Active Wallet creates opportunities for the people and builds trust between them worldwide.
Active Wallet is committed to conducting business in accordance with the highest ethical and
professional standards. The public, Active Wallet’s partners and Users’ have the right to
expect that professional, competent and trustworthy people are employed by Active Wallet.
Active Wallet will provide adequate and appropriate resources to implement the Anti-Fraud Policy and will ensure it is communicated and understood.
The Anti-Fraud Policy has been drafted to comply with the current applicable local and international legislation, including, but not limited to applicable EU legislation. Adherence to the Anti-Fraud Policy Active Wallet will ensure compliance with all relevant legislation and internal policies.
In pursuance of the Anti-Fraud Policy, Prohibited Conduct includes fraud, corruption,
collusion, money laundering, financing of terrorism and other criminal conduct defined as
A. Fraud: any act or omission, including a misrepresentation that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
B. Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the action of another party.
C. Collusion: arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
D. Money laundering: (a) the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action; (b) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity; (c) the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity; (d) participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points
E. Criminal conduct: conduct, which constitutes an offence in any part of the world or would constitute an offence in any part of the world if it occurred there. Active Wallet will review the Anti-Fraud Policy to reflect new legal and regulatory developments and ensure good practice.