Sanctions & Anti-Corruption Stance Policy

Purpose and Audience

Because STIDE sits in the flow of cross-border mandates, structures and information, STIDE’s ability to operate depends on a clear and uncompromising position on sanctions, bribery and corruption. This page states STIDE’s public stance and the minimum behavioural expectations for parties engaging with STIDE (including clients, counterparties, introducers and other intermediaries).

STIDE’s Role and Regulatory Perimeter

STIDE operates as an arranger/advisory and structuring support firm and is not a bank or deposit-taking institution. STIDE does not accept deposits, does not act as lender-of-record, does not provide custody, and does not handle client monies or transaction proceeds. Where regulated activities may arise in connection with a transaction, those activities must be performed by appropriately licensed or exempt third parties with clear handoffs and role allocation.

Sanctions Stance

Zero tolerance for sanctions breaches and circumvention. STIDE maintains a zero-tolerance stance towards violations or circumvention of applicable sanctions regimes, including UN, Singapore, US/OFAC, EU and UK sanctions (and other national regimes where applicable to the mandate).

STIDE will not knowingly advise on, arrange, or participate in any transaction, structure, or relationship that involves:

• sanctioned persons, entities, vessels or countries; or
• arrangements whose purpose or effect is to evade or frustrate sanctions controls.

Where multiple sanctions regimes may apply, STIDE applies the most conservative position that is reasonably practicable for the mandate.

Anti-Corruption / Anti-Bribery Stance

Zero tolerance for bribery and corrupt conduct. STIDE prohibits bribery, kickbacks, facilitation payments and any form of corrupt conduct, whether direct or through third parties.

STIDE will not support any engagement involving the payment, offer, request or acceptance of bribes or improper advantages in any form.

Refusal to Participate in Concealment Structures

STIDE will not design, recommend, or facilitate structures whose main purpose or effect is to:

• conceal or obscure ultimate beneficial ownership (UBO);
• disguise the true origin or destination of funds or assets;
• evade or frustrate sanctions, anti-corruption, AML/CFT or tax transparency requirements; or
• shield politically exposed persons (PEPs) or state-linked actors from legitimate scrutiny.

STIDE expects full transparency on ownership, control and source of wealth/funds from clients, counterparties and introducers as a condition of engagement.

Expectations of Clients, Partners and Introducers

STIDE requires counterparties and partners (including borrowers, sponsors, originators/NBFIs, investors, consultants, introducers and intermediaries) to:

• comply with applicable sanctions, anti-corruption and AML/CFT laws in all relevant jurisdictions;
• maintain internal controls to prevent bribery, corruption and sanctions evasion;
• provide accurate, complete and timely information on ownership, control, business activities and source of wealth/funds; and
• refrain from using STIDE’s services to mask or legitimise unlawful or unethical conduct.

STIDE will not pay or receive fees through opaque or unvetted third parties and will not enter sham “consulting” or “success fee” arrangements designed to channel improper payments.

Screening, Due Diligence and Ongoing Monitoring

7.1 Minimum onboarding checks

Before accepting a mandate, STIDE’s minimum checks include:

• identify and verify the client (borrower, sponsor, originator, investor or other party);
• identify UBOs and key controllers to a reasonable level based on risk;
• understand business activities, geographic exposure and source of wealth/funds at a high level; and
• screen the client, UBOs and key controllers against relevant sanctions lists and, where available, PEP/adverse media databases.

7.2 Handling matches and red flags

Any positive or uncertain screening match must be escalated and cleared before proceeding. Where significant red flags arise, STIDE documents the risk assessment, prepares an escalation note, and records the decision (proceed / proceed with conditions / decline or exit).

7.3 Ongoing monitoring

For active mandates and key counterparties, STIDE conducts periodic re-screening and reviews for material changes (e.g., sanctions changes, ownership changes, major investigations). Material changes or new red flags are documented and escalated for a decision.

High-Risk Jurisdictions, Sectors and Structures

STIDE applies enhanced controls and approvals for higher-risk mandates, including those involving (i) high-risk jurisdictions, (ii) PEPs or close links to PEPs, (iii) complex multi-layered structures across multiple offshore jurisdictions, and (iv) sectors with elevated corruption or sanctions risk.

Internal lists to be adopted and maintained by STIDE: (a) high-risk jurisdictions list (STIDE TO DECIDE), (b) elevated-risk sectors list (illustrative examples in the internal policy include defence, extractives, gambling, crypto/virtual assets, and certain state-linked sectors), and (c) higher-risk structure types (e.g., multi-layer nominee chains, opaque trusts, complex offshore-on-offshore flows without clear rationale).

Third Parties, Introducers, Consultants and Fee-Sharing

STIDE does not engage intermediaries or share fees unless:

• a written agreement defines scope, services and fees;
• the intermediary has been subject to basic KYC and sanctions screening;
• fees are commensurate with legitimate work performed; and
• payments are made through traceable, legitimate banking channels to the contracted entity.

STIDE prohibits:

• paying success fees or commissions to government officials, PEPs or close associates;
• paying fees to anonymous or unvetted third parties at the direction of clients; and
• cash payments (other than low-value, pre-approved petty cash where relevant).

Gifts, Hospitality, Donations and Sponsorships

Modest, reasonable and transparent gifts and hospitality may be permitted only where lawful, pre-approved in line with STIDE’s internal rules, and recorded in a gifts and hospitality register.

Monetary thresholds and pre-approval rules: STIDE TO DECIDE (the internal policy explicitly requires thresholds, pre-approval rules, and recording).

Donations and sponsorships must be approved by senior management, be transparent and documented, and must not be linked to obtaining or retaining business.

Facilitation (“Grease”) Payments

Facilitation payments are prohibited, even if considered customary in certain countries.

Exception (duress only): payments made under genuine duress or immediate threat to health or safety may be permitted, but must be reported as soon as practicable, documented (amount, recipient, circumstances), and reviewed for follow-up action.

Escalation, Decision-Making and Right to Decline/Exit

STIDE reserves the right to decline mandates or relationships where it is not satisfied with sanctions or anti-corruption risk, information quality or transparency. STIDE may suspend or terminate engagements where new information, sanctions developments or red flags arise. Where legally required and appropriate, STIDE may share information with relevant partners or authorities.

Any suspected sanctions or corruption issue must be escalated immediately to the designated Compliance Officer and, where material, senior management/the Board. High-risk onboarding and exceptions require a written escalation note, a recorded decision with rationale, and approval in line with STIDE’s internal authority matrix.

Compliance Officer designation and authority matrix: STIDE TO DECIDE (the internal policy requires appointment of a Compliance Officer, even if dual-hatted initially).

Record Keeping and Retention

STIDE maintains adequate records of KYC/CDD/EDD information and screening results, risk assessments and red flag analyses, escalations/decisions/approvals, and training/monitoring/testing activities.

Records are retained for at least 7 years after the end of the relationship or transaction, or longer if required by law.

Training, Monitoring and Testing

Staff receive sanctions and anti-corruption training at hiring (induction) and periodically thereafter (at least annually). STIDE implements proportionate monitoring and testing, including periodic file reviews, spot checks on higher-risk mandates, and reviews of gifts/hospitality and intermediaries. As STIDE grows, it may consider independent/external testing of controls.

Whistleblowing and Non-Retaliation

STIDE maintains a whistleblowing mechanism allowing concerns to be raised confidentially and without retaliation. Credible allegations are investigated promptly and fairly, and STIDE may take appropriate action including discipline, mandate termination, and reporting to authorities where required.

Channel: reports may be raised via compliance@stide.asia. The internal roadmap contemplates establishing a dedicated whistleblowing channel (email/line) not accessible to line managers only: STIDE TO IMPLEMENT.

Cross-Border Considerations

This stance applies across jurisdictions where STIDE operates or has counterparties. Parties engaging STIDE remain responsible for complying with applicable local laws. Where multiple regimes apply, STIDE applies a conservative, risk-based approach and may decline or exit where transparency cannot be achieved.

Contact

General: contact@stide.asia
Compliance escalation / reporting: compliance@stide.asia

Items Still Marked “STIDE TO DECIDE / IMPLEMENT”

Abbreviations / Glossary

• ABC: Anti-Bribery and Corruption
• AML/CFT: Anti-Money Laundering / Countering the Financing of Terrorism
• CDD: Customer Due Diligence
• EDD: Enhanced Due Diligence
• OFAC: U.S. Office of Foreign Assets Control
• PEP: Politically Exposed Person
• UBO: Ultimate Beneficial Owner
• UN: United Nations