Financial Risks Policy

Anti Money Laundering, Financing Terrorism, Criminal Activity, Tax Evasion and Sanctions Policy (collectively Financial Risks Policy – FRP).

​The Someya Group Limited is aware of the risk of third parties exploiting us to engage in money laundering or financing of entities under sanction, financing terrorism, criminal activity, tax evasion.

We do not assist, support, tolerate, participate in or permit money laundering, terrorist financing or entities under sanction.

We do not accept money or other assets if we know or suspect that they derive from any kind of criminal activity. We do not knowingly deal with criminals, suspected criminals, or the proceeds of crime.

We do not facilitate the acquisition, ownership or control of criminal proceeds or other assets deriving from criminal activity nor do we assist others in concealing criminal proceeds or assets.

We do not tolerate tax evasion of any kind and we do not knowingly or wilfully facilitate tax evasion. We implement procedures to prevent the facilitation of tax evasion by our people and others acting on our behalf.

We do not facilitate the acquisition, ownership or control or financing or proceeds or any business activity associated with nations, companies and individuals that are under sanction imposed by the USA, Europe, UK, and other nations.

​To manage our FRP and ensure compliance, Trillium Group Limited implements several controls and processes. These include:

Conducting extensive Know Your Counterparty (KYC) and due diligence procedures to determine the background and identity of our counterparties; and

Implementing controls in respect of payments we make and receive using a risk-based approach to ensure that they are consistent with the requirements of this policy; and

We require employees/associates to be alert to any unusual or suspicious arrangements which could expose us to the risk of money laundering or the facilitation of tax evasion or the breaking of sanctions rules, and to report such arrangements to Compliance; and

Reporting to appropriate authorities of any infringement or suspicious activity connected with any of the above.

​This policy applies to all employees, directors, and officers, as well as contractors/associates under The Someya Group Limited’s direct supervision, working for a The Someya Group Limited office or asset directly or indirectly controlled or operated by The Someya Group Limited.

We actively assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with the intent of this policy.