Anti-Fraud and Financial Crime Policy

TD & Partners Global is committed to preventing fraud and financial crime in our operations. We act honestly, maintain robust controls, and respond firmly to any suspected fraud or financial crime.

This policy applies to everyone acting on our behalf. It covers fraud, theft, embezzlement, false accounting, money-laundering risk, sanctions exposure and other financial crime, across all our activities.

We maintain controls designed to prevent fraud and financial crime, including segregation of duties, approval thresholds, accurate record-keeping and oversight. We promote awareness so people recognise and can report concerns.

We monitor for indicators of fraud and financial crime through management review, reconciliation and other controls. We act on anomalies and investigate where appropriate.

We are alert to the risk that our services could be misused for money-laundering or sanctions-evasion purposes. Where relevant to an engagement, we conduct proportionate checks and seek appropriate advice. We comply with applicable financial-crime laws in our markets.

Where fraud or financial crime is suspected, we investigate promptly and confidentially, take steps to contain the issue and recover losses, and report to authorities where required. We do not tolerate retaliation against those who raise concerns in good faith.

Everyone is responsible for helping prevent fraud. Leaders ensure controls operate and that concerns are addressed. Concerns should be raised through our Speak Up and Whistleblowing Policy.

We review this policy and our controls regularly. The effective date and version are shown on the policy page.