Compliance Statement

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​3.OBJECTIVES

ERSG operates in a highly regulated environment therefore we are obliged to comply with applicable laws and regulations. The following objectives are sought:

1. Monitoring efficiency and compliance,

2. Sharing of knowledge of compliance procedures within ERSG.

3. Encouraging a preventive culture based on the principle of “zero tolerance” for the commission of unlawful acts and fraud;

4. Application of the principles of ethics and responsible behaviour of all ERSG professionals, regardless of their hierarchical level.

5. Reviewing internal procedures to verify their validity and effectiveness, as well as the improvement of planned controls for preventing inappropriate behaviour in those procedures.

6. Encouraging the preparation and implementation of employee training programs relevant to their role, regarding applicable legislation and this policy, with sufficient frequency.

7. Establishing the tools needed to record the actions that make up ERSG’s compliance systems.

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4.GENERAL PRINCIPLES

ERSG is committed to carrying out all its activities in line with strict rules of ethical behaviour and compliance with current legislation.

As a recruitment company , ERSG operate in the UK under rigorous oversight of regulatory bodies such as the Employment Agencies Standards Inspectorate, the Information Commissioners Office, HMRC, and the Maritime and Coastguard Agency.

Persons performing the competencies of the compliance function of the business (Legal and Compliance Department) have unrestricted access to any information that is relevant to carrying out the tasks they are responsible for.

Regular communication and training programs are also conducted to make employees aware of the risks they face.

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5. POLICY CONTENT

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5.1. Compliance culture and structure

The Legal and Compliance Director advises the Board on compliance with the laws, regulations and administrative provisions that affect the company and on compliance with internal regulations. The Legal and Compliance Director also performs an assessment of the impact of any changes in the legal environment affecting the operations of the company or the Group and determines and assesses non-compliance risk.

The following matters are included within the competence of the Legal and Compliance department: insurance management and supervision, distribution of insurance policies, prevention of corruption and money laundering, , treating customers fairly, personal data protection and confidentiality, accreditation and registration requirements.

A strong compliance culture means all employees and contractors acting for or on behalf of ERSG understand compliance risks relevant for their respective roles and are empowered to take active steps to ensure the ERSG remains compliant with applicable laws, rules and regulations. ERSG’S compliance culture is defined by a framework of governing documents, , implementing appropriate governance, including monitoring and reporting mechanisms, relevant policies, instructions and systems, ongoing training and awareness.

Strong leadership from the board of directors and leadership teams is fundamental in promoting awareness and equipping employees to do their job properly in alignment with sound risk management principles and practices.

5.2. Regulatory compliance, financial crime and conduct risks

ERSG seeks to limit the potential for exposure to financial crime through having robust systems, processes and controls including but not limited to risk-based customer due diligence and transaction monitoring.

ERSG is committed to conducting permissible cross-border activity.

ERSG must take action to quickly and decisively mitigate any negative client, regulatory or reputation impacts, if this occurs.

5.3. Delegation

The Legal and Compliance Director retains the right to delegate specific elements of the mandate for the role to enable compliance to function efficiently and effectively in providing oversight of ERSG’s compliance activities.

Delegation can only be provided to a qualified person with sufficient competence and experience to undertake the responsibility. For this purpose, appropriate procedures for supervision and control are established (i.e., follow-up, review and reporting processes) to demonstrate that delegated responsibilities are being exercised properly.

5.4. Decisions and changes

Compliance must be considered when ERSG seeks to undertake significant decisions, strategic initiatives and major transactions. The Legal and Compliance department may escalate risks of non-compliance to the Legal and Compliance Director, as appropriate.

The Legal and Compliance Director may refer any major decisions to the board of directors for consideration where there is an actual or potential material risk of non-compliance, or the decision is inconsistent with the risk tolerance for regulatory compliance, financial crime and conduct risks.

5.5. Data Privacy

Data privacy compliance is administered by the Data Privacy Officer, via a system in place in which breaches can be logged and reported to ICO where necessary.

5.6. Independent reporting

The Legal and Compliance director is responsible for providing compliance reports to the board of directors to provide a clear picture of ERSG’s compliance risks and measures required to mitigate these risks. Areas of coverage for reporting include but they are not limited to key changes and developments in the law, a summary of compliance resources, a summary of complaints, resolutions and key trends, a summary of material findings of the Legal and Compliance department, including any compliance breaches and deficiencies in the compliance process.

The Contracts and Compliance Manager provides weekly reports that provide a comprehensive overview of activities, tracking requested compliance documents from contractors and prompting reminders for pending submissions.

Legislative changes prompt internal compliance audits within ERSG.

5.7. Investigations of breaches of this policy

Where a breach of this policy has been identified, an employee should notify their immediate manager. The Legal and Compliance department retains the right to undertake an investigation into the causes and make recommendations to address deficiencies in ineffective risk management where identified.

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6. VALIDITY AND UPDATING

This policy is reviewed annually and it will remain valid until it needs to be revised in accordance with any changes and legal updates that occur in the future, which will result in the preparation and publication of a new version.