CORPORATE OVERVIEW

​

Corporate Infrastructure, Scope of Operations & Philosophy: Westsphere BKK operates globally and takes pride in its continent-spanning reputation for integrity and honesty. It is essential that Westsphere BKK employees, counter-parties, and all those associated with Westsphere BKK, protect that reputation. Money laundering, bribery and corruption are criminal offenses. In addition to the fines, penalties and reputational harm that Westsphere BKK may suffer, such activities can lead to untoward human rights abuses and conflict financing. Employees, counterparties and all those associated with Westsphere BKK involved in money laundering, bribery and corruption will be terminated. Third parties doing business with Westsphere BKK are expected to comply with all applicable laws and adhere to our policies and contract provisions relating to the prevention of money laundering, bribery and corruption. As a leader in the precious and other metal smelting supply chain, Westsphere BKK recognizes it is uniquely positioned to detect and prevent commercial activities that contribute to illegal activities. Westsphere BKK works with its employees and counter parties to ensure they are aware of our policies and procedures and that the materials intermediated by Westsphere BKK do not contribute to such illegal activities.

 

ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

 

Internal Controls, Procedures & Compliance Management: Westsphere BKK’s integrated anti-money laundering (“AML”), know our customer (“KYC”) and chain of custody (“COC”) policies, procedures and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a periodic basis. Westsphere BKK employs on boarding procedures to insure its understanding of the nature, scope, motivation and provenance of those with whom it engages. Westsphere BKK’s Management periodicaly reviews Westsphere BKK’s policies, procedures and internal controls with professional international audit, taxation and legal counsel to ensure their ongoing efficacy. Further, Westsphere BKK submits to external periodic independent audit of its compliance regimen. Westsphere BKK’s management is vested with responsibility for enforcement and as such a working knowledge  with related statutory regimes including but not limited to: The foreign corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended. Accordingly, Westsphere BKK complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if Westsphere BKK uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: Westsphere BKK is committed to a zero-tolerance approach to money laundering, bribery and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner; (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery and corruption; (iii) implement and enforce effective systems to counter the risk of money laundering, bribery and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing Counter-Party either refuses to provide the information requested, or appears to have intentionally provided misleading information, Westsphere BKK will terminate engagement with that entity or individual Westsphere BKK maintains AML and KYC documentation regarding each counter-party and transaction. Westsphere BKK maintains ongoing employee training under the leadership of a designated Compliance Officer Westsphere BKK’s training is based on its policies, procedures and internal controls as well as applicable statues and regulations. Westsphere BKK’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees’ roles in compliance efforts; (iv) record retention; and (v) disciplinary consequences of non compliance.