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
follows:
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.