Our robust Compliance framework

Overview

In the cross-jurisdictional environment that we operate in, successful business development and delivery is not possible without compliance with the laws and regulations applicable in relevant countries.

At Ashon we strive to maintain a robust Compliance framework to protect us and our counterparts from related risks. For this purpose, our Compliance strategy sets a strong methodological base, implements adequate controls, develops its areas of growth, and properly supports our business activities.

Compliance strategy

Our Compliance strategy aims to create a sustainable value culture, in which reliability, honesty, credibility, and integrity are the cornerstones of our actions. For our team compliance is more than just following laws and regulations; compliance is a mindset. This includes our firm commitment that our company stands for fair and transparent business.

Compliance

Key pillars

We continually review our internal policies and procedures, implement training programs, promote the deeper integration of compliance into our business processes, and expand our targeted communications.

Methodology development

Creating and keeping a set of documents – policies and procedures – up-to-date to reflect all applicable requirements, roles and responsibilities, tasks, controls, escalation path and governance framework.

Automated and manual controls

Automated and manual compliance controls are introduced at various stages of business activity to ensure ongoing risk assessment and mitigation.

Top Management reporting

Accurate and timely reporting of detected breaches and issues, as well as changes to the Company’s compliance risk exposure.

Compliance testing and audits

Internal and external checks may be arranged to assure quality level of compliance controls.

Staff awareness

Regular training, notifications on applicable laws and regulations are provided to staff to keep everyone updated.

Compliance hotline

Any concerns or breaches should be escalated to our Compliance team for further investigation and remediation via our Whistleblowing channel.

General

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Registration information

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Address and contact details

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information on business activity

The Date of latest revision of the company Articles of Association (or an equivalent document)

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key executive and non-executive managers

Register and paid share capital

bank details

Shareholders and beneficiary owners

Individuals

Legal entities (including governmental and state structures)

Please: provide in addition a copy of up-to-date shareholding structure (graphic chart) duly signed by an authorized person, in case more than 2 (two) shareholders/beneficiary owners are in the shareholding structure

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information on audit

Auditor's report modified

Business purpose of relations *

Please: enclose to this questionnaire copies of the following documents. All documents shall be provided with English translation in case they are issued in other language.

for legal entities

a copy of articles of association or similar document;
certificate of incorporation (or similar document)
extract from commercial registry (or similar document confirming active legal status, signatories and address of the entity) not older than 6 months from date of issuance
a document confirming the Counterparty’s domicile (in case legal address is not indicated in the extract from commercial registry or similar document) not older than 6 months from date of issuance;
o copy of tax certificate (in case tax ID number is not indicated in the extract from commercial registry or similar document) issued by relevant authority not older than 6 months from date of issuance);
up-to-date counterparty’s shareholding structure (graphic chart), including names of all legal entities (including state and governmental structures) and natural persons (ultimate beneficiaries) holding 10% and more of shares/proprietary rights of the Company (directly or indirectly), duly dated and signed by an authorized person, not older than 6 months from date of issuance (in case more than 2 (two) shareholders/beneficiary owners are in the shareholding structure)
a copy of certificate of conformity/license for a particular type of the Counterparty’s activities (with respect to counterparties carrying out licensed activities);
a copy of a Power of Attorney for signatories (in case signatories are not indicated in other documents as per list above)
a copy of the latest audited financial statements together with report of the professional auditor (certified by the service provider (contractor) own senior team).
bank account details or letter from the bank regarding bank account of the service provider (contractor).

for unincorporated (individual) entrepreneurs

a copy of certificate of registration as an individual entrepreneur;
a copy of tax certificate issued by relevant authority not older than 3 (three) months from date of issuance);
proof of registered address of the individual (utility bills, etc. not older than 3 (three) months from date of issuance)
a copy certificate of conformity/license for a particular type of activities;
a copy of the ID/passport

for individual shareholders or beneficiary owners

a copy of the ID/ passport or full name, date of birth, residency / citizenship, document ID number, date of the ID document issue
proof of address registered address of the individual (utility bills, etc.)

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Declaration

I hereby declare that the information in and accompanying this questionnaire is true and complete to the best of my knowledge and belief. I undertake to promptly notify of any changes therein.

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