Money Laundering and Terrorist Financing have been identified as major threats to CJS Payroll Limited and, indeed, the international financial services community. The United Kingdom, along with many other countries, has passed legislation to prevent money laundering and combat terrorism.
The principal requirements, obligations and penalties on which our company’s financial crime systems and controls are based derive from:
CJS Payroll Limited is responsible for the following policies covering:
These policies and principles are designed to ensure that all group companies comply with the legal and regulatory requirements in the UK and with their local obligations.
Our company’s AML policy is designed to ensure compliance with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate risks in firms that are used to facilitate financial crime. The AML policy sets out the minimum standards, which all our companies must comply with and includes:
All employees receive training on the Anti-Money Laundering and Counter-Terrorist Financing policies and principles at least once a year, with more detailed and advanced training for those whose roles involve major financial risks. Failure to comply with these policies and principles may give rise to disciplinary action, up to and including dismissal.
We have a zero-tolerance policy toward bribery and corruption. Our company recognises that bribery and corruption adversely affect communities wherever they occur. They can threaten laws, democratic processes and fundamental human freedoms while distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, on occasion, the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.
We are committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Fie is subject to the provisions of the UK bribery act 2010 and the US foreign corrupt practices act, which have an extra-territorial effect globally, as well as applicable local anti-bribery laws in relevant jurisdictions.
In addition to the anti-bribery and anti-corruption policy, our company has an introducer clause described in the Introducer agreement. The clause covers the activities of all third parties that generate or retain business or secure a business benefit for us. These third parties are termed “introducers” by CJS Payroll Limited. Potential examples would include senior advisors, lead generators, and existing clients of CJS Payroll Limited. Our introducer policy protects CJS Payroll Limited against bribery and corruption risks, reputational risk, and broader operational and conduct risks associated with introducers. Our employees must apply the specific controls and procedures set out in the policy.
Regular reviews of the effectiveness of these group policies are carried out in addition to audits periodically undertaken by CJS Payroll Limited’s internal audit function. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regarding the operating effectiveness of the group’s controls relating to these policies.
