Anti-Money Laundering Policy
We take our responsibilities under laws aimed at the prevention of financial crime seriously. This policy sets out what we do to minimise the risk that we will be exposed to money laundering in the course of what we do.
What we do
We are an industry association focused on representing the needs and views of those in the chemicals business in the UK, and we operate only in the UK. Our membership consists of manufacturers, processors, formulators, importers and exporters, distributors and chemical technology developers who operate in the UK, with associate members who provide services to chemical companies. Our work consists of representing our members in considering and publishing papers on policy issues and guidance for our members, and providing fora for our members to come together to attend training courses on all aspects of operating chemical and pharmaceutical businesses in the UK, exchange views or meet to recognise the achievements of those in the industry. Part of the work of our Sustainability Steering Group helps members to share best practice in areas of governance, to help them address the risks they face, including compliance and bribery and corruption. We also work to encourage future leaders in our industry.
Our anti-money laundering obligations
In common with anyone else doing business in the UK, we are subject to the UK laws that criminalise a range of activities relating to money laundering and terrorist finance, in particular the Proceeds of Crime Act 2002 and the Terrorism Act 2000. We take measures to identify the risks we face from, and to protect ourselves against the risks of committing, offences under those laws relating to becoming involved in arrangements that facilitate the retention of the proceeds of crime, or relating to acquiring, possessing, using, concealing or transferring the proceeds of crime.
Our business does not fall within the "regulated sector" for the purposes of anti-money laundering legislation. As a result, we are not obliged to carry out detailed risk assessments, conduct legally required due diligence on those with whom we do business, appoint a nominated reporting officer for money laundering suspicions or train our staff.
However, as a matter of good practice and corporate governance, we have in place a number of systems and controls to both minimise the risk that we will be exposed to money laundering and identify and address any potential issues that arise.
Our anti-money laundering policy
Given the nature of our membership and our business, we have assessed that our money laundering risk is low. We take the following steps further to mitigate this:
- Our members are UK based businesses, many of whom are household names, and almost all of whom are registered at Companies House and/or appear on professional services or similar registers. [When we receive an application for membership, we request and review information about the applicant's business and those individuals within the business who we are entitled to deal with. Should we have any doubts that the applicant is the business they claim to be, or do not receive the information we need about the business, we would ask further questions and may refuse an application].
- We expect our members to make any payment due from them to us by bank transfer, from an account with a UK authorised financial institution or institution in another reputable jurisdiction. Any payment received from any other account, or any over-payment, is flagged and investigated by our finance team.
- If we need to make a refund or other payment to a member, we will do so only to their known bank account, from which we receive payments from them.
- We apply similar requirements, as appropriate, to any other person with whom we do business.
- In the unlikely event of any suspicious activity on the part of any member, our relevant staff are trained to recognise what might be suspicious and to report their concerns to the Finance Director, who will, in conjunction with the Chief Executive decide on whether it is necessary to make a report to the National Crime Agency.
We review our policy annually to assess how any concerns have been dealt with and whether we need to make any changes to the policy.
July 2019