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- ANTI BRIBERY & CORRUPTION POLICY STATEMENT
- CRIMINAL FINANCE ACT 2017 POLICY STATEMENT
- MODERN SLAVERY STATEMENT
- SANCTIONS AND SCREENING POLICY
ANTI BRIBERY & CORRUPTION POLICY STATEMENT
Pursuant to the relevant law, regulations, codes of practice and/or regulatory guidance regarding anti-bribery and anti-corruption applicable in each of Ocorian’s jurisdictions, Ocorian has in place an anti-bribery and anti-corruption policy (the Policy) supported, where relevant, by appropriate procedures. The Policy prohibits (inter alia) the making, offering or promising to make, requesting, accepting or receiving a payment (including any service, gift or entertainment) for any improper purpose or business advantage. The Policy applies to all employees of Ocorian and its group companies and all business undertaken and structures administered by those entities.
Ocorian is committed to achieving the highest standards of ethical conduct and to ensuring that its employees and external parties who may provide services on its behalf, act in compliance with applicable legislation. This includes compliance with all laws, domestic and foreign, prohibiting improper payments or inducements to any person, including Public Officials (as defined under applicable law).
Before any transactions occur or services are provided, Ocorian will require confirmation of awareness of the applicable law from all clients (by means of an Engagement Letter (or equivalent)) and relevant third parties, such as consultants, those holding power of attorneys and those to whom Ocorian has outsourced or delegated a function (by means of an appropriate declaration), together with
confirmation that, where relevant, they have in place appropriate anti-bribery and anti-corruption policies and procedures of their own; or otherwise conduct themselves in such a manner as to adhere to the applicable law and this policy statement. Where deemed appropriate, Ocorian will also carry out additional due diligence. All payments must be made on clear payment terms (including clarity in relation to what is being paid for).
Ocorian has procedures in place requiring the reporting of any knowledge or suspicion that any client, relevant third party or employee is involved in any way in bribery or corruption.
CRIMINAL FINANCE ACT 2017 POLICY STATEMENT
As a firm, we value our reputation for ethical behaviour and for financial probity and reliability. We do not
tolerate tax evasion, or the facilitation thereof in any circumstances, where committed by or facilitated by a
client, personnel or associated persons/companies.
We are committed to fighting tax evasion and have rigorous policies and procedures in place to detect and
prevent the facilitation of tax evasion offences.
We provide regular training on the requirements of the Criminal Finances Act 2017 to all personnel.
We require all personnel to demonstrate the highest standards of honesty at all times and appropriate
disciplinary action will be taken wherever tax evasion or the facilitation thereof by any personnel has been
We undertake due diligence on all associated persons/companies to mitigate the risk of the facilitation of tax
MODERN SLAVERY STATEMENT
What is modern slavery?
Modern slavery is a fundamental breach of human rights. It is a global industry which takes many forms, such
as slavery, servitude, forced or compulsory labour, and human trafficking. It is the responsibility of
organisations and individuals around the world to eradicate this practice which, according to a 2016 UN study,
claimed more than 40 million victims in that year alone. It is, therefore, of critical importance that
organisations ensure that slavery and human trafficking are not taking place in their businesses or in any of
their supply chains.
The law on modern slavery
The Modern Slavery Act 2015 came into force in the UK on 29 October 2015. It created specific offences aimed
at tackling slavery and human trafficking. The legislation also requires commercial organisations, incorporated
or carrying on business in the UK, supplying goods or services with a turnover in excess of £36 million, to
publish a slavery and human trafficking statement each financial year in order to demonstrate the steps it has
taken to ensure that slavery or human trafficking are not taking place in its business or its supply chains.
Ocorian is a global business with 1600+ staff in 20 international locations. While Ocorian is a provider of
financial services, the business has a number of suppliers, consultants and contractors working in a range of
sectors such as catering, facilities management, office services, information technology and marketing.
Ocorian has in place a comprehensive due diligence process for each of our clients in a number of our
jurisdictions and we are committed to implementing this across the business as we continue to expand. We
also have in place an on‐boarding process for employees in each jurisdiction which complies with national
laws, such as evidence of right to work, contracts of employment and ensuring employees or apprentices are
16 or over.
The business is committed to corporate social responsibility, the purpose of which is to build relationships and
leave a lasting legacy on society and the environment.
In the sector in which Ocorian operates the risk of modern slavery is low but that does not mean that we take
our responsibilities lightly. While we have in place a number of controls and initiatives to tackle modern
slavery and other criminal behaviour, there are still steps we want to take in order to ensure that such
abhorrent practices do not form part of our business or the businesses of our clients.
The highest risk of modern slavery would be in our supplier chains, especially in high‐risk sectors such as
catering and office services, as well a business undertaken in high‐risk locations. It is our responsibility to
ensure that those with whom we enter into business are not involved in slavery or human trafficking at any
stage in the provision of their services.
The approach taken to approve and monitor each client will be proportionate depending on the client's (and
its sector's) risk‐rating. Our aim is to make all clients and suppliers aware of our collective responsibilities in
relation to modern slavery and put in place systems and controls to monitor suppliers across jurisdictions in
accordance with their assigned risk‐rating.
Ocorian is committed to making all employees aware of modern slavery and its ramifications as well as putting
in place a procedure, as part of our whistleblowing policy and procedure, for confidentially reporting any
suspicion of slavery or human trafficking.
The Ocorian group, and the entities which fall thereunder, adopts a zero‐tolerance approach to slavery and
human trafficking and all forms of corruption and bribery directly and indirectly associated with these criminal
We are committed to ensuring that slavery or human trafficking does not form part of our, or our clients’,
business. We also aim to support a culture where any suspicion of modern slavery is raised with us in
confidence and without delay.
Ocorian's slavery and human trafficking statement is reviewed annually.
SANCTIONS AND SCREENING POLICY
Pursuant to the relevant law, regulations, codes of practice and/or regulatory guidance pertaining to sanctions and screening applicable in each of Ocorian’s jurisdictions, Ocorian has in place a sanctions and screening policy (the Policy) supported, where relevant, by appropriate procedures. The Policy prohibits (inter alia) the conduct of any business that would breach any part of a sanction or embargo. The Policy applies to all employees of Ocorian, and its group companies and all business undertaken, and structures administered by those entities.
Ocorian is committed to achieving the highest standards of ethical conduct and to ensuring that its business is conducted in a manner which adheres to and upholds both the spirit and the letter of applicable sanctions and embargoes. This includes continually monitoring and ensuring compliance with local and international sanctions and embargoes, including those issued by the US Office of Foreign Assets Control, the United Nations, the European Union, the United Kingdom, and other relevant individual government bodies.
Before any transactions occur or services are provided, Ocorian will determine whether an applicant for business or client, an owner or controller of that applicant or client, or a third party on whose behalf the applicant or client acts, is itself or is involved or does business with a sanctioned or embargoed person, regime, or jurisdiction. The Policy does not prohibit Ocorian from dealing with persons connected with sanctioned regimes or jurisdictions, provided that the sanctions or embargoes are not relevant to that person, or an asset or activity of that person.
As part of Ocorian’s new business take on policy, Ocorian will require confirmation of awareness of the applicable law from all clients and their agreement not to undertake any activities, business or transactions which may contravene relevant sanctions and embargoes, applicable law, or this policy statement.
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