CORPORATE OVERVIEW

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CORPORATE INFRASTRUCTURE, SCOPE OF OPERATIONS & PHILOSOPHY:

Port Shepherd Limited is an Isle of Man Company (hereinafter “PS” or the “Company”) with a United Kingdom subsidiary company, managed by qualified industry professionals that was incorporated to both to: (i) act as a corporate holding company for its United Kingdom (UK) subsidiary, and (ii) to conduct its corporate group’s business activities on the Isle of Man. PS does not undertake any regulated activity or services. The Company provides administrative services with the sole intention of achieving its associated members goals in strict compliance with all applicable legal, regulatory and industry regimes. PS to provide a limited number of decerning family offices with unconflicted practical goal-oriented solutions. PS conducts itself relative to each associated member in conformity with our mission statement

 

ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

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Internal Controls, Procedures & Compliance Management: Port Shepherd’s integrated anti-money laundering (“AML”) and know our customer (“KYC”) policies, procedures and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a regular basis. Port Shepherd employs on boarding procedures to ensure its understanding of the nature, scope, motivation and provenance of those with whom it engages. Port Shepherd’s Management regularly reviews Port Shepherd’s policies, procedures and internal controls with professional international audit, taxation and legal counsel to ensure their ongoing efficacy. Further, Port Shepherd submits to external periodic independent audit of its compliance regimen. Port Shepherd’s management is vested with responsibility for enforcement and as such a general familiarity with related statutory regimes including but not limited to: The foreign Corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended is required. In this regard, when questions arise Port Shepherd reverts to legal counsel to govern its response. As a result of such counsel, Port Shepherd complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if Port Shepherd uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: Port Shepherd monitors the provenance of all funds transfers encountered in its administrative capacity. Port Shepherd is committed to a zero-tolerance approach to money laundering, bribery and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner; (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery and corruption; (iii) implement and enforce effective systems to counter the risk of money laundering, bribery and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing Counterparty either refuses to provide the information requested, or appears to have intentionally provided misleading information, Port Shepherd will terminate engagement with that entity or individual. Port Shepherd maintains AML, and KYC documentation regarding each counterparty and relevant transaction. Port Shepherd outsources ongoing employee training under the leadership of a designated Compliance Officer. Port Shepherd’s training is based on its policies, procedures and internal controls as well as applicable statues and regulations. Port Shepherd’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees’ roles in compliance efforts; (iv) record retention; and (v) disciplinary consequences of noncompliance.

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