AFS is a company that conducts its business according to the following principles:
- Integrity and Transparency: We handle our day to day business with integrity and according to the applicable laws, regulations and proceedings;
- Trust: In every industry but especially in the financial industry trust is a ‘key’ word. Trust is a value preached by everybody within AFS;
- Respect: We communicate respectfully with our clients, employees and counterparties.
In our company we have implemented the following compliance proceedings to ensure that we are compliant with all applicable laws and regulations:
Anti Money Laundering
AFS is committed to preventing its business from being used to facilitate money laundering or terrorist financing. AFS has implemented an anti-money laundering (AML) compliance program to ensure it is in compliance with all applicable laws and regulations, including the Bank Secrecy Act (BSA). Among other things, this AML program includes procedures related to customer identification and verification, monitoring and reporting suspicious activity and transactions, ongoing employee training and annual independent testing of the program’s adequacy. All employees are required to adhere to the AML program.
Employee Code of Conduct
The AFS Code of Conduct has been compiled to avoid any (semblance of) mixing of business and private interests with respect to transactions in financial instruments. The code of conduct is applicable to all employees.
Know Your Customer
For every new client, AFS will start a ‘Know Your Customer’ proces to ensure the true identity of our clients and/or counterparties.
Pre Employment Screening
Before entering in our company, all employees are screened (Pre-employment Screening) by the official Dutch Security Institute to ensure that all our employees meet certain requirements in terms of expertise, integrity and work experience.
AFS’ subsidiaries operate under supervision of the Dutch Central Bank (DNB) and avail of all required licences of the Netherlands Authority for the Financial Markets (AFM). AFS is also a member of the ICMA (International Capital Market Association) and ACI Nederland (The Financial Markets Association). The company is also a participant in DSI (Dutch Securities Institute) and its traders have been registered at DSI. The activities of the London office are regulated by the FSA (Financial Services Authority). The Zurich branch is regulated by the FINMA.
The AFS remuneration policy is thoughtfully prepared according to all applicable law and regulations, taking into account the AFS strategy, risk appetite, corporate values, business principles and corporate governance. The personal variable component in the employer’s remuneration is discretionary and based on several indicators like: department- desk and personal turnover, acquisition, general effort, junior assistance, cooperation and business development. The AFS management is valuate on the same principles.
Strict segregation of duties between Front-, Mid-, and Back-Office
Within AFS the Mid-Office records, confirms and settles trades transacted by the Front-Office, draws up loan contracts and reconciles trades with details sent by the counterparty. The Mid-Office also authorises the clearing to accept and/or release securities and payments for trades. The Back-offices takes care of invoicing, provides the regulatory reports and management accounting.
Summarised: separately from the Front-Office, the Mid- and Back-Office provides the necessary checks to prevent unauthorised trading and minimise the potential for fraud and embezzlement.