Code of Conduct - Flipbook - Page 12
WE PREVENT FINANCIAL CRIME
WE NEVER ACCEPT BRIBES OR IMPROPER INFLUENCE
We do not tolerate corruption, bribery or other forms of financial crime. This means
we must never offer or accept any improper benefits such as cash, lavish gifts, or
excessive entertainment – especially when dealing with public officials or partners
involved in regulatory matters.
Even small unofficial payments to speed up a process – often called “facilitation
payments” – are not allowed.
Any gifts, hospitality or sponsorships must be modest, appropriate and transparent.
WE COMPLY WITH AML AND SANCTIONS LAWS
The Club complies with laws and regulations on anti-money laundering, terrorism
financing and financial sanctions. We must understand who we are dealing with –
including the ownership structure and risk level – and be alert to suspicious payments
or third-party involvement.
We do not engage with parties or transactions that violate laws and regulations or raise
red flags. Any concerns must be reported immediately to the MLRO or the Head of AFC.
As a manager, you must be vigilant and ensure that your team understands the risks of
undue influence and financial crime. Refer to the Club’s AML and sanctions procedures
for further guidance.
HAVE IN MIND:
Always know who you are dealing with – and why
Be alert to unusual transactions or unclear/complex ownership structures
Never offer or accept anything that could be seen as an attempt to influence
Escalate any suspicious behaviour to Head of AFC or to the MLRO
