Anti-Money Laundering Policy

Intent

Becton aims to prevent, detect and not knowingly facilitate money-laundering and terrorism financing. Becton has adopted this policy to protect its reputation, to comply with relevant laws and to be a good corporate citizen. The purpose of this policy is to—

  1. make employees, contractors and third parties aware of the meaning of anti-money laundering and counter-terrorism financing (AML/CTF)
  2. state Becton’s attitude toward money-laundering and the financing of terrorism
  3. outline the key roles and responsibilities of Becton’s employees, contractors, third parties and business units in relation to AML/CTF, and
  4. document the requirements of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) which replaces over time the requirements of the Financial Transaction Reports Act 1988.

Risk of facilitating money-laundering and terrorism and terrorist funding

Becton faces risks of money laundering or terrorism financing if it (or its employees) knowingly facilitate or fail to put in place the appropriate training, processes and systems to prevent the facilitation of money-laundering or terrorism financing. The potential risks that could occur include the following:

  1. Reputation risk—customer loss of confidence in being associated with an entity perceived to be assisting criminals or terrorists. This loss of confidence could lead to a loss of business and revenue and to a decline in shareholder value and undermine Becton’s investments in corporate and social responsibility.
  2. Personal risk—employees who facilitate money-laundering or terrorist activities, or fail to take appropriate steps to prevent these activities, could face personal criminal action, civil action or dismissal.
  3. Regulatory risk—potential or increased regulatory oversight if perceived to be facilitating money-laundering or terrorist financing. This could be from regulators other than AUSTRAC. This could also result in possible fines or regulatory sanctions.
  4. Shareholder risk—potential for shareholders to bring civil lawsuits against officers and directors if the failure to take appropriate anti-money laundering or counter-terrorism financing actions was the proximate cause of a decline in shareholder value.

Policy framework

This policy is part of a policy framework comprising this policy, the AML/CTF compliance program adopted and maintained by Becton and the AML/CTF procedures.

Scope

This policy applies to all Becton’s employees, secondees, contractors, and people on work experience in Australia and in other overseas offices (these are called employees and contractors in this policy). This policy applies to all countries in which Becton operates. Non-Australian based business units will use this policy as the basis for which to draft business unit specific procedures, but will incorporate the requirements of local laws where relevant.

Definitions

Money-laundering—money-laundering is the process by which criminals use the financial system to hide the proceeds of crime, turning 'dirty' money into 'clean' laundered money. Criminals undertake money-laundering in order to reduce the risk of detection and confiscation by the authorities.

Money-laundering is just a series of the underlying crimes that generates the money that is laundered (for example, criminals are less likely to engage in drug-trafficking if they are unable to profit from it financially in a way that avoids detection). Preventing money-laundering can therefore for instance, help prevent drug-trafficking.

Terrorism financing—terrorism financing differs from money-laundering in two ways:

  1. Very small sums of money can do very large amounts of damage in the hands of a terrorist.
  2. Although terrorists can finance their activities through crime, particularly fraud involving stolen cheques or fake or stolen credit cards, legitimate funds can also be misappropriated for terrorist financing.

Principles

The principles governing Becton’s approach to money-laundering and terrorism financing are as follows:

  1. We maintain a Program as required by the AML/CTF Act. This means we—
    1. have and comply with a Program
    2. implement processes designed to identify, mitigate and manage the risk we may reasonably have that the provision of designated services by us might (whether advertently, inadvertently or otherwise) involve or facilitate money-laundering or financing of terrorism, and
    3. implement applicable customer identification procedures for our investors.
  2. We comply with the law and aim for best practice:
    1. We comply with national AML/CTF laws in the countries in which we operate and have regard to international best practice as detailed, for example, in the recommendations of the Financial Action Task Force.
    2. We will work in conjunction with the Australian government, and the governments of any country in which we operate, and support these government's objectives in relation to prevention, detection and control of financial crime.
    3. We will refuse to enter into relationships with shell banks.
  3. We take a risk-based approach:
    1. We train our employees and contractors to be alert to money-laundering and terrorism financing risks.
    2. Our systems, procedures and training are developed to take account of the differences in AML/CTF risk in the countries in which we operate.
    3. Due diligence processes for customers are tailored according to our analysis of the money-laundering or terrorism financing risk associated with those customers (or customer groupings) and the designated services, geographies or channels involved.
    4. We check relevant transactions, including by referring to worldwide terrorist lists.
    5. We conduct research into money-laundering and terrorism financing risks. The output of this research is used for internal training and monitoring customer activity.
    6. We assess the risks of our products, and monitor the activities of our customers using a risk-based approach.
  4. We adopt a centralised model (where appropriate):
    We identify customers in accordance with current legislative requirements in the countries in which we operate.
  5. We act on our suspicions:
    1. We report our suspicious matters or activity to the appropriate authorities in a timely and comprehensive manner, as required by local laws or our own policy, whichever provides the greater standard.
    2. We will refuse to enter into business relationships where we suspect that Becton’s products or services might be used for illegitimate purposes. We will not provide the reasons to the customer to avoid tipping off the customer.
  6. We maintain a high standard of record keeping. Becton will retain records of all documentation as required pursuant to the AML/CTF Act whilst ensuring complete compliance with the Privacy Act 1988 (Cth).

Policy review

This policy will be reviewed annually by our AML/CTF Compliance Officer to determine if policy amendments need to be submitted to our board of directors for consideration and approval. In addition, this policy will be reviewed following any substantial changes to AML/CTF legislation or external factors such as regulatory feedback. If a change proposed for this policy will impact significantly on Becton’s business, then the change will require board sign off.

Consequences of breaching this policy

Every employee of Becton has compliance and operational risk related obligations that vary according to their job. Non-compliance with the obligations set out in this policy may be considered a breach. A breach of this policy may result in disciplinary action and could include dismissal if the breach is serious.

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