C1 Broker – Commitment to Anti-Corruption and Anti-Money Laundering
At C1 Broker, we believe that corruption undermines the fundamental principles of democracy, including equality, transparency, free competition, impartiality and the rule of law. We conduct our business in accordance with ethical and legal principles that enable us to build strong relationships of trust with clients, insurers, supervisory authorities, employees, external partners and, more broadly, society, communities and their institutions.
C1 Broker’s multidisciplinary Compliance team is committed to implementing measures to prevent and detect corruption within the company, while respecting the Portuguese, Spanish and European legal frameworks. The choice of a cross-border legal approach reflects the international nature of our company, its founders and its expatriate clients. In recent decades, considerable efforts have been made to harmonise legal frameworks worldwide through multilateral conventions on the prevention and suppression of corruption, and C1 Broker has joined this movement by establishing an internal anti-corruption procedure.
C1 Broker’s Anti-Corruption Commitment
At C1 Broker, we reject any conduct that may, directly or indirectly, be related to corruption. Our actions are guided by the fundamental principles of respect, integrity, loyalty, ethics and compliance with applicable law.
In this context, the management of C1 Broker has approved an Anti-Corruption Policy as a tool to prevent both C1 Broker and external entities with which it has direct or indirect relationships from engaging in conduct that may be contrary to the law or to ethical and behavioural principles.
Some of the preventive measures we have implemented to reduce the likelihood of corruption risks and related offences include:
- Internal procedures and rules through the Anti-Corruption Policy;
- Appointment of a person responsible for regulatory compliance;
- Code of Ethics and Conduct;
- Whistleblowing Channel;
- Risk assessment;
- Internal controls and audits;
- Promotion of awareness and prevention measures;
- Annual training programme.
Ethical Values and Anti-Corruption
C1 Broker does not tolerate any conduct that may, directly or indirectly, be related to acts of corruption. All our activities are guided by the principles of respect and compliance with applicable general and sector-specific legislation.
C1 Broker does not participate in any unlawful activity and always seeks to prevent acts of corruption and safeguard against situations involving conflicts of interest.
Anti-Money Laundering and Counter-Terrorist Financing
Money laundering and terrorist financing are currently among the most serious criminal phenomena affecting the financial sector, with tax offences such as tax fraud being particularly significant. By their nature, these activities may arise from offences linked to corruption, including attempts to launder money received in exchange for improper benefits or influence.
C1 Broker, as a customer-focused company committed to complying with all applicable legislation, seeks to know the clients and entities with which it conducts business. We are committed to preventing money laundering and combating terrorist financing as a priority, complying with the relevant laws and regulations and taking measures to prevent and discourage the use of our products and services for money laundering or terrorist financing purposes.
Under the applicable legislation establishing measures to combat money laundering and terrorist financing, obliged entities are subject to a set of preventive duties and must implement the necessary procedures to ensure proper compliance with those obligations.
The risk profiles of clients in the Life Insurance sector are among the highest, and the standards applied by the insurers we work with in this area are more complex and demanding. C1 Broker has prepared, approved and implemented internal documents defining the procedures in force to ensure compliance with both national legislation and European Union requirements.
Implementation and Control
As a dynamic management tool, our Corruption Risk and Related Offences Prevention Plan is subject to updates and reviews and is evaluated and monitored annually in order to assess and adjust the effectiveness of the preventive measures implemented.
The plan and its annual implementation reports are published on the C1 Broker website and made available to employees.
This plan was prepared in June 2024 and will be reassessed every three years.