Standard #10:

General Statement: Money-Laundering and Anti-Terrorism

• Money laundering is the process of concealing the identity of illegally obtained money so that it appears to have come from a lawful source. PowerSource does not condone, facilitate or support money laundering.

Elaboration of Standard:

• Group companies and their employees must not:
  

• engage in any transaction which they know or suspect involves the proceeds of criminal activity; or
• otherwise be knowingly involved directly or indirectly in any money laundering activity.
  

• They must pursue practices directed towards ensuring that their activities do not inadvertently contravene any relevant money laundering legislation.
  

• Group companies are required to adopt and maintain procedures designed to:
  

• minimize the risk of inadvertent participation in transactions involving the proceeds of criminal activity;
• detect and prevent any dishonest involvement in money laundering activity on the part of their employees; and
• support employees in identifying circumstances which ought to give rise to a suspicion of money laundering activity.
  

• Group companies must ensure that their existing customer approval and “know your customer” procedures are sufficient to provide comfort, as far as possible, that their customers are not involved in any form of criminal activity.
  

• Employees should promptly refer suspicious transactions or activities by any customer or other party with whom they are dealing to their line manager or local legal counsel.
  

• Group companies and their employees must:
  

• ensure that they do not knowingly assist in the financing of, or otherwise provide support for, terrorist activity; and
• pursue practices to ensure that their activities do not otherwise inadvertently contravene any relevant anti-terrorism measures.
  

• Most jurisdictions impose laws making it a criminal offence to engage in money laundering activity. Generally speaking, such laws make it an offence for any person or company to engage in transactions involving assets which they know or suspect are derived from criminal activity.
  

• Penalties for breach of money laundering laws can be severe (including substantial fines and/or imprisonment) and can attach both to individuals and to corporations. In essence, the more effective a company’s procedures are at detecting and preventing money laundering activity, the less likely it is that the company will be liable for prosecution as a result of its employees’ activities.
  

• Few Group employees will ever personally be in a position to infringe money laundering laws. However, you should be conscious of situations which ought to give rise to a suspicion of possible money laundering activity. These include (but are not limited to):
  

• payments made in currencies other than those specified on the invoice;
• payments made in cash or cash equivalents, in particular where the sum involved is substantial;
• multiple payments from different sources in satisfaction of a single invoice;
• payments to or from an account other than the normal business relationship account;
• requests to make an overpayment;
• payments made by, or requests to supply goods to, someone not a party to the contract; and
• requests to supply goods to a location other than the most proximate branch/office or to adopt an unusual shipping route.

	Our Standards in Practice
	1. Whistleblowing 2. Conflicts of Interest 3. Bribery and Corruption 4. Entertainment and Gifts 5. Political Contribution 6. Charitable Contributions 7. Accurate Accounting and     Record-Keeping 8. Protection of Corporate Assets 9. Confidentiality and      Information Security 10. Money-Laundering and       Anti-Terrorism
	Business Principles