ANTI-FINANCIAL CORRUPTION AND DUE DILIGENCE POLICY


Effective Date: 31 July 2025 (review date 30 July 2026)
Applies to: All employees, directors, officers, contractors, and partners of AR Studios Ltd

1. Policy Statement

AR Studios Ltd (“the Company”) is committed to conducting its business with the highest standards of integrity, transparency, and accountability. The Company adopts a zero-tolerance approach to bribery, corruption, money laundering, terrorist financing, fraud, or any form of financial crime.

This Policy is designed to safeguard AR Studios Ltd from engaging—directly or indirectly—with individuals, entities, or jurisdictions associated with financial irregularities, fraudulent practices, opaque accounting, or high-risk profiles, including those linked to sanctioned regimes such as the Russian Federation.

In line with our commitment to ethical growth and sustainability, we also strive for alignment with ESG (Environmental, Social, and Governance) principles. Partners that demonstrably share these values will be prioritised.

2. Scope

This Policy applies to:

  • All employees, officers, directors, and consultants of AR Studios Ltd;

  • All third-party contractors, suppliers, vendors, financiers, and production partners;

  • All co-producers, funders, distributors, or content licensees;

  • Any party engaging in joint ventures, partnerships, or any commercial collaboration with AR Studios Ltd.

3. Legal Framework

This Policy is in full compliance with the following legislation:

  • UK Bribery Act 2010

  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

  • Sanctions and Anti-Money Laundering Act 2018

  • Companies Act 2006

  • Proceeds of Crime Act 2002

  • All applicable regulations issued by HM Treasury’s Office of Financial Sanctions Implementation (OFSI)

4. Prohibited Conduct

The Company strictly prohibits the following:

  • Engaging in or facilitating any bribery, including offering, promising, giving, requesting or accepting a financial or other advantage to influence decisions;

  • Receiving or providing any benefit in return for preferential treatment in any business matter;

  • Entering into commercial arrangements with individuals or organisations that:

    • Are unable or unwilling to produce transparent financial records;

    • Appear on UK or international sanctions lists (e.g. OFSI, EU, UN, US OFAC);

    • Have suspected or known affiliations with hostile state actors, including but not limited to Russia, Iran, or North Korea;

    • Have previously been involved in money laundering, embezzlement, fraud, or misappropriation of public or private funds;

    • Operate through offshore, shell, or unverified banking structures or complex ownership chains lacking clear beneficial ownership.

5. Mandatory Due Diligence Procedures

Prior to entering any formal engagement (e.g. contractual agreement, investment partnership, content licensing, co-production), AR Studios Ltd shall:

  • Conduct Enhanced Due Diligence (EDD) for all high-risk parties or transactions, including:

    • Verification of Ultimate Beneficial Owners (UBOs);

    • Full review of corporate structure, financial statements, and source of funds; including requiring a signed Source of Funds declaration.

    • Screening against international sanctions lists;

    • Adverse media and PEP (Politically Exposed Persons) checks.

  • Where red flags are identified, escalate to the Compliance Officer for further review and written clearance.

  • Retain full documentation of all due diligence checks for a minimum of six (6) years.

  • Require counterparties to sign a Compliance Certificate, affirming their understanding and acceptance of this Policy, and declaring they are not subject to any sanctions or investigations.

6. Whistleblowing and Internal Reporting

AR Studios Ltd encourages and protects individuals who raise concerns about suspicious financial activity or breaches of this Policy. Whistleblowers are protected under the Public Interest Disclosure Act 1998.

Concerns should be reported to:
Compliance Officer (CEO): Mr Ranw Aso-Rashid
Email: info@arstudiosltd.com

All disclosures will be treated confidentially and without retaliation.

7. Enforcement and Disciplinary Action

Failure to comply with this Policy will result in disciplinary action, which may include:

  • Termination of contract or employment

  • Civil legal action

  • Criminal prosecution, where applicable

AR Studios Ltd reserves the right to report any suspicious activity to the National Crime Agency (NCA), OFSI, or relevant enforcement bodies without prior notice to the involved party.

8. Ongoing Monitoring and Right to Terminate

AR Studios Ltd reserves the right to:

  • Conduct ongoing risk assessments and transaction monitoring;

  • Audit counterparties and joint venture partners;

  • Suspend or immediately terminate any relationship, even mid-contract, if new adverse information comes to light or material risk emerges relating to legal non-compliance, sanctions breaches, financial irregularities, or ESG misalignment.

9. Training and Awareness

All relevant personnel will undergo periodic training to understand their obligations under this Policy and applicable UK law. Refresher training will be provided annually or upon material legislative or regulatory changes.

10. Policy Review

This Policy will be reviewed annually or upon the enactment of new relevant legislation. Updates will be approved by the CEO and disseminated to all relevant stakeholders.