Policy Statements

Anti-Bribery and Corruption Policy Statement

 

Pursuant to the relevant law, regulations, codes of practice and/or regulatory guidance regarding anti-bribery and anti-corruption applicable in each of Estera’s jurisdictions, Estera has in place an anti-bribery and anti-corruption policy (the Policy) supported, where relevant, by appropriate procedures.  The Policy prohibits (inter alia) the making, offering or promising to make, requesting, accepting or receiving a payment (including any service, gift or entertainment) for any improper purpose or business advantage.  The Policy applies to all employees of Estera and its group companies and all business undertaken and structures administered by those entities.

Estera is committed to achieving the highest standards of ethical conduct and to ensuring that its employees and external parties who may provide services on its behalf, act in compliance with applicable legislation. This includes compliance with all laws, domestic and foreign, prohibiting improper payments or inducements to any person, including Public Officials (as defined under applicable law).

Before any transactions occur or services are provided, Estera will require confirmation of awareness of the applicable law from all clients (by means of an Engagement Letter (or equivalent)) and relevant third parties, such as consultants, those holding power of attorneys and those to whom Estera has outsourced or delegated a function (by means of an appropriate declaration), together with confirmation that, where relevant, they have in place appropriate anti-bribery and anti-corruption policies and procedures of their own; or otherwise conduct themselves in such a manner as to adhere to the applicable law and this policy statement.  Where deemed appropriate, Estera will also carry out additional due diligence.  All payments must be made on clear payment terms (including clarity in relation to what is being paid for).

Estera has procedures in place requiring the reporting of any knowledge or suspicion that any client, relevant third party or employee is involved in any way in bribery or corruption.

 

Sanctions and Embargoes Policy Statement

 

Pursuant to the relevant law, regulations, codes of practice and/or regulatory guidance pertaining to sanctions and embargoes applicable in each of Estera’s jurisdictions, Estera has in place a sanctions and embargoes policy (the Policy) supported, where relevant, by appropriate procedures.  The Policy prohibits (inter alia) the conduct of any business that would breach any part of a sanction or embargo.  The Policy applies to all employees of Estera and its group companies and all business undertaken and structures administered by those entities.

Estera is committed to achieving the highest standards of ethical conduct and to ensuring that its business is conducted in a manner which adheres to and upholds both the spirit and the letter of applicable sanctions and embargoes. This includes continually monitoring and ensuring compliance with local and international sanctions and embargoes, including those issued by the Office of Foreign Assets Control, the United Nations, the European Union and relevant individual government bodies.

Before any transactions occur or services are provided, Estera will determine whether an applicant for business or client, an owner or controller of that applicant or client, or a third party on whose behalf the applicant or client acts, is itself or is involved or does business with a sanctioned or embargoed person, regime or jurisdiction.  [The Policy does not prohibit Estera from dealing with persons connected with sanctioned regimes or jurisdictions, provided that the sanctions or embargoes are not relevant to that person, or an asset or activity of that person.]

As part of Estera’s new business take on policy, Estera will require confirmation of awareness of the applicable law from all clients and their agreement not to undertake any activities, business or transactions which may contravene relevant sanctions and embargoes, applicable law or this policy statement. 

Estera has procedures in place requiring:

  1. on-going monitoring to regularly screen client structures, their owners and all connected entities against sanctions and embargoes lists; and
  2. the reporting of any knowledge or suspicion of a breach of sanctions and embargoes.

 

Criminal Finance Act 2017 Policy Statement

 

As a firm, we value our reputation for ethical behaviour and for financial probity and reliability. We do not tolerate tax evasion, or the facilitation thereof in any circumstances, where committed by or facilitated by a client, personnel or associated persons/companies.

We are committed to fighting tax evasion and have rigorous policies and procedures in place to detect and prevent the facilitation of tax evasion offences.

We provide regular training on the requirements of the Criminal Finances Act 2017 to all personnel.

We require all personnel to demonstrate the highest standards of honesty at all times and appropriate disciplinary action will be taken wherever tax evasion or the facilitation thereof by any personnel has been proven.

We undertake due diligence on all associated persons/companies to mitigate the risk of the facilitation of tax evasion offences.

 

 

 

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