Ethics & Compliance

Our senior management promotes a culture of compliance throughout the organization. Zinerva LLC’s commitment to, and support of the Sanctions Compliance Program (SCP) places our SCP at the forefront of our business. We continually review and approve the Zinerva LLC SCP and ensure the existence of direct reporting lines between the SCP function and our senior management, including routine and periodic meetings between these two bodies.

We empower our personnel to report sanctions related misconduct by the organization or its personnel to senior management without fear of reprisal. At Zinerva LLC, our senior management recognizes the seriousness of apparent violations of the laws and regulations administered by OFAC and implements necessary measures to prevent any and all violations, including, taking actions that discourage misconduct and prohibited actives, and highlighting the potential repercussions of non-compliance with OFAC sanctions.

Our remediation measures include addressing the root causes of possible past apparent violations and represent systemic solutions whenever possible.

Zinerva LLC will conduct OFAC risk assessment that adequately accounts for potential risks. Zinerva LLC recognizes that these risks could be posed from nearly any point of its’ core business activity. Zinerva LLC appropriately updates the risk assessment to account for the root causes of any apparent violations or systemic deficiencies identified during our routine core of business.

Zinerva LLC implements an extensive due diligence effort at various points in a relationship or in a transaction including customer onboarding through our Know Your Customer (KYC) process. Zinerva LLC has developed a methodology to identify, analyze, and address risks by risk classification.

Zinerva LLC follows an internal controls process, including policies and procedures, in order to clearly and effectively identify, interdict, escalate, report (as appropriate), and keep records pertaining to activity that is prohibited by the sanctions programs administered by the OFAC. Zinerva LLC ensures that, upon learning of a weakness in its internal controls pertaining to OFAC compliance, it will take immediate and effective action, to the extent possible, to identify and implement compensating controls util the root cause of the weakness can be determined and remediated.

Zinerva LLC stands by a comprehensive, independent, and objective testing function that ensures awareness of where and how our programs are performing and should be updated, enhanced, or recalibrated to account for a changing risk assessment or sanctions environment. Zinerva LLC commits to ensuring that the testing or audit function is accountable to senior management, is independent of the audited activities and functions and has sufficient authority, skills, expertise, resources, and authority within the organization.

Zinerva LLC recognizes the importance of an adequate training program, tailored to an entity’s risk profile and all appropriate employees and stakeholders.

Zinerva LLC will not facilitate or support money laundering or terrorist financing. Zinerva LLC recognizes the definition of money laundering as the process by which individuals or entities try to conceal illicit funds, such as the proceeds of crime, or otherwise make such funds look legitimate. Zinerva LLC recognizes the definition of terrorist financing as using the money to fund terrorism.

Zinerva LLC’s Anti Money Laundering and Terrorist Financing Policy and Compliance documentation provides detailed guidance on the standards and controls that Zinerva LLC has in place to combat any money laundering activity to which the company may be exposed whilst conducting its business activities.

As an international organization, Zinerva LLC applies the principles of internationally recognized, industry standards to its anti-money laundering procedures and internal controls designed to ensure compliance with all applicable Bank Secrecy Act (BSA) and Financial Industry Regulatory Authority (FINRA) rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

At Zinerva LLC, all potential new clients and customers must satisfy the Know Your Client (KYC) due diligence process and be approved by compliance before any payments can be made or received. Any failure to follow the KYC process is reported to the Compliance Committee and is treated as a serious breach of the Code.

Zinerva LLC maintains integrity in its core business operations. Zinerva LLC complies with anti-bribery policies and prohibits the willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act of violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.

As Zinerva LLC maintains all securities listed in the United States, we meet the FCPA’s accounting provisions to make and keep books and records that accurately and fairly reflect the transactions of the corporation, and devise and maintain an adequate system of internal accounting controls.

Political Contributions & Activities

Zinerva LLC does not support individual political parties or individual politicians. Zinerva LLC employees should not make direct or indirect contributions on behalf of Zinerva LLC to political parties, organizations or individuals engaged in politics. Employees are free to participate in democratic political activities, but this should be done in their own time, using their own money and without reference to their relationship with Zinerva LLC.

Bribery & Corruption

Zinerva LLC is committed to conducting all of its business dealings in accordance with the principles set out in the FCPA bribery provisions which we believe reflects the same principles as other leading global anti-corruption regulation applicable standards.

Zinerva LLC prohibits employees and all of its representatives from engaging in any form of bribery or corruption, whether in the private or public sector.

Detailed guidance for employees is set out in the Zinerva LLC Anti-bribery and Corruption policy explains the principles applied by Zinerva LLC to its business activities; appropriate employee behavior; and how to handle high-risk activities such as the use of certain third-party advisors, joint venture arrangements and the provision of gifts and entertainment.

Gifts, Hospitality, & Entertainment

Reasonable gifts or entertainment, as part of normal business courtesy and general relationship building are generally acceptable.

Employees are not permitted to offer any gifts to representatives of government agencies or state owned entities other than small corporate branded gifts and reasonable value consumable products.

However, any form of gift or entertainment, irrespective of value, can be an issue if it results, even unintentionally, in the receiving party being improperly influenced.

Employees should consult the Zinerva LLC Anti-bribery and Corruption policy for details of the pre-approval process that needs to be followed before gifts and entertainment are offered or accepted.

Employees, consultants and all other representatives of the company, should not give, or accept, any gift or entertainment that is intended, or could be perceived as intended, to influence the outcome of a commercial decision.

Use of Consultants and Intermediaries

Zinerva LLC does not retain third-parties for the provision of business origination or business development services.

The use of certain types of third party service providers can expose Zinerva LLC to increased risk.

Consequently, all arrangements with any type of advisory consultant must be pre-approved by senior management as part of the enhanced due diligence process applicable for these types of entities before any written or oral commitment to retain their services is made.

The Compliance Department can provide details of the relevant procedure and will oversee the review process.

Zinerva LLC always operates in compliance with all applicable anti-trust and competition law requirements. More detail on the approach that employees are expected to apply is set out in the Zinerva LLC Competition and Anti-trust Policy.

All Zinerva LLC employees are required to maintain accurate books and records of Zinerva LLC business activities. It is particularly important that employees do not produce or amend documentation with the intent of illegally misleading any third party in relation to any aspect of a transaction.