COMPLIANCE

SPARFELL Compliance and Ethics Programme provides a framework for effective compliance within the company, serving as a guideline to the high standards to be upheld and observed by all employees and business partners throughout the duration of their duties.

Written compliance and ethics-related policies, codes and procedures have been developed by SPARFELL, designed to establish clear guidelines for its employees and business partners to carry out their functions in compliance with applicable laws and regulations whilst furthering the mission and objectives of the company.

The following points are comprised of codes, policies and procedures that are applicable to SPARFELL business partners,  all employees, officers, directors and contracted personnel, and to such other persons as designated by SPARFELL during a given time period, as well as all natural and legal persons (and respective employees, officers and directors) who perform services for on on behalf of SPARFELL, including, without limitation, supply-chain partners, suppliers, consultants, contractors, distributors and agents (including, without limitation, sales agents/representatives).

SPARFELL has zero tolerance for money laundering and funding of terrorism, and is committed to the highest level of transparency, integrity and accountability. SPARFELL will conduct business only with reputable Customers and Associated Persons with funds derived from legitimate sources.

SPARFELL is also committed to compliance with relevant economic and trade sanctions laws in all jurisdictions in which it operates, applying to its operations through identifying, mitigating and managing the risks of both primary and secondary sanction violations.

SPARFELL has zero tolerance for bribery and corruption and is committed to acting with integrity and professionalism in all of its business dealings and relationships. Furthermore, the company is also committed to assist in the implementation and enforcement of effective systems to counter bribery and corruption. The integrity of the company’s employees and associated persons is critical to the group's success.