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Compliance Department, Code of Conduct and Social Responsibility

Anti-money Laundering

Picfare has a separate Money Laundering Reporting Officer (MLRO) whose responsibility it is to identify, assess, advise on, monitor and report external and internal compliance risks that is, the risk of legal or regulatory sanctions as a result of Picfarefailure to comply with all applicable laws, regulations, codes of conduct and standards of good practice. This responsibility includes documenting PicfareCompliance and Anti-Money Laundering (AML) policies and procedures which have been approved by the Board of Directors.

These contain sound Customer Due Diligence measures, procedures for identifying and reporting suspicious transactions and a program for periodic awareness training. The MLRO role is responsible for supervising the AML activities and for maintaining appropriate and effective systems, controls and records to ensure compliance with AML regulations and the provisions of PicfareAML Manual. The MLRO’s responsibility includes reviewing and reporting any suspicions concerning a customer or an account to the senior management. The MLRO reports directly to the Chief Executive Officer. A summary of PicfareAML policies are available elsewhere on Picfarewebsite.

The LRMCD conducts a full review of Picfare’s policies and procedures, with a focus on measures for enhancing staff awareness on compliance issues and providing a framework for resolving issues of an investigative nature.

Code of Conduct

Picfarehas adopted a professional Code of Ethics containing rules on conduct, ethics and on avoiding conflicts of interest applicable to all the Consultants and Directors of Picfare.  The Code of Ethics has been approved by the Board and each employee and all of the board members have signed up to it.

 The Code of Ethics is designed to guide all employees and directors through best practices to fulfil their responsibilities and obligations towards Picfare’s stakeholders in compliance with all applicable laws and regulations. 

The Code of Ethics addresses such issues as upholding the law and following best practices; acting responsibly, honestly, fairly and ethically; avoiding conflicts of interest; protecting Picfareproperty and data; protecting client confidential information and safeguarding the information of others; complying with insider dealing rules and with the prohibition of insider trading; preventing money laundering and terrorism financing; rejecting bribery and corruption; and avoiding compromising gifts.

Corporate Communications

In keeping with sound governance and transparency standards, the Board has adopted an updated Corporate Communications policy in line with best practices. These requirements call for the Board to oversee the process of disclosure and communications with stakeholders, and ensure that the disclosures made by Picfareare rational, understandable, thorough and timely, and reflect the image of Picfareand the nature, complexity and risks inherent in its business activities.

Corporate Social Responsibility

Picfare is committed to ensuring that its interactions with employees, clients, suppliers, shareholders, society and the wider environment are managed responsibly and ethically.

Maintaining high standards results in a range of long-term benefits for all stakeholders, including motivating employees, supporting community growth and development, minimizing risk, reducing costs and increasing shareholder value.

The Board and its Committees oversee these efforts and review performance and compliance periodically. Picfare’s vision is to maintain a set of values and standards focusing on the commitments outlined below:

  • Fostering an ethical work culture and respecting the principles of equality and diversity across all employment practices;

  • Safeguarding the health and safety of Picfare's customers, the public and Picfare's work force and maintaining a safe and secure working environment at all company locations;

  • Working with Picfare’s suppliers and business partners to promote the sustainable procurement of supplies, services and works;

  • Adhering to the highest quality and environmental management processes, with a commitment to green buildings and the environment; creating energy efficient residential and commercial buildings that support development;

  • Ensuring that Picfareprojects include the facilities necessary to support integration with local communities

Picfare adheres to the principles of corporate governance and a code of best practice set out in the UK Corporate Governance Code and is committed to high standards of corporate governance.

As part of Picfare’s Corporate Social Responsibility policy, all staff are afforded the opportunity to spend time volunteering for a charity or fundraising organisation that they would like to donate their time and energy to.  Opportunities have also been set up for staff to support charities that Picfareis already associated with.

Picfare also support a number of charities in Uganda through sponsorship, donations, fundraising and mentoring opportunities.