be carried out on a risk-sensitive basis, depending on the type of client, business relationship, product, or transaction in question.

The Company typically deals with large regulated financial service companies however, where a prospective client is unknown and considered to carry a higher risk, a Client Due Diligence (also known as KYC - Know Your Client) Checklist should be completed. This must include verification of the client’s identity

3.1.1.  Required Customer Information

Prior to engaging with a customer, the Company will collect the following information:

• business street address, local office or other physical location

• an identification number

When engaging with a foreign business that does not have an identification number, the Company will request alternative government-issued documentation certifying the existence of the business or enterprise.

3.1.2.  Misleading or Incomplete Information

If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, EXPEND LIMITED will not engage with the customer. In either case, the the COO will be notified in order to determine whether the situation should be reported to the appropriate regulatory authorities.

3.2.  Reputational Risk

The Company must be aware of potential reputational risk that may accompany certain professional relationships. Relationships with third parties that have been associated with negative press, particularly in relation to legal and regulatory violations, could potentially damage the Company’s reputation. Before establishing a new client relationship, the Company’s Corporate and Social Responsibility Policy should be considered and where appropriate a search should be conducted to identify if the potential client has been previously associated with legal or regulatory violations. The senior management team will make a judgement as to whether it is appropriate for the Company to be associated with a prospective client and to proceed with onboarding the client.

3.3.  Detection and Reporting of Suspicious Activities

Examples of suspicious transactions are those that have no business or apparent lawful purpose, are unusual for the client, or lack any reasonable explanation. Example behaviour or activity that may raise a “red flag” and require further investigation:

• A client exhibits an unusual level of concern for secrecy, particularly with regard to the client’s identity, type of business or source of assets

• A client lacks general knowledge of its own industry

• A client is from, or has accounts in, a country identified as a haven for bank secrecy, money laundering or narcotics production

All suspicious activities should be reported to the the CEO or the COO. If it is determined that reporting of the incident is warranted, the the CEO or the COO shall be responsible for reporting the matter to the regulatory authorities.

In the event of any money laundering investigation being commenced, it is important that no action is taken that would alert any persons suspected of such activities (“tipping-off”). Client confidentiality should not prevent notification to the authorities. All internal enquiries made in relation to the report, and the reason behind whether or not to submit the report to the authorities, should be documented.

4.  Fraud

The term is used to describe such acts as theft, deception, bribery, forgery, corruption, false accounting and conspiracy to commit these offences. Fraud typically involves the use of deception to obtain an unjust or illegal financial advantage and intentional misrepresentations affecting the financial statements by one or more individuals among management, staff or third parties.

5.  Fraud prevention

Fraud risk can best be managed through preventative and detective control measures. The following Company policies are in place and assist in fraud prevention:

• Code of Ethics

• Gifts and Entertainment (Anti-Bribery)

• Supplier Management

• Conflict of interest

• HR policies that include screening of new staff

6.  How can you help prevent fraud?

All staff must act with propriety in the use of official resources and in the handling and use of company funds whether they are involved with cash or payments systems, receipts or dealing with contractors or suppliers.

Report details immediately to your line manager or next most senior manager if you suspect that a fraud has been committed or see any suspicious acts or events.

7.  Fraud Investigation

Where reasonable suspicion that fraud against the Company has taken place, the Company will investigate the matter thoroughly. In most cases, external expertise will be called up to run the investigation into suspected cases of fraud. All investigations will be carried out objectively, in confidence and independently of the line management for the area in which the fraud is suspected.

It is the policy of the Company to report all known criminal activity to the police for investigation by them. The timing of police involvement will be at the discretion of the CEO.

In situations where EXPEND LIMITED or an EXPEND LIMITED employee is involved in an investigation of fraud relating to one of our clients, the same approach will be applied and employees are required to cooperate fully in the investigation.

8.  Whistleblowing

If you think a company or individual is involved in wrongdoing such as money laundering or Insider Trading, we urge you to inform the CEO.

In the event of any such report, the confidentiality of the reporting individual will be respected and the reporting individual will be supported and protected from reprisals. The Company will take all reasonable steps to ensure that no person under their control victimises the whistleblowing individual.

In the event that the individual feels unable to make such an internal report, they should consider approaching the appropriate person or body directly. A list of the bodies can be found here on the UK government website: Further Details