New Sparta Portfolio Management Limited

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How We Engage Our Clients and Improve
Our Client Experience

We have developed solid and everlasting relationships as part of our management plan. On all business transactions that occur with clients, partners, or acquisitions, we ensure an efficient communication and relationship. This statement is a core cultural belief and a fundamental element of the success of NewSparta Asset Management Limited. Members of our community tend to share core values that are highly compatible with those that are central to the business and established at the outset — expertise, integrity and discretion. We treat each other with mutual respect, openness and fairness and are driven by a desire to ‘do the right thing’ by all our stakeholders. This is our culture – it is central to our success. We are therefore proactive in building and reinforcing it.

Anti-Bribery And Corruption Framework

NewSparta Asset Management Limited operates within the commercial banking laws and protocols. We make sure all business transactions follow our Code of Conduct and values. As a company, we have enforced a robust framework to prevent all forms of bribery and corruption. Our Anti- Bribery and Corruption Policy forbids the actual or attempted use of any form of bribery or corruption, either directly or indirectly, on NewSparta Asset Management Limited behalf on any business-related activity.

Risk assessment

These include periodic risk assessments to identify and address bribery and corruption risk and controls tailored to manage the risks identified through this process.

Policies & Procedures

Bribery and corruption risks are addressed through a number of other NewSparta Asset Management Limited policies and procedures, including our Anti-Money Laundering and Counter-Terrorism Financing Policy, incorporating Client Identification. This document is a summary of NewSparta Asset Management Limited' Anti-Bribery and Corruption Policy and framework. It is not intended to create third party rights or duties or to form part of any contractual agreement between NewSparta Asset Management Limited and any other party.

Procedures

NewSparta Asset Management Limited staff must take reasonable steps to avoid, giving or accepting gifts and entertainment that are intended to, or may, improperly influence them or others. We also maintains a Whistle-blower Policy and framework which promotes the escalation and reporting of matters including bribery and corruption. Staff are encouraged to raise matters through line management or to compliance, and can also approach the Integrity Office or anonymously through an externally-hosted staff hotline.

Due Diligence

In dealing with third parties, the Policy requires sufficient due diligence to be undertaken to ensure that they are suitable to be associated with NewSparta Asset Management Limited, and that appropriate controls are implemented, designed to prevent and detect bribery and corruption. Third parties associated with NewSparta Asset Management Limited are in turn expected to have appropriate due diligence arrangements and controls in place in relation to the other parties they engage with, on behalf of NewSparta Asset Management Limited.

Monitoring & Review

NewSparta Asset Management Limited performs payment monitoring, including monitoring for bribery ‘red flags’ and NewSparta Asset Management Limited' independent compliance function conducts periodic risk-based monitoring of gifts and entertainment.

Training & Communication

NewSparta Asset Management Limited promotes staff awareness in compliance with the Anti-Bribery & Corruption framework through the appropriate dissemination of the Policy and procedures (including disciplinary procedures) and training on induction and periodically thereafter

Anti-Money Laundering & Counter-Terrorism Financing Policy

Policy Summary

NewSparta Asset Management Limited is committed to performing its business in agreement with industry laws and regulations, and in a way that maintains and enhances our unique reputation. This policy covers NewSparta Asset Management Limited ’s approach to the identification, mitigation, and management of all risks that the NewSparta Asset Management Limited brand in totality might become associated with, concerning money laundering and corruption.

Description of money laundering and terrorism financing

NewSparta Asset Management Limited defines money laundering (“ML”) as activity which is designed to conceal or disguise the true origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate sources. Terrorist Financing (“TF”) is considered to be the act of providing financial support to terrorism or terrorist organizations to enable them to carry out acts of terrorism.

Objectives of NewSparta Asset Management Limited’s AML/CTF policy

NewSparta Asset Management Limited has established an AML/CTF policy which sets the core principles for the management of ML/TF risk. The policy is global in nature and outlines group-wide standards to meet regulatory and ethical obligations in the economies in which NewSparta Asset Management Limited does business. This contributes to the stability, integrity and strength of the global financial system and protects us from reputational damage.

The core principles

NewSparta Asset Management Limited has adopted the following core principles:

NewSparta Asset Management Limited opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.
NewSparta Asset Management Limited reports any activity that it detects which is suspicious and may involve potential money laundering or terrorism financing to the applicable regulator.
NewSparta Asset Management Limited will comply with the AML/CTF laws, rules and regulations of the countries that relate to AML/CTF where NewSparta Asset Management Limited has permanent places of business through which NewSparta Asset Management Limited provides services.
NewSparta Asset Management Limited will endeavor to provide its products and services only for legitimate purposes to customers whose identities has been able to reasonably ascertain.
NewSparta Asset Management Limited will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by NewSparta Asset Management Limited’s AML/CTF Program.
NewSparta Asset Management Limited employees are required to attend AML/CTF training to understand their obligations under the relevant laws, rules and regulations.
NewSparta Asset Management Limited will monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent. NewSparta Asset Management Limited will manage new and revised changes to NewSparta Asset Management Limited’s products, business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.

NewSparta Asset Management Limited’s AML/CTF training program

NewSparta Asset Management Limited has a robust AML/CTF Training Program to educate employees in implementing and maintaining NewSparta Asset Management Limited’s AML/CTF Program. All employees undergo initial AML/CTF training when they join NewSparta Asset Management Limited. In addition, there are ongoing training requirements for all employees.

NewSparta Asset Management Limited’s record retention

NewSparta Asset Management Limited’s Record Management Policy requires retention of records for as long as required by applicable laws, rules and regulations.

Know your customer (“KYC”)

NewSparta Asset Management Limited endeavors to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity and bonafides of customers will also be complied with.

These will include customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk to NewSparta Asset Management Limited and require a higher level of due diligence;

Procedures to establish if customers are known or suspected money launderers, terrorists or otherwise engaged in criminal activity (e.g. reviewing customers against government/United Nations/regulators’ lists of proscribed persons)
Enhanced Due Diligence undertaken where a transaction or a counter party results in a heightened level of financial crime
A risk-based periodic review of existing customer records to maintain currency and completeness
Ongoing monitoring of transactions conducted by customers using a risk based approach
Procedures prohibiting accounts/relationships, including payment processing, with shell banks
A clear statement on what records must be kept on customer identification and individual transactions and their retention period; and
Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.

Suspicious activity

NewSparta Asset Management Limited staff are trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with customers and customer related information. NewSparta Asset Management Limited has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.

Independent review of the AML/CTF program

NewSparta Asset Management Limited’s AML/CTF Program is subject to independent review in accordance with the requirements of each local jurisdiction. The results of the review are presented to senior management for review and action. In addition, regular reporting is provided by Compliance to NewSparta Asset Management Limited’s Board

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