Borealis Commercial Limited unequivocally commits to full compliance with all applicable laws and the highest ethical standards in Hong Kong and abroad. This commitment is anchored by our adherence to key legal frameworks: the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), which has been in effect since 2012, and the Prevention of Bribery Ordinance (Cap. 201), Hong Kong’s seminal anti-corruption law enacted in 1971. In practice, this means we have robust systems to detect and prevent money laundering and terrorist financing, and we strictly prohibit and will not tolerate any form of bribery or corrupt practice within our organization or in any business dealing.
Our compliance program also encompasses international obligations on sanctions and human rights. We ensure strict sanctions compliance, observing all sanctions and export control laws administered by the UN Security Council, U.S. OFAC, the EU, the UK, and relevant Hong Kong authorities. We do not engage with any sanctioned individuals, entities, or countries, and we continuously screen counterparties against updated sanctions lists. Additionally, we endorse the humanitarian values behind the UK Modern Slavery Act 2015. The company has procedures in place to guard against forced labor or human trafficking in any part of our supply chain.
To implement these principles effectively, we conduct comprehensive Know Your Customer (KYC) and Customer Due Diligence (CDD) reviews for all counterparties, thereby verifying their identities and assessing risk before entering into any business relationship. We also invest in regular training for our employees and continuously enhance our internal control systems to ensure ongoing compliance and to quickly address any potential issues. We affirm that all personnel, from leadership to front-line staff, are accountable for upholding these commitments, and we will take prompt disciplinary action in the event of any violations. Our zero-compromise approach to compliance and ethics serves to protect our reputation, meet our legal obligations, and build trust with our stakeholders.