Financial Crime

InfraCo Asia has zero tolerance for fraud, bribery, corruption, money laundering, tax evasion, insider dealing and the financing of terrorism  (Financial crime).

In this regard, InfraCo Asia has put in place policies and procedures to counter the risk of Financial crime within InfraCo Asia’s operations and to assist in compliance with the applicable laws relevant to countering fraud, bribery and corruption in the jurisdictions in which InfraCo Asia operates  (Financial crime policies). InfraCo Asia Financial crime policies are consistent with PIDG’s Anti-corruption and Integrity Policy and Procedures.

Reporting

The success of implementing Financial crime policies depends on all employees and anyone acting on InfraCo Asia’s behalf playing their part in helping to mitigate the risk of, and to prevent where possible, Financial crime.  All employees and anyone acting on behalf of InfraCo Asia are encouraged to report any suspected or actual Financial crime to :

– their line manager;
– their designated Local Compliance Officer (LCO);
– the InfraCo Asia Local Compliance Officer (ILCO);
– the InfraCo Asia compliance email address at compliance@infratest.tryangled.online; and/or
– the InfraCo Asia designated Safecall anonymous compliance hotline;

(collectively, referred to as the Compliance authorities)

Investigation

If Financial crime is detected to have occurred, it will be appropriately investigated and, where necessary, reported to the relevant authorities.

Compliance team

We have a designated legal and compliance team, who have the necessary authority and independence to oversee the effectiveness of our policy and procedures.

Protection assurance for reporters of Financial crime

We do not tolerate harassment or victimisation of individuals validly raising a concern or reporting a Financial crime in good faith. Every reasonable effort will be made to protect the subject individual from retaliation, discrimination or disciplinary action for such action. Designated Compliance authorities commit to treat subject reports with confidence in accordance with the applicable laws and the applicable InfraCo Asia policies and procedures, particularly where reports contain personal data.

Regular review

We will monitor the effectiveness of our policy and procedures regularly and will implement improvements that are necessary to enhance their effectiveness. Changes to the policy and procedures will be made available to relevant parties using appropriate communication channels.

Consequences of not complying

We commit to not conduct business with anyone that does not support our anti-Financial crime objective. If InfraCo Asia is aware of violations of any sort from internal stakeholders, this may result in disciplinary action up to and including dismissal.