Corporate Infrastructure, Scope of Operations & Philosophy: International Infrastructure Company, Ltd., is Isle of Man company (hereinafter “IIC”) which is wholly owned by Ein Sof an Isle of Man foundation commonly referred to as the Conservancy. The Conservancy sponsors and manages the application of technologies to real world requirements for: water, power, shelter, and food on a humanitarian basis. Toward this objective the Conservancy maintains intellectual property, finance, insurance, engineering and project management relationships in North America, Europe, the Middle East, and Asia. These relationships, informed by unrivaled infrastructure, capacity, and experience, allow the Conservancy to provide sovereign counterparties with practical goal-oriented solutions.

 

IIC, and its related entities, operate globally and take pride in our continent-spanning reputation for integrity and honesty. It is essential that IIC employees, counterparties and all those associated with IIC, protect that reputation. Money laundering, bribery and corruption are criminal offenses. In addition to the fines, penalties, and reputational harm that IIC may suffer, such activities can lead to untoward human rights abuses and conflict financing. Employees, counterparties, and all those associated with IIC involved in money laundering, bribery, and corruption will be terminated. Third parties doing business with IIC are expected to comply with all applicable laws and adhere to our policies and contract provisions relating to the prevention of money laundering, bribery, and corruption. As a prime actor in IP development and deployment, IIC recognizes it is uniquely positioned to detect and prevent commercial activities that contribute to illegal activities. IIC works with its employees and counterparties to ensure they are aware of our policies and procedures.

 

ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

 

Internal Controls, Procedures & Compliance Management: IIC’s integrated anti-money laundering (“AML”) and know your counterparty (“KYC”) policies, procedures, and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a periodic basis. IIC employs on boarding procedures to ensure its understanding of the nature, scope, motivation, and provenance of those with whom it engages. IIC’s Management periodically reviews IIC’s policies, procedures, and internal controls with professional international audit, taxation, and legal counsel to ensure their ongoing efficacy. Further, IIC submits to external periodic independent audit of its compliance regimen. IIC’s management is vested with responsibility for enforcement and, as such, possesses a working knowledge and familiarity with related statutory regimes including but not limited to: The foreign corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended. Accordingly, IIC complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if IIC uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: IIC monitors all transactions under its purview. IIC is committed to a zero-tolerance approach to money laundering, bribery, and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner; (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery, and corruption; (iii) implement and enforce effective systems to counter the risk of money laundering, bribery, and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing counterparty either refuses to provide the information requested, or appears to have intentionally provided misleading information, IIC will terminate engagement with that entity or individual. IIC maintains AML and KYC documentation regarding each counterparty and transaction. IIC maintains ongoing employee training under the leadership of a designated Compliance Officer. IIC’s training is based on its policies, procedures, and internal controls as well as applicable statues and regulations. IIC’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees' roles in compliance efforts; (iv) record retention; and (v) disciplinary consequences of non-compliance.

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