1. Purpose and Scope
This document defines the ethical standards, confidentiality requirements, conduct expectations, and AML/CTF procedures applicable to all employees, directors, consultants, representatives and partner offices of Kurz Sullivan.
Its purpose is to:
- establish a unified governance and compliance framework,
- define mandatory principles of integrity, professionalism and responsible conduct,
- ensure strict adherence to confidentiality obligations and NDAs,
- protect client information and strategic business materials,
- prevent financial crime, money laundering and terrorist financing,
- support consistent processes across all jurisdictions where Kurz Sullivan operates.
This policy applies to the London head office, the Prague EU operations hub and all recognised partner offices.
2. Ethical Code
2.1 Integrity and Professional Conduct
All personnel must act with honesty, independence and objectivity. Conduct that may compromise the company’s integrity, reputation or client interests is prohibited.
2.2 Confidentiality and Information Protection
All client and company information is strictly confidential and may only be used for legitimate business purposes.
This obligation continues indefinitely, including after termination.
2.3 NDA Compliance
All employees, contractors and partners must follow:
- internal confidentiality rules,
- NDAs with clients, partners or the company,
- secure data-handling and access protocols.
Unauthorised disclosure is a serious breach and may result in termination and legal action.
2.4 Conflicts of Interest
Any actual or potential conflict must be identified, disclosed and managed transparently.
2.5 Anti-Corruption and Anti-Bribery
Kurz Sullivan operates a zero-tolerance approach to bribery, facilitation payments and corrupt behaviour.
2.6 Professional Competence
All personnel must maintain relevant professional knowledge and regulatory awareness. Compliance training is mandatory.
3. Confidentiality & NDA Framework
3.1 Scope of Confidential Information
Confidential information includes, without limitation:
- client data, personal information and financial details,
- investment strategies, analyses and internal reports,
- agreements, contracts, business plans and legal materials,
- proprietary methodologies, tools and pricing structures.
3.2 Protection and Storage
- Confidential data must be stored only in authorised, secure environments.
- Access is granted strictly on a need-to-know basis.
- Sensitive data must be transmitted via secure or encrypted channels.
3.3 Prohibited Actions
Personnel may not:
- copy or transmit confidential information without approval,
- disclose information to unauthorised third parties,
- remove documents from secure systems without permission,
- use confidential information for personal benefit.
3.4 Post-Termination Obligations
Confidentiality and NDA obligations remain binding indefinitely, even after cooperation ends.
4. AML / CTF Policy
4.1 Client Due Diligence (CDD)
Client verification is mandatory prior to onboarding.
Individual Clients
- identity and address verification,
- date of birth verification,
- document authenticity checks.
Corporate Clients
- verification of legal existence,
- identification of UBOs,
- directors and authorised signatories,
- ownership and control structure.
Enhanced Due Diligence is required for high-risk clients.
4.2 Risk Assessment
Clients are risk-assessed based on factors such as:
- jurisdictional risk,
- PEP status,
- Source of Funds (SoF) / Source of Wealth (SoW),
- industry risk,
- adverse media,
- transaction behaviour.
4.3 Sanctions and PEP Screening
Clients and related parties are screened against sanctions and PEP lists on onboarding and periodically thereafter.
4.4 Source of Funds / Source of Wealth
Source of Funds
Verification of how a transaction is being financed.
Source of Wealth
Verification of how the client accumulated their overall wealth.
Acceptable evidence includes bank statements, contracts, audited accounts, inheritance documents, tax filings, etc.
4.5 Transaction Monitoring
The company reviews:
- unusual or inconsistent transaction patterns,
- large or cross-border transfers,
- payments from higher-risk jurisdictions,
- transactions without clear commercial purpose.
Any suspicious activity must be escalated internally.
4.6 Reporting and Escalation
Financial crime suspicions must be reported internally to the designated compliance function.
“Tipping off” is strictly prohibited.
4.7 Record Keeping
All AML and KYC documentation is retained securely for the required retention period.
5. Risk Scoring Matrix
Kurz Sullivan applies a structured risk-assessment model that classifies clients into four categories:
Low Risk (Score 0–4)
Characteristics:
- resident in a low-risk jurisdiction,
- simple and transparent SoF/SoW,
- no PEP exposure.
Requirements:
- standard CDD,
- basic SoF documentation.
Monitoring:
- review every 3–5 years; routine monitoring.
Medium Risk (Score 5–8)
Characteristics:
- generally regulated jurisdiction with minor elevated risk factors,
- limited structural complexity,
- SoF/SoW may require clarification.
Requirements:
- enhanced CDD,
- additional documentation.
Monitoring:
- review every 2–3 years; heightened alerts.
High Risk (Score 9–12)
Characteristics:
- client exposure to higher-risk jurisdictions or industries,
- complex ownership structure,
- significant or cross-border activity,
- PEP involvement.
Requirements:
- Enhanced Due Diligence (EDD),
- senior management approval.
Monitoring:
- annual review; targeted monitoring.
Very High Risk (Score 13+)
Characteristics:
- operations in high-risk/sanction-sensitive jurisdictions,
- opaque or incomplete SoF/SoW,
- adverse media or unresolved red flags.
Requirements:
- full EDD,
- potential refusal of onboarding.
Monitoring:
- continuous monitoring if accepted in exceptional circumstances.
6. Internal Security & Operational Controls
- strict access management,
- segregation of duties,
- cybersecurity procedures (encryption, MFA, VPN),
- secure data systems,
- periodic internal audits and compliance reviews.
7. Partner Office Compliance
Partner offices must follow:
- Kurz Sullivan’s Ethical Code and AML/CTF Policy,
- internal confidentiality standards and NDA requirements,
- local regulatory obligations,
- KYC/KYB coordination,
- periodic compliance reviews.
Non-compliance may result in immediate termination of cooperation.
8. Breaches and Consequences
Breaches of this policy may result in:
- disciplinary action,
- suspension or termination,
- reporting to authorities,
- contract termination,
- internal investigation.
9. Review and Updates
This document is reviewed periodically and updated when regulatory, operational or strategic circumstances require.