Compliance Policy

As an organization committed to transparent and ethical business conduct, we at SFS Ventrures LLC strive to maintain the highest standards of integrity and professionalism in all our business activities. This Compliance Policy serves to inform our stakeholders and other interested parties about our compliance policies and procedures, including our commitment to anti-corruption, zero tolerance of misconduct, adherence to tax and competition laws, compliance with anti-money laundering (AML) regulations, and governance body commitment.

Transparent and Ethical Business Conduct

At our organization, transparent and ethical business conduct is paramount. We expect all our employees and stakeholders to act with honesty, integrity, and professionalism in all their interactions, both within and outside the organization. Our commitment to transparent and ethical business conduct includes:

1. Anti-Corruption: Our organization strictly prohibits any form of corruption, bribery, or unethical conduct, whether it involves public officials, business partners, or any other individual or entity. We comply with all applicable laws and regulations related to anti-corruption, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other relevant local laws. Our employees and stakeholders are required to report any suspected or actual instances of corruption or bribery immediately to the designated compliance officer.
2. Zero Tolerance of Misconduct: Our organization has a zero-tolerance policy towards misconduct, including fraud, embezzlement, theft, insider trading, and other unethical behaviors. Any employee or stakeholder found to be engaged in such conduct will face disciplinary action, up to and including termination, and may be subject to legal action.

Adherence to Tax and Competition Laws

Our organization is committed to full compliance with all applicable tax and competition laws. We strive to accurately report our financial information, including income, expenses, and other financial transactions, in accordance with applicable tax laws. We also comply with competition laws and regulations, including those related to anti-trust and fair competition, and do not engage in any anti-competitive behaviors such as collusion, price-fixing, or market manipulation.

Compliance with Anti-Money Laundering (AML) Regulations

Our organization is fully committed to compliance with all AML regulations and takes necessary measures to prevent money laundering and terrorist financing activities. We have established robust policies and procedures to identify, verify, and report suspicious activities or transactions in accordance with applicable laws and regulations. Our employees are trained to recognize and report any suspicious activities or transactions to the  compliance function for further investigation.

Governing Body Commitment and Tone at the Top

Our organization's governing body is fully committed to promoting a culture of compliance and setting the tone at the top. They are responsible for establishing and maintaining an effective compliance management system (CMS) that includes policies, procedures, and controls to ensure compliance with applicable laws and regulations. They lead by example and demonstrate a commitment to transparency, integrity, and ethical business conduct in all their actions and decisions.

Regular Management Review and Oversight of the CMS

Our organization conducts regular management reviews and oversight of the CMS to ensure its effectiveness and adherence to compliance policies and procedures. This includes monitoring and reporting on compliance activities, conducting risk assessments, identifying and addressing compliance gaps or deficiencies, and taking appropriate corrective actions. The designated compliance function reports directly to the governing body and provides regular updates on the status of the CMS and any compliance issues or concerns.

Conclusion

At SFS Ventures LLC we are committed to maintaining the highest standards of compliance, transparency, and ethical business conduct. By upholding these principles, we can achieve our mission while building trust with our customers, partners, and the communities we serve.

Contact:

compliance@sfs-ventures.com