Compliance and anti-corruption

This policy applies to DEV STUDIOS CANADA INC., its directors, employees, agents and representatives, wherever they work. We expect our partners, suppliers and intermediaries to meet equivalent standards.

We comply with the laws applicable in the countries where we operate, including:

• the Corruption of Foreign Public Officials Act (CFPOA) and the Criminal Code of Canada;
• the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA);
• Canadian economic sanctions laws (Special Economic Measures Act, United Nations Act);
• the rules applicable in our other countries of operation, including within WAEMU, and international standards (US FCPA, UK Bribery Act, French Sapin II law) where they apply.

• Offering, promising, giving, soliciting or accepting, directly or through an intermediary, an undue advantage to influence a decision.
• Facilitation payments, whatever their amount.
• Gifts and hospitality that are disproportionate, repeated or offered at a sensitive time (tender, inspection, negotiation).
• Any transaction intended to conceal the origin of funds or circumvent our controls.

• Due diligence on our clients, partners and intermediaries (KYC/KYB, beneficial owners, sanctions screening).
• Transaction monitoring and reporting of suspicious transactions to the competent authorities, including FINTRAC.
• A designated compliance officer, written policies, risk assessment and staff training.
• Accurate record keeping and document retention as required by law.

Anyone — employee, director, contractor, partner, client or third party — may report in good faith any instance of corruption, money laundering, terrorist financing, fraud, conflict of interest or any breach of the law or our policies.

Reports go to compliance@sendchap.com. They may be anonymous. They are handled confidentially and the reporter’s identity is protected as far as the law allows. No retaliation is tolerated against anyone who reports in good faith.

Any breach of this policy may lead to disciplinary measures, termination of the business relationship and, where appropriate, reporting to the competent authorities.

This policy is reviewed at least once a year and whenever our business or the regulation changes significantly.