Modern Slavery & Human Trafficking Statement

TM PHARMA GROUP Limited, a company incorporated under the laws of England and Wales and has its registered office at 1st & 2nd Floor, 2 West Street, Ware, Hertfordshire, England. SG12 9EE (hereinafter referred to as the “Service Provider” or “TM Pharma” or “TMPG“), which expression shall, unless it be repugnant to the context or meaning thereof, mean and include its successors and permitted assigns, through its Director / Authorised Signatory Tracy Moore.

1. Purpose

The purpose of this document is to make all employees & contractors aware of the strict money laundering policy that TMPG follows. The company is committed to the highest standards of openness, transparency, and accountability and to conducting its affairs in accordance with the requirements of the law and regulatory bodies. TMPG has a zero-tolerance approach to money laundering and the policy applies to activity both at home and abroad and to any activity with contracted partners.

2. Definitions & Legislative Context

The Money Laundering, Terrorist Financing & Transfer of Funds Regulations 2017 (MLR 2017) came into force on 26 June 2017. They implement the EU’s 4th Directive on Money Laundering. In doing so, they replace the Money Laundering Regulations (MLR 2007). The UK Anti-Money Laundering (AML) framework also incorporates the Proceeds of Crime Act 2002. TMPG are also aware of additional changes by which regulation 9 amends regulation 30A(1) of the MLRs (discrepancy reporting) and other changes with effect from 1st April 2023.

MLR 2017 adopts a more risk-based approach towards anti – money laundering and how due diligence is conducted.

Money laundering is the process of taking profits from crime and corruption and transforming them into legitimate assets. It takes criminally-derived ‘dirty funds’ and converts them into other assets so they can be reintroduced into legitimate commerce. This process conceals the true origin or ownership of the funds, and so ‘cleans’ them.

There are three stages in money laundering; placement, layering and integration. Placement is where the proceeds of criminal activity enter the financial system; layering distances the money from its illegal source through layers of financial transactions; finally, integration involves the re-introduction of the illegal proceeds into legitimate commerce by providing an apparently genuine explanation for the funds.

3. Scope

This policy statement applies to all TMPG employees, contractor and to third parties, including academic partners, and governing bodies undertaking business in partnership with TMPG.

Money laundering is a criminal offence. In the UK, penalties include unlimited fines and/or terms of imprisonment ranging from two to 14 years. Offences include:

• Failing to report knowledge and or suspicion of money laundering
• Failing to have adequate procedures to guard against money laundering
• Knowingly assisting money launderers
• Tipping-off suspected money launderers
• Recklessly making a false or misleading statement in the context of money laundering. TMPG could also face a range of sanctions for non-compliance, imposed by HM Revenue and Customs (HMRC) and /or the Financial Conduct Authority (FCA).

Therefore, legal, or disciplinary action under TMPG’s procedures may be taken against members of staff who fail to comply with this policy.

4. Risk Assessment

MLR 2017 requires TMPG to undertake a risk assessment and assess its exposure to money laundering. There are 4 main areas that need to be considered to assess its overall risk.

Product / Service Risk – This is the risk associated with delivery of TMPG activity including regulatory inspection, teaching, research collaboration, enterprise, and conferencing activity.

Jurisdictional Risk – TMPG is a global company operating in multi-jurisdictional countries. This is a recognised risk associated with TMPG’s countries of operation, location of customers, suppliers and agents.

Customer/Third-Party Risk – This is the risk associated with the people and/or organisations that we undertake business with including customers/third-parties, beneficial owners, agents, contractors, vendors and suppliers. Politically Exposed Persons (PEP’s) and Sanctioned Parties are also considered within this risk.

Distribution Risks – This is the risk associated with how we undertake business, including direct and indirect relationships (e.g. via an agent or third-party), face-to-face, digital/online and telephonic.

Whilst much of the TMPG’s financial activity could be considered relatively low risk from the perspective of money laundering, all staff and contractors need to be vigilant against the financial crime and fraud risks that the TMPG faces day-to-day.

Possible signs of money laundering include:

• An individual or company makes a large, unexpected payment to TMPG but fails to provide evidence confirming their identity and reason for payment.
• An individual or company attempts to engage in “circular transactions” where a payment is made to TMPG followed by an attempt to obtain a refund. For example, a client pays a significant sum, then withdraws and seeks a refund.
• A person or company undertaking business with TMPG fails to provide proper paperwork (examples include charging VAT but failing to quote a VAT number or invoices purporting to come from a limited company, but lacking company registered office and number)
• A potential supplier submits a very low quotation or tender. In such cases, the business may be subsidised by the proceeds of crime with the aim of seeking payment from TMPG “clean money”.
• Involvement of an unconnected third party in a contractual relationship without any logical explanation.

This list is not exhaustive and money laundering can take many forms. If there are any concerns, then these should be raised with the Money laundering Reporting Officer who in this instance is Tony Moore, Senior Associate, TMPG.

5. Risk Mitigation

TMPG has several policies and procedures in place to minimise the risk of money laundering that are stored within a central digital repository. The Director and Senior Associate are both trained in AML with backgrounds in Law Enforcement and Government regulatory compliance

6. Unusual or Large payments

TMPG will investigate and establish what they are for. TMPG’s accountants (Baker Pringle ltd) also advise on high-risk countries where financial transactions are either prohibited or heavily restricted.

7. Cash Thresholds

MLR 2017 has reduced the limit for eligible cash transactions from €15,000 (£13,000) to €10,000 (£8,800) and is extended to receiving, as well as making, payments in cash. TMPG recognise that any amount of cash over €1,200 (£1,000) may be considered in scope if the circumstances warrant further investigation.

TMPG does not accept cash payments to settle invoices raised against clients.

8. Know Your Customer / Supplier

Anti-Money Laundering Regulations requires that TMPG must be reasonably satisfied as to the identity of the customer (and others) that they are engaging with in a contractual relationship. To discharge the “reasonably satisfied” TMPG must obtain a minimum level of personal information from a customer including date of birth and home address. For third parties’ letters or documents proving name, address and relationship should be obtained.

If an organisation is not known to TMPG then Letter Headed documents, website and credit checks may be undertaken as appropriate.

TMPG must be clear on the purpose and the intended nature of the business relationship i.e. knowing what you are doing with them, or supplying to them and why.

In most cases TMPG’s exposure to money laundering is likely to be low. Financial due diligence is already considered as part of the decision whether to supply or contract-in services, consultancy, and collaborative provision. However, in certain instances if TMPG is considering establishing a business relationship in a high-risk country or with a politically exposed person, then appropriate advice should be taken from the Money Laundering officer (MLRO) pre entering the arrangement.

9. Processing Refunds:

TMPG will undertake appropriate checks before processing any refunds and funds can only be refunded back to the original payer and cannot be refunded to a third party. Where the original payment has been received from abroad the refund will be to the foreign bank account and not to a UK bank account.

10. Financial Sanctions Targets

The UK government publishes frequently updated guidance on financial sanctions targets, which includes a list of all targets. This guidance can be found at: https://www.gov.uk/government/publications/the-uk-sanctions-list

If TMPG is planning to undertake any consultancy activities (either directly or via deployed contractors) with entities and/or individuals in any of the above countries, the MLRO will be consulted, and a full risk analysis conducted pre-deployment so that TMPG can review the register and ensure that the proposed activity is not with an embargoed individual or organisation.

11. Roles and Responsibilities

Tony Moore – Director of Valiance Global Ltd and Senior Associate to TMPG has responsibility for the Anti- Money Laundering Policy, which will be reviewed annually.

12. Money Laundering Reporting officer (MLRO)

The MLRO is the primary contact for any further information or to report any suspicious activity. The deputised MLRO is:

Tony Moore – Director
Senior Associate
Shepperton, Surrey
+44 (0)345 5480700

And the Controller is:

Tracy Moore – Director
TM Pharma Group Ltd
Shepperton, Surrey
+44 (0)345 5480700

The MLRO is responsible for:

• receiving reports of suspicious activity from any employee in the business.
• considering all reports and evaluating whether there is – or seems to be, any evidence of money laundering or terrorist financing.
• reporting any suspicious activity or transaction to the National Crime Agency by completing and submitting a Suspicious Activity Report (SAR).
• asking the NCA for consent to continue with any transactions that must be reported and making sure that no transactions are continued illegally.

13. All members of TMPG – Reporting Suspicious Activity

All employees, contractors & associates who need to report suspicious activity must complete the Suspicious Activity Report (SAR) which is detailed in Annex A. They should provide as much detail as possible and the report must be made in the strictest confidence, being careful to avoid “tipping off” those who may be involved.

Money laundering legislation applies to all members of TMPG and extends to contracted-in associates or other supplier of professional services. TMPG could be committing an offence if they suspect money laundering (or if they become involved in some way) and do nothing about it. Potential Red flags are highlighted in Section 3.

The MLRO will report any findings to the Director of TMPG who will then instruct Valiance Global, or another suitably qualified company to carry out any investigation or report the circumstances to a statutory body.

14. Training

TMPG will ensure that members of staff with financial responsibility receive appropriate money laundering training. Refresher training will take place at each revision of the policy.

15. Related Policies

The following related documents can be found at:

• Financial Regulations Counter Fraud Policy – TMPG digital repository
• Whistle Blowing Policy – TMPG digital repository
• GDPR Compliance policy – TMPG digital repository
• IT Security and acceptable use policy – TMPG digital repository

16. Review, Approval and Publication

The Anti-Money Laundering Policy is subject to review annually by the MLRO or following a change to relevant UK legislation.

Updates to the Anti- Money Laundering Policy will be reviewed by the MLRO and final approval will be given by the Director, TMPG.

Tony Moore

MLRO & Senior Associate to TMPG