Anti-Economic Crime Policy

1. Policy Statement

One Touch Data Ltd is committed to preventing all forms of economic crime, including but not limited to fraud, bribery, corruption, money laundering, tax evasion, terrorist financing, and sanctions violations, across its business and supply chain. We operate with zero tolerance for knowingly facilitating or appearing to facilitate any such activities.

2. Scope

This policy applies to all employees, contractors, consultants, officers, directors, and suppliers of One Touch Data Ltd, as well as any third parties acting on our behalf.

3. Our Commitments

  • Compliance: Adhere strictly to all applicable laws and regulations, including the Bribery Act 2010, UK Money Laundering Regulations, and relevant international standards.
  • Prevention: Implement robust controls to deter, detect, and respond to economic crimes such as fraud, bribery, money laundering, terrorist financing, and tax evasion.
  • Risk Assessment: Conduct regular risk assessments to identify and mitigate exposure to economic crime; apply enhanced controls where higher risks are identified (e.g., politically exposed persons, high-risk jurisdictions).
  • Due Diligence: Perform initial and ongoing due diligence on suppliers, customers, employees, and third parties, including identity verification and screening for adverse media.
  • Monitoring: Monitor transactions and business relationships for signs of suspicious activity, and report findings to relevant authorities as required.
  • Training: Provide regular, mandatory training for staff on economic crime risks, reporting obligations, and controls.
  • Reporting: Encourage employees and partners to report any suspicions of economic crime, ensuring protection under the company’s whistleblowing policy.
  • Offboarding: Terminate business relationships where economic crime risks cannot be adequately mitigated or where due diligence requirements are not met.
  • Collaboration: Cooperate with law enforcement, regulatory bodies, and industry groups to identify, prevent, and respond to economic crime threats.

4. Responsibilities

  • Senior management is responsible for oversight and accountability of the company’s economic crime framework.
  • All employees and associates must comply with this policy and report suspected or actual breaches promptly.

5. Review

This policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, and economic crime trends