C1 Broker - Anti-Corruption and Money Laundering Commitment
At C1 Broker, we believe that corruption offends the fundamental principles of democracy, such as equality, transparency, free competition, impartiality and legality, among others. Based on Decreto-Lei nº 109-E/2021, the Mecanismo Nacional Anticorrupção and the proposed Estratégia Nacional Anticorrupção, we guide our activity through ethical and legal principles that allow us to achieve solid bonds of trust between clients, insurers, control bodies, workers and external collaborators, and in general, citizens, communities and their institutions.
C1 Broker’s multidisciplinary Compliance working group is committed to implementing measures to prevent and detect corruption within the company, as a productive organization made up of people and capital, and respecting the Portuguese, Spanish and European legal framework. The choice of a transnational legal approach is due to the international nature of our company, its founders and its Expats clients. In recent decades, there has been a considerable effort to harmonize legal frameworks around the world through the adoption of multilateral conventions on the repression and prevention of corruption, and C1 Broker has joined this movement by setting up an internal anti-corruption procedure.
Portuguese legislation, specifically Decreto-Lei n.º 109-E/2021 , defines corruption and related offenses as “the crimes of corruption, undue receipt and offer of advantage, embezzlement, economic participation in business, concussion, abuse of power, prevarication, influence peddling, money laundering or fraud in obtaining or diverting a subsidy, grant or credit” provided for in the Penal Code and the Code of Military Justice.
C1 Broker's anti-corruption commitment
At C1 Broker we repudiate the practice of any conduct that, directly or indirectly, may be related to corruption, regulating our actions by the fundamental principles of respect, integrity, loyalty, ethics and compliance with the law in force.
In this context, C1 Broker’s management has approved an Anti-Corruption Policy as an instrument to prevent both C1 Broker and the external entities with which it has direct or indirect relationships from acting in ways that could constitute practices contrary to the law and to ethical and conduct principles.
Some of the preventive measures we have implemented to reduce the likelihood of risks of corruption and related infractions are:
- Internal procedures and regulations through the Anti-Corruption Policy;
- Election 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 actions;
- Annual training program.
Ethics and anti-corruption values
C1 Broker does not tolerate the practice of any conduct which, directly or indirectly, may be related to acts of corruption, guiding all its actions by the principles of respect and compliance with the general law and other regulations.
C1 Broker does not collaborate with any illicit cause, always aiming to prevent the existence of acts of corruption and to safeguard situations in which there is a conflict of interest.
Prevention of Money Laundering and Terrorist Financing
Money laundering and terrorist financing are currently among the most serious criminal phenomena in the financial sector, with tax crimes such as tax fraud standing out. By their nature, they can result from a crime linked to a crime of corruption, in an attempt to launder money received in exchange for some favor or undue influence.
C1 Broker, as a client-focused company committed to complying with the applicable legislation, wants to get to know the clients and entities with which it has dealings. We are committed to the prevention of money laundering and the fight against terrorist financing as a priority task, complying with the laws and regulations on this matter in order to prevent and discourage the use of its products and services for money laundering or terrorist financing purposes.
Under current Portuguese legislation, Lei n.º 83/2017, de 18 de agosto, which establishes measures to combat money laundering and terrorist financing, a set of preventive duties are imposed on obliged entities, to which they are bound and in relation to which they must implement the procedures necessary for proper compliance.
The risk profiles of Life Clients are the highest and the standards of the insurance companies we work with in this sector are more complex and demanding. C1 Broker has developed, approved and implemented internal documents defining the procedures in force to comply with both national and EU legislation.
Implementation and Monitoring
As a dynamic management tool, our Plan for the Prevention of Risks of Corruption and Related Offenses is subject to updates and revisions and is evaluated and monitored annually, with the aim of tracking and adjusting the performance of the preventive measures implemented.
The plan and the annual implementation reports are published on C1 Broker’s website and among its employees.
This plan was drawn up in June 2024 and will be reassessed every 3 years.
