b'Mobile phones To fail to disclose to the appropriate authorities, knowledge or suspicionIf you are provided with a mobile phone, we willof money laundering pay all running expenses on condition that you: To tip off a person known or suspectedTake good care of it and immediately reportof being involved in money laundering, any loss of it. A company mobile phone must(including tipping off a third party) where this not be left in an unattended carcould prejudice an investigation Criminal conduct is defined as conduct which Use the mobile only for business purposesconstitutes an offence in any part of the United in accordance with any applicable companyKingdom; or, in certain circumstances, where an policy in relation to the phoneact is committed abroad (from which proceeds Return the mobile immediately on requestare generated) which would also constitute an offence in any part of the United Kingdom.Any misuse of a company issued mobileThis not only includes serious criminal conduct, phone is a disciplinary offence and could but also any other offence which is committed lead to summary dismissaland where benefit is gained, of whatever size, for any person.It is important to understand there When leaving employment, the companyis no requirement for ECDC to have reasonable mobile phone must be returned to suspicion and that persons making reports in your manager good faith are protected under the UK AML rules.Criminal property is property which is, or represents, a persons benefit from criminal Money launderingconduct and includes all property of any kind (including but not limited to cash, banked funds, It is the policy of ECDC to comply with the UKreal property, any kind of asset).Anti-Money Laundering (AML) and SanctionsIt is also an offence for anyone in the regulated Framework, as these regulations may specificallysector (which can include property developers apply to various elements of the business. ECDCin certain circumstances) who fails to make a has designated the Chief Executive Officerdisclosure to authorities that they know or suspect or Senior Director as the Money Launderingor have reasonable grounds to suspect that Reporting Officer (MLRO) to overseeanother person is engaged in money laundering.compliance with the UK AML and Sanctions Framework in accordance with the proceduresEmployee Responsibilitiesin our policy (obtainable from the Directors Executive Assistant. All employees should readEmployees shall be alert at all times to possible and acknowledge the policy annually). involvement of criminal property or sanctioned It is a criminal offence to: persons in any business activity.To acquire, use, possess, conceal, disguise,If it appears that criminal property or any convert, transfer or remove criminal propertysanctioned person may be involved in the activity, from the United Kingdom, or to facilitate itsemployees shall immediately contact the Chief acquisition, retention, use or control Executive Officer or his designee for review ofby another person the activity and instructions on whether to proceed. 40'