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A compilation of articles, highlighting the depth and complexity of this world wide problem. 

A compilation of articles, highlighting the depth and complexity of this world wide problem. 

company

A compilation of articles, highlighting the depth and complexity of this world wide problem. 

Our Governance

Our Governance We view good governance as essential to creating and preserving value for our shareholders and other stakeholders. This includes a sound approach to corporate governance that complies with all applicable laws, rules, regulations and policies, as well as unwavering adherence to our values. Our directors and all employees, including senior management, conduct themselves in accordance with the highest moral and ethical standards.

Ethixbase 360 Managed Services Schedule - Remediation

The provision of Managed Services by Ethixbase360 is subject to the terms of the:

  1. Ethixbase360 terms and conditions for the provision of Services (Terms). Words and expressions defined in the Terms have the same meanings in this Schedule;
  2. Order (as defined in the Terms) for Managed Services;
  3. additional terms and conditions set out in this Managed Services Schedule (together Managed Services Agreement) In the event of any conflict, the following order of precedence will apply: this Managed Services Schedule, the Terms and the Order. However the Order will prevail if it refers to a specific provision of this Managed Services Schedule or the Terms and an intention to vary it. 

This Managed Service Schedule contains:

  • Schedule 1: Additional Definitions
  • Schedule 2: Managed Services Description
  • Schedule 3: Support
  • Schedule 4: Dependencies

Schedule 1: Additional Definitions

Additional Definitions

In addition to the definitions set out in the Terms, the following words shall have the meaning set out below:

 1.1 Alert: a possible Match generated when a search against the name of a Report Subject or any Associate is made through the Ethixbase360 Platform.

1.2 Alerted Entity: an entity or person whose name appears in Ethixbase360 Data.

1.3 Associate: a maximum of two entities or individuals associated with Report Subject that Customer has requested to be included in a Report via the Ethixbase360 Platform.

1.4 Managed Services: the services described in Schedule 2.

1.5 Managed Services Team: Ethixbase360 personnel engaged in performing the Managed Services.

1.6 Match: a Report Subject or Associate that is flagged as a possible Alerted Entity through the Ethixbase360 Platform as a result of the Managed Services.

1.7 Report: an Instant Due Diligence, Instant Due Diligence Plus or ESG Explore report provided to Customer through the Ethixbase360 Platform.

1.8 Report Subject: the legal entity or individual that is the primary subject of a Report.

1.9 Secondary Identifiers: a means of identifying a Report Subject, an Associate or Alerted Entity which in the reasonable opinion of the Managed Services Team can be used to dismiss an Alert with a high level of confidence (a) provided by Customer via the Ethixbase360 Platform; or (b) obtained by the Managed Services Team as part of the Managed Services.

1.10 Service Hours: the hours during which the Managed Services will be provided being 09.00 to 17.30 in Singapore Monday to Friday other than public holidays.

1.11 Service Report: a report issued by Ethixbase360 in accordance with Schedule 2 .

 

Schedule 2: Managed Services

Section A – Description

Managed Services

1.1 The Managed Services shall be provided:

1.1.1. during Service Hours;

1.1.2  subject to the Service Exclusions in Part B and the Performance Factors in Part C of this Schedule;

1.1.3  subject to satisfaction by Customer of the Dependencies.

Remediation Managed Service

Background

The Remediation Managed Service is the process of mitigating the number of false positive Matches and flagging possible risks for each Report Subject and any Associates within the Ethixbase360 Platform.

The Remediation Managed Service will occur at two stages:

1.1 Initial Remediation (single search or bulk upload)

An initial remediation is triggered when a Report Subject and/or any Associate is  first screened through the Ethixbase360 platform resulting in  an Alert flagged against it. Any Alert will indicate on the Ethixbase360 Platform and the Managed Services Team will undertake a remediation review of any Alerts using the remediation methodology set out below.

1.2 Ongoing Monitoring (OGM)

OGM captures Alerts by continuously checking the Report Subject and/or any Associates against Ethixbase360 Data. The Managed Services Team will be automatically notified by the Ethixbase360 Platform and will review any Alerts and remediate them based on the remediation methodology set out below.

The Price for Managed Services is based on one Report Subject and a maximum of two Associates.  Managed Services will not be provided for any excess number of Associates without payment of additional charges.

Ethixbase360 Remediation Methodology

1.1 The remediation process necessarily requires the exercise of discretion on behalf of Customer by the Managed Services Team. Ethixbase360 takes a conversative approach to the remediation process. If Ethixbase360 cannot dismiss an Alert with a high degree of confidence, it will remain a possible Match and Customer will need to review and decide on next steps (e.g. EDD).  

1.2 Four main indicators will be used to determine whether an Alert is valid:

Name Match:  a Match occurs based on Exact Name, Same Name, Partial Name, Phonetic and Possible Alias of Report Subject or Associate.

Affiliation Match: a Match occurs if a Report Subject or Associate is:

(a) a legal entity, and is found to be associated to the same group of companies as an Alerted Entity; or

(b) an individual, and is found to be associated with an Alerted Entity.  

Location Match: (individuals only) a Match occurs based on Country location of Report Subject or any Associate.

Secondary Identifiers: a Match based on Secondary Identifiers.

Remediation Methodology Process Flow – Legal Entity (Report Subject or Associate)

Step Description
1
The Managed Services Team will review the name of the Legal Entity and determine whether in their opinion there is a Name Match. If in their opinion there is no Name Match, the Managed Services Team will mark this as a false positive in the Ethixbase360 Platform.
2
If there is a Name Match, the Managed Services Team will check if the Location of the Legal Entity appears to be the same as the Alerted Entity. If in the opinion of the Managed Services Team, there is a Location Match, the Alert will remain flagged as a Match in the Ethixbase360 Platform.
3
If there is no Location Match, the Managed Services Team will undertake internet research to find Secondary Identifiers. The research will compromise a review of the first 10 hits discovered after a search against the Legal Entity name using a search engine.
4
If the Managed Services Team find Secondary Identifiers that in their opinion can be used to dismiss the Alert with a high level of confidence, the Match will be marked as a false positive in the Ethixbase360 Platform.
5
If the Managed Services Team cannot find Secondary Identifiers to remove the Match with a high level of confidence, the Alert will remain flagged as a Match on the Ethixbase360 Platform.
6
If the Managed Services Team find any Affiliation Match between the Legal Entity and the Alerted Entity, the Alert will remain flagged as a Match even if there is no Location Match.
7
The Managed Services Team will take into consideration any Secondary Identifiers of Report Subject or Associates provided by the Customer including reviewing Secondary Identifier documents uploaded and Due Diligence Questionnaires (DDQ) responses generated through the Ethixbase360 Platform. If the Managed Services Team finds any match between the Secondary Identifiers and the Alerted Entity, the Alert will remain flagged as a Match.
8
If public domain information cannot be obtained on the Alerted Entity to compare to any Secondary Identifier provided by Customer, the Alert will remain flagged as a Match.

Remediation Methodology Process Flow – Individual (Report Subject or Associate)

Step Description
1
The Managed Services Team will review the name of the Individual and determine whether in their opinion there is a Name Match. If in their opinion there is no Name Match, the Managed Services Team will mark this as a false positive in the Ethixbase360 Platform.
2
If there is a Name Match, the Managed Services Team will check if the Location of the Individual (which will be assumed to be the Location of the Report Subject) appears to be the same as the Alerted Entity. If in the opinion of the Managed Services Team, there is a Location Match, the Alert will remain flagged as a Match in the Ethixbase360 Platform.
3
If there is no Location Match, the Managed Services Team will undertake internet research to find Secondary Identifiers. The research will compromise a review of the first 10 hits discovered after a search against the Individual name using a search engine.
4
If the Managed Services Team find Secondary Identifiers that in their opinion can be used to dismiss the Alert with a high level of confidence, the Match will be marked as a false positive in the Ethixbase360 Platform.
5
If the Managed Services Team cannot find Secondary Identifiers to remove the Match with a high level of confidence, the Alert will remain flagged as a Match on the Ethixbase360 Platform.
6
If the Managed Services Team find any Affiliation Match between the Individual and the Alerted Entity, the Alert will remain flagged as a Match.
7
The Managed Services Team will take into consideration any Secondary Identifiers of Report Subject or Associates provided by the Customer including reviewing Secondary Identifier documents uploaded and the Due Diligence Questionnaires (DDQ) responses. If the Managed Services Team finds any match between the Secondary Identifiers and the Alerted Entity, the Alert will remain flagged as a Match.
8
If public domain information cannot be obtained on the Alerted Entity to compare to any Secondary Identifier provided by Customer, the Alert will remain flagged as a Match.
9
If reports of non-business related criminality are discovered in connection with an Individual, the Managed Services Team will exercise discretion to determine whether, in their opinion, the criminality is likely to be relevant. For example, if a search against the name of the CEO of a Fortune 500 company reveals information about non-business related crime undertaken by a person of the same name, the Managed Services Team has the discretion to decide that in their opinion this is unlikely to be a Match.

 Expedited Requests

The Managed Services Team will process all remediation requests based on a First-In-First-Out basis. However, Ethixbase360 recognises that from time to time, a Report Subject may need to be processed urgently. In these cases, Customer may contact the Managed Services Team at [email protected] for expedition requests. These are accepted in the discretion of Ethixbase360.  Customer recognises that this occasional flexibility should be limited to genuine urgent or critical business issues and is subject to fair usage. If Ethixbase360, in its sole discretion, believes that this flexibility is not used either reasonably or in a bona fide fashion, Ethixbase360 will no longer accept such requests from Customer.  

Reporting

Managed Service activity will be reported by Ethixbase360 using reporting functionality in the Ethixbasse360 Platform (Service Report). 

Service Reports will be discussed at Quarterly Business Reviews (QBR) between Customer and Ethixbase360.

 

Part B – Managed Service Exclusions

The Managed Services do not include:

  • technical queries in relation to the operation of Ethixbase360 Platform
  • research other than in the English language
  • verification of the accuracy of any machine translation

Part C – Factors Affecting Managed Services

The following can affected the success of the Managed Services:

  • Report Subjects/Associates (a) with high profile or common names or (b) in certain regions/countries with large populations, will generate a high volume of Alerts that may be difficult to remediate
  • lack of or inaccurate information available within the Ethixbase360 Data
  • failure by Customer to fulfil a Dependency
  • breach by Customer of the Managed Services Agreement including the Fair Use Policy.

Schedule 3: Support

Support Requests

1.1. Support requests may be submitted by Customer by the following methods:

In relation to technical issues with the Ethixbase360 Platform:

In relation to the Managed Services:

Support requests made by other means (such as by emailing or calling an Account Manager or any other individual at Ethixbase360) will be responded to once our Support Team becomes aware of them but will not be covered by this Schedule.

Schedule 3 – Dependencies

Customer is responsible for the following (Dependences):

Specific Dependencies

 1.1 The Customer shall:

1.1.1. provide accurate information about Reports Subjects and Associates via the Ethixbase360 Platform

1.1.2. provide the full legal name of a Report Subject and any Associates and each name should have two parts. Names like SMART, EXPRESS, Globe, Ahmed, John etc will generate a high volume of Alerts and are unlikely to be remediated due to lack of information.

1.1.3. provide Secondary Identifiers by uploading to the “Manage Documents” section or by adding Customer Attributes in the Ethixbase360 Platform. Screening individual names with no country location or other Secondary Identifiers make remediation more difficult

1.1..4 request further remediation by email to [email protected] stating platform name and Report Subject/Associate name if Secondary Identifiers are added to the Ethixbase360 Platform once initial remediation has been undertaken.

Fulfilment of the Dependencies identified at paragraph 1.1.1 are important to ensure both an optimal Customer experience and that the Price for Managed Services remain commercially viable.  If Customer consistently fails to fulfil any of those Dependencies, Ethixbase360 reserves the right to increase the Price for Managed Services on Service of not less than 30 days written notice on Customer (Price Increase Period).  

Customer may terminate the Managed Services Agreement by service of written notice on Ethixbase360 at any time within the Price Increase Period. If Customer does not terminate the Managed Services Agreement in this way, the increased prices will be effective from the end of the Price Increase Period.

 

General Dependencies

 1.2 The Customer shall:

1.2.1. review, confirm and decide next steps in relation to all output of the Managed Services flagged in the Ethixbase360 platform;

1.2.2. satisfy itself that the Ethixbase360 remediation methodology described above is sufficient to satisfy Customer’s risk appetite. The remediation methodology requires the exercise of discretion by the Managed Services Team on behalf of Customer which is a matter of informed opinion alone;

1.2.3. ensure that Managed Services are sufficient to enable it to comply with its legal or regulatory obligations. Ethixbase360 does not provide legal advice and the provision of Managed Services does not constitute the provision of legal advice;

1.2.4. make all decisions in relation to the conclusion, termination or alteration of the terms of any commercial relationship or discussions with any third parties based on the output of the Managed Service.

1.2.5. co-operate with Ethixbase360 in the delivery of the Managed Services;

1.2.6. provide all information reasonably required for Ethixbase360 to provide the Managed Services.

Our Environmental Impact

Promote responsibility for the environment within the organisation and communicate and implement this policy at all levels.
Reduce the use of energy, water and other resources to reduce operating costs.
Minimise waste by reduction, re-use and recycling methods.
We actively encourage compliance with all relevant environmental legislation and regulation on a global scale.
Identify and provide appropriate training, advice and information for staff and encourage them to develop new ideas and initiatives.
Promote and encourage involvement in local environmental initiatives and schemes.

Ready to learn more?

Read the latest Ethixbase360 eBook 

Modern Slavery & Forced Labor: A Global Perspective’