PAGB recognises that Endemic economic crime (particularly when associated with organised crime and terrorist financing) can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition.
PAGB is committed to conducting its global activities with integrity and respecting its regulatory, ethical and social responsibilities to:
- Protect investors, employers, employees and any others with whom PAGB interacts; and,
- Support governments, regulators, and law enforcement in wider economic crime prevention.
PAGB will not tolerate any deliberate breach of financial crime laws and regulations (e.g. bribery, corruption, and money laundering, sanctions, or tax evasion facilitation) that apply to the transactions we facilitate and undertake.
PAGB has a dedicated global Financial Crime function, which sits within Compliance under the control and oversight of the Chief Executive Officer.
The Financial Crime function facilitates risk-based, effective and efficient financial crime risk management by providing expert support and oversight to the PAGB and our legal entities around the world.
PAGB has adopted a holistic approach to Financial Crime and have one group-wide Financial Crime Policy that sets the minimum control requirements in four key risk areas: –
- anti-bribery & corruption (ABC)
- anti-money laundering & counter-terrorist financing (AML)
- anti-tax evasion facilitation (ATEF); and,
- sanctions.
This combined approach allows PAGB to effectively identify and efficiently manage the relevant inter-connectivity between the key risk areas.
- check all investor organisations against the relevant lists of “proscribed organisations”
- ensure that all country programmes undertake an annual risk assessment
- provide guidelines to staff on relevant Terrorism and Money Laundering regulations to reduce the risk of abuse
- establish internal reporting procedures on actual or suspected incidents involving “proscribed organisations”
- include a requirement in partner and affiliate agreements not to support “proscribed organisations”