The Man­ag­ing Board and all other staff of ElPhylPlc. in­clud­ing its branches, li­ai­son of­fices and  sub­sidiaries (here­inafter col­lec­tively ‘ElPhylPlc.’) endeavor to main­tain a com­pany cul­ture and busi­ness strat­egy whereby ElPhylPlc.’s core and base val­ues and stan­dards of pro­fes­sional con­duct are main­tained at every busi­ness level and within all its ac­tiv­i­ties. These stan­dards in­clude na­tional, in­ter­na­tional and Eu­ro­pean leg­is­la­tion, reg­u­la­tions is­sued by the rel­e­vant lo­cal (su­per­vi­sory) au­thor­i­ties, gen­er­ally ac­cepted busi­ness stan­dards and ElPhylPlc.’s own in­ter­nal stan­dards (in­clud­ing eth­i­cal stan­dards).

ElPhylPlc. en­deav­ors to con­tribute to the global fight against fi­nan­cial and eco­nomic crime, such as money laun­der­ing. For this, it has de­vel­oped and main­tains a sound frame­work, which in­cludes poli­cies, pro­ce­dures, processes and pe­ri­od­i­cal train­ings to staff mem­bers on fi­nan­cial and eco­nomic crime pre­ven­tion.

ElPhylPlc. does not tol­er­ate tax eva­sion, be­ing a vi­o­la­tion of (in­ter)na­tional law. At the same time, it rec­og­nizes that the le­gal es­tab­lish­ment, busi­ness struc­tures and trans­ac­tions of some (le­gal) en­ti­ties can be mo­ti­vated by tax in­cen­tives, ex­emp­tions, or other tax ben­e­fits legally of­fered by spe­cific (off­shore) ju­ris­dic­tions or specialized tax com­pa­nies. It is a well-known fact that tax con­sid­er­a­tions (reg­u­lar tax plan­ning) play a part in com­pa­nies and pri­vate in­di­vid­u­als set­ting up a le­gal struc­ture. ElPhylPlc. there­fore specif­i­cally as­sesses the risks of tax avoid­ance to as­cer­tain that tax rea­sons are not the only rea­son for the busi­ness struc­tur­ing and/or reg­is­tra­tion in off­shore ju­ris­dic­tions of its cus­tomers. Un­der no cir­cum­stances ElPhylPlc. will ac­cept or con­done ac­tiv­i­ties or behavior that will or might in any way con­flict with any of its core and base val­ues and stan­dards.

ElPhylPlc. is com­mit­ted to cre­ate value for its cus­tomers whilst meet­ing its statu­tory and reg­u­la­tory oblig­a­tions. This in­cludes main­tain­ing a fraud and cor­rup­tion pre­ven­tion cul­ture. ElPhylPlc.’s core and base val­ues and stan­dards, gov­er­nance and risk man­age­ment frame­works, and con­trols work to­gether to pre­vent, de­tect and re­spond to po­ten­tial or ac­tual fraud­u­lent or cor­rupt con­duct. To en­sure ElPhylPlc. un­der­stand at all times the in­tegrity risks ￚ also re­ferred to as com­pli­ance risks ￚ it is fac­ing, in­tegrity risk as­sess­ments are un­der­taken pe­ri­od­i­cally to de­ter­mine how these risks are mit­i­gated by the con­trols that have been im­ple­mented and to es­tab­lish whether the resid­ual risk level is within CE­B’s in­tegrity risk ap­petite. ElPhylPlc. staff are pro­vided with train­ing and com­mu­ni­ca­tion in ethics and com­pli­ance, in­clud­ing fraud and cor­rup­tion pre­ven­tion, to un­der­stand their re­spon­si­bil­i­ties and oblig­a­tions in ob­serv­ing and main­tain­ing high stan­dards of in­tegrity in all ElPhylPlc.’s busi­ness deal­ings.

The Man­ag­ing Board has adopted a Com­pli­ance Char­ter and val­i­dated com­pli­ance poli­cies on spe­cific top­ics with the sole pur­pose of em­bed­ding the in­tegrity prin­ci­ples of ElPhylPlc. in all lev­els and struc­tures of its organization. The in­tegrity prin­ci­ples iden­ti­fied by ElPhylPlc. are grouped in four (4) cat­e­gories: staff in­tegrity, cus­tomer in­tegrity, organization in­tegrity and ser­vices in­tegrity. By im­ple­ment­ing these prin­ci­ples in all lev­els and struc­tures of its organization, ElPhylPlc. in­tends (i) to pro­tect its as­sets from any form of loss or dam­age and (ii) to avoid fur­ther any kind of neg­a­tive pub­lic­ity for its or­ga­ni­za­tion.

Al­though the Man­ag­ing Board has the over­all re­spon­si­bil­ity for en­sur­ing com­pli­ance, it is im­por­tant to stress that all staff of ElPhylPlc. have a duty in re­spect of com­pli­ance. There­fore, the mit­i­ga­tion of any com­pli­ance risk is a shared re­spon­si­bil­ity. For this, ElPhylPlc. ap­plies a three lines of de­fense model:

• The first line of defense is formed by management and business which are ￚas stated hereinabove ￚprimarily responsible for the implementation and maintenance of proper control measures with respect to compliance.
• The second line of defense is formed by the risk management functions ￚincluding the compliance function ￚ that support the first line of defense functions and provide advice on the implementation and maintenance of compliance.
• The third line of defense is formed by the internal audit function, which assesses the functioning and effectiveness of the business units and the risk management and compliance activities.

As com­pli­ance is strongly re­lated to so­cially ac­cepted stan­dards and so­ci­ety is con­stantly chang­ing, ElPhylPlc.’s method of mit­i­gat­ing any com­pli­ance risk is sub­ject to con­stant eval­u­a­tion and up­grade.

Please find on this web­page fur­ther in­for­ma­tion on the mea­sures taken by ElPhylPlc. to fight against money laun­der­ing and ter­ror­ist fi­nanc­ing, and to deal with po­ten­tial con­flicts of in­ter­ests.

 
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