Corporate
The standards to which every ALNJH Group transaction is built, and against which a correspondent bank, insurer or customs authority may test it.
01. Compliance Position
ALNJH Group treats compliance as a condition of doing business rather than an administrative step to be completed once terms are agreed. Counterparty verification, sanctions screening and end-use review are conducted before commercial terms are issued, not after a contract is signed and a cargo is committed.
This ordering is deliberate. It costs the Group business, and it is the reason the Group's document sets are accepted by compliance departments that routinely reject those of larger intermediaries.
Where the Group cannot establish the identity of a counterparty, the beneficial ownership behind it, the origin of the goods or the intended end-use, the enquiry is closed. That decision is not subject to commercial appeal.
02. Know Your Customer & Anti-Money Laundering
03. International Trade Regulation
| Area | Group Undertaking |
|---|---|
| Sanctions Law | The Group observes the sanctions and restrictive measures applicable in every jurisdiction connected to a transaction, including those of the country of origin, transit, destination and of the currency of settlement. |
| Export Control | Controlled and dual-use items are supplied only against a valid licence issued by the competent authority, with classification established before commitment. |
| End-Use Verification | End-user and end-use are established in writing and independently corroborated. End-User Certification is mandatory in the Specialized & Tactical Procurement division. |
| Customs & Origin | Accurate tariff classification, declared valuation and certification of origin. The Group does not participate in mis-declaration, undervaluation or transhipment intended to obscure origin. |
| Anti-Bribery | No facilitation payment, commission or benefit is offered or accepted to secure a contract, permit or clearance. Agents are contractually bound to the same standard. |
| Data Protection | Counterparty information is held only for the purpose and period necessary for verification, contracting and statutory record retention. |
04. Ethical Sourcing Policy
Material must be traceable to a named producer, mine, mill or licensed exporter. The Group does not deal in material of undocumented origin, and does not knowingly handle goods originating from conflict-affected extraction.
Suppliers are required to confirm the absence of forced and child labour in their operations, and to permit verification where the Group considers the risk material to the supply line.
Suppliers must hold the environmental permits required in their jurisdiction. Waste, residue and hazardous material movements are conducted under the applicable international convention.
05. Raising a Compliance Concern
Counterparties, suppliers, agents and employees may raise a compliance concern directly with the Group. Correspondence marked for the attention of the Compliance Officer is routed to that function without commercial review, and may be submitted through the inquiry portal by selecting Corporate Governance & Compliance as the sector of interest.
Concerns raised in good faith are treated confidentially and no counterparty relationship will be prejudiced by having raised one.
