Money laundering and terrorist financing are a source of serious concern for the financial system of European Union member countries and the security of its citizens. The Management of MetalLogic, realizing the seriousness of this issue, the legal consequences that may arise from such activities, as well as the effects they will have both on the reputation and value of the company and on its personnel, maintains transparency regarding its transactions, while ensuring the legality of all its activities and actions. For this reason, MetalLogic fully complies with Law 4557/2018 on the prevention and suppression of money laundering and the financing of terrorism
DEFINITIONS - ABBREVIATIONS
ML/FoT: Abbreviation of the term “Money Laundering / Financing of Terrorism”. The terms Money Laundering and Financing of Terrorism have the same meaning.
Policy: This is MetalLogic’s policy for addressing the risk of AML/CFT.
Compliance Officer: In the case of MetalLogic, the Compliance Officer is the person designated at corporate level (pursuant to the provisions of articles 36 and 38 of Law 4557/2018) in order to coordinate the activities of the Compliance Officers of all the company’s trading parties and to exchange relevant information with them, where required.
FIELD AND MEANS OF IMPLEMENTATION
This policy extends to and concerns all trading and interested parties. For this reason it is communicated by any appropriate means. Compliance with the provisions of this policy is mandatory and binds the parties to do everything possible to prevent and suppress ML/FoT. Stakeholders’ commitment to comply with this policy is sought through various means, such as a signed declaration of acceptance of MetalLogic’s Code of Conduct, or the inclusion and signature of specific terms in its contractual documents.
MetalLogic seeks the continuous information and training of its employees in matters of combating ML/FoT and the consistent implementation of the required controls and procedures on a case-by-case basis. The Management of MetalLogic, following the recommendation of the Compliance Officer, is the competent body for approving this policy and processing it in the event of the need for its revision in case that:
- Significant changes occur in the company’s organizational structure
- New products or services are introduced or there is a material modification of existing products/services provided
- Changes are noted in the relevant legislative/regulatory framework
- The company deems that relevant processing and revision is necessary.
The Compliance Officer ensures that MetalLogic employees are informed and fully aligned with its efforts to eliminate the risk of ML/FoT.
MetalLogic
POLICY
MetalLogic, its staff, as well as its partners, in order to eliminate the risk of ML/FoT must comply with the provisions of this Policy according to the following:
- Understanding and applying this policy as well as all due diligence measures as described therein.
- Informing those dealing with MetalLogic regarding the following policy
- Constant vigilance to detect suspicious or unusual transactions, customer behavior and relevant internal reporting in case of non-compliance with existing policy.
- Participation in educational activities related to the information and prevention of the phenomenon of ML/FoT.
- Respect for the confidentiality of information regarding customers who are being investigated for illegal activities.
- Respond promptly to requests by MetalLogic or the Compliance Officer for written, oral or other information related to customer and partner transactions.
- Ensuring the maximum possible level of security of the information registered and processed
In order to identify and prevent ML/FoT incidents, MetalLogic applies a due diligence process by adopting a series of measures and performing various tasks. Due diligence measures are implemented by MetalLogic in advance of entering into any business relationship or conducting transactions. A basic requirement is knowledge of the partner (KYP) and knowledge of the customer (KYC). In this way MetalLogic ensures specific measures and conditions.