Money Laundering (ML) and Anti-Bribery & Corruption (ABC) Policy 2025/2026

FinREV Plus Ltd

This combined Anti-Money Laundering (ML) and Anti-Bribery & Corruption (ABC) Policy sets out FinRev Plus Ltd’s (“FinRev+”) commitment to preventing financial crime, bribery, and corruption in all forms. It is issued in accordance with the UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, Terrorism Act 2000, and the UK Bribery Act 2010.

Part A – Money Laundering (ML) Policy

1. Introduction
FinRev+ operates a zero-tolerance approach to money laundering and terrorist financing. We are committed to conducting business in accordance with the highest ethical standards and in compliance with all relevant UK laws and regulations.
2. Scope
This policy applies to all directors, contractors, subcontractors, and suppliers engaged by FinRev+. It governs how we assess, monitor, and manage risks of money laundering and financial crime across both client and supplier relationships.
3. Customer Due Diligence (CDD)
– Verify the identity of all clients before commencing work.
– Identify and verify the ultimate beneficial owners (UBOs) of client companies.
– Apply enhanced due diligence for high-risk clients, politically exposed persons (PEPs), or clients in high-risk jurisdictions.
– Maintain clear records of CDD processes and verification steps.
4. Supplier and Subcontractor Due Diligence
FinRev+ applies proportionate due diligence to suppliers, subcontractors, and partners. We require written confirmation that they comply with applicable UK ML legislation, financial crime regulations, and sanctions regimes. Payments will only be made to suppliers in their legal entity name and through approved banking channels. Any supplier or subcontractor failing to meet these standards will be removed from our supply chain.
5. Risk-Based Approach
We conduct risk assessments of new clients, projects, and suppliers, considering factors such as geography, sector, transaction size, and complexity. Enhanced checks will be applied to engagements assessed as high-risk.
6. Ongoing Monitoring
We monitor client activity, supplier relationships, and engagements for unusual or suspicious transactions. Where required, enhanced scrutiny will be applied to ongoing relationships.
7. Record Keeping
All due diligence records, risk assessments, and transaction monitoring records are retained for a minimum of 5 years, in compliance with UK regulations.
8. Reporting Suspicious Activity
If any director, contractor, or subcontractor suspects money laundering or terrorist financing, they must immediately report it to the Nominated Officer (ML Officer) at FinRev+. The ML Officer is responsible for assessing the suspicion and, if appropriate, filing a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA).
9. Training and Awareness
Although FinRev+ does not employ staff, all directors and relevant subcontractors must be aware of their obligations under UK ML legislation. Periodic awareness reminders will be provided, and compliance will be monitored as part of our onboarding and supplier engagement processes.
10. Responsibility
The Director of FinRev+ is designated as the ML Officer and has responsibility for ensuring compliance with this policy, including oversight of due diligence, monitoring, and reporting obligations.
11. Review
This policy will be reviewed annually and updated as required to remain compliant with UK law and industry expectations.

Part B – Anti-Bribery & Corruption (ABC) Policy

1. Introduction
FinRev+ is committed to conducting business fairly, transparently, and in compliance with the UK Bribery Act 2010. We prohibit bribery and corruption in all forms and will uphold all applicable anti-bribery laws wherever we operate.
2. Scope
This policy applies to all directors, contractors, subcontractors, partners, and suppliers of FinRev+. It extends to all jurisdictions in which FinRev+ conducts business, including the UK and international markets.
3. Prohibited Conduct
Under this policy, the following conduct is strictly prohibited:
– Offering, promising, giving, requesting, or accepting a bribe in any form.
– Facilitation payments (‘grease payments’) made to secure or speed up routine government action.
– Kickbacks or secret commissions.
– Gifts, hospitality, or expenses intended to improperly influence business decisions.
– Any other activity that could be considered corrupt under the UK Bribery Act 2010 or local laws.
4. Gifts and Hospitality
Reasonable and proportionate gifts and hospitality may be permitted if they are:
– Occasional and of modest value;
– Clearly given as a gesture of goodwill and not intended to improperly influence a decision;
– Compliant with local law and cultural norms; and
– Declared to and approved by the Director of FinRev+ prior to acceptance or provision.

Any gifts or hospitality that could be perceived as a bribe must be refused.
5. Third Parties and Suppliers
FinRev+ requires all subcontractors, suppliers, agents, and partners to comply with this policy. We will not engage in business with third parties who are known or reasonably suspected to engage in bribery or corruption. Written confirmation of compliance may be required as part of our onboarding and due diligence processes.
6. Risk Assessment
FinRev+ recognises that certain jurisdictions and sectors carry higher risks of bribery and corruption, particularly where we may operate in international markets or emerging markets. We will assess bribery risks on a case-by-case basis and apply enhanced due diligence where necessary.
7. Reporting Concerns
Directors, contractors, subcontractors, or suppliers must report any suspicion or knowledge of bribery or corruption immediately. Reports should be made directly to the Director of FinRev+. Concerns will be treated confidentially and investigated appropriately. Whistleblowers will be protected from retaliation.
8. Record Keeping
FinRev+ will maintain accurate and transparent records of all financial transactions, gifts, hospitality, and third-party engagements. False or misleading records are strictly prohibited.
9. Responsibility
The Director of FinRev+ is responsible for overseeing compliance with this policy and ensuring proportionate procedures are maintained to prevent bribery and corruption in line with the UK Bribery Act 2010.
10. Review
This policy will be reviewed annually and updated as necessary to ensure it remains compliant with UK law and reflects FinRev+’s operations.

Signed By,
Rivana Vavshack – Mazerska
Director, FinRev Plus Ltd
Date: 04/07/2025