ALF has a strict anti-bribery and corruption policy that applies to all our people. We will not directly or indirectly engage in bribery or corruption whether it involves private individuals or public officials.

We will never accept, solicit, agree to receive, promise, offer or give a bribe, facilitation payment, kickback, or other improper payment.

For this purpose, “bribe” means a financial or other advantages, intended to induce a person to give improper assistance in breach of their duty, or to otherwise improperly influence someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business, and “facilitation payments” are small bribes made to government or public officials to speed up routine administrative processes or other actions.

Furthermore, ALF has a legal obligation to comply with anti-money laundering laws and regulations. Broadly, money laundering can arise if a person acquires, retains, transfers uses, or controls the proceeds of a crime for the benefit of criminal activity. In this section, references to money laundering include references to similar financial offenses committing in relation to terrorism.

In order to fulfill our legal obligations, we must verify the identity of new clients, and in certain circumstances existing clients.

Additionally, from time to time our internal procedures may also require us to conduct background checks on new and existing clients.

procedures have been completed. In other circumstances, we may agree to commence acting whilst these procedures are carried out. We reserve the right to decline to act or, if appropriate, cease to act should these procedures not be completed to our satisfaction.

We may also be required to make detailed inquiries of any unusual transactions such as the transfer of large amounts of cash and such inquiries may result in us processing additional personal information.

Grounds for processing your data for anti-money laundering purposes. We process your information in accordance with Law No 2 for 2005 concerning Anti-Money Laundering.

All of our activities are managed in full compliance with this policy and with all applicable legal and regulatory anti-bribery and corruption Libyan obligations. We expect our business partners to have similar policies that apply to all dealings with, on behalf of, or involving ALF.