Compliance & Ethics

Anti-Money Laundering (AML) Policy

Nautical Resources Sdn Bhd is committed to conducting its business in a lawful, ethical, and transparent manner — with zero tolerance for money laundering or terrorism financing.

Sections

  1. Introduction
  2. Objectives
  3. Scope
  4. Definitions
  5. Legal Framework
  6. Prohibition of ML Activities
  7. Due Diligence
  8. Monitoring & Detection
  9. Record Keeping
  10. Training & Awareness
  11. Reporting & Whistleblower
  12. Policy Review

1. Introduction

Nautical Resources Sdn Bhd is committed to conducting its business in a lawful, ethical, and transparent manner. The Company adopts a zero-tolerance approach to money laundering, terrorism financing, and any activities involving the proceeds of unlawful activities.

Money laundering undermines the integrity of financial systems and facilitates criminal activities. Nautical recognizes its responsibility to prevent its business operations, financial systems, and relationships from being used to facilitate such illegal activities.

Any employee, director, or person associated with Nautical who is involved in money laundering activities will be subject to disciplinary action, including termination of employment or contractual relationship, and may be reported to the relevant authorities.

2. Objectives

The objectives of this Policy are to:

  • Ensure compliance with applicable Malaysian laws and regulations relating to money laundering and terrorism financing.
  • Establish internal controls and procedures to detect, prevent, and report suspicious financial activities.
  • Provide employees with guidance on identifying and responding to potential money laundering risks.
  • Protect Nautical from legal, regulatory, financial, and reputational risks associated with money laundering.

3. Scope

This Policy applies to ALL employees and directors of Nautical Resources Sdn Bhd,
regardless of their position or department.

This Policy also applies to persons associated performing work or services with, for, or on behalf of Nautical, including:

  • Contractors
  • Vendors
  • Suppliers
  • Consultants
  • Agents and representatives
  • Business partners

All persons covered by this Policy must comply with relevant provisions when
conducting business on behalf of Nautical.

4. Definitions

In this Policy, unless the context otherwise requires, the following terms shall have the meanings respectively assigned to them:

Money Laundering

Refers to any act of converting, transferring, acquiring, possessing, or using proceeds derived from unlawful activities with the intent to conceal or disguise the illegal origin of such funds.

Terrorism Financing

Refers to the provision or collection of funds intended to support terrorist acts, terrorist organizations, or individuals involved in terrorism.

Person Associated

Refers to external parties with whom Nautical has or intends to establish business relationships, including contractors, vendors, suppliers, consultants, agents, and representatives.

Suspicious Transaction

Any transaction that appears unusual, inconsistent with normal business practices, or gives rise to suspicion that it may involve money laundering or terrorism financing.

Proceeds of Unlawful Activities

Refers to any property or financial benefit derived directly or indirectly from illegal activities.

5. Legal and Regulatory Framework

This Policy is developed in accordance with relevant Malaysian laws and regulations, including but not limited to:
  • Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA)
  • Bank Negara Malaysia guidelines and regulatory requirements
  • Other applicable laws relating to financial crimes and unlawful activities.
Nautical is committed to complying with all relevant legal obligations and regulatory requirements in preventing money laundering and terrorism financing.

6. Prohibition of Money Laundering Activities

Nautical strictly prohibits any involvement in money laundering or related activities.
Employees and associated persons must not:

  • Accept or process funds that are suspected to be derived from unlawful activities
  • Conceal or disguise the origin of illegally obtained funds
  • Assist any individual or entity in laundering money
  • Participate in any transaction that may facilitate terrorism financing
Any violation of this Policy may result in disciplinary action, termination of employment or contract, and referral to law enforcement authorities.

7. Customer and Business Partner Due Diligence

Nautical will conduct appropriate due diligence before entering into business
relationships with customers, vendors, suppliers, contractors, or other third parties.

Due diligence may include:

  • Verifying identity and legitimacy of business partners
  • Assessing business reputation and background
  • Reviewing ownership structures and beneficial owners
  • Evaluating potential risks of money laundering

Enhanced due diligence may be applied where higher risk factors are identified.

8. Monitoring and Detection of Suspicious Activities

Employees must remain vigilant in identifying potential signs of money laundering, including:

  • Unusual payment methods or large unexplained cash transactions
  • Transactions that do not match the nature of the business relationship
  • Requests to structure payments to avoid reporting requirements
  • Use of complex or unexplained financial arrangements

Any suspicious activities must be reported immediately through the appropriate internal
channels.

9. Record Keeping

Nautical maintains accurate and complete records of financial transactions and business relationships. Records must include:
  • Transaction documentation
  • Customer and partner identification information
  • Due diligence records
  • Compliance documentation
These records must be maintained securely and retained in accordance with applicable legal and regulatory requirements.

10. Training and Awareness

Nautical may provide training and awareness programs to employees to ensure they understand:
  • Money laundering risks
  • Legal obligations under Malaysian law
  • How to identify suspicious transactions
  • Reporting procedures under this Policy

Employees must cooperate with compliance initiatives and participate in relevant
training where required.

11. Reporting Violations & Whistleblower Protection

Employees and associated persons are encouraged to report suspected money laundering activities or violations of this Policy.
Reports may be made to:

  • Immediate Supervisor
  • Head of Department
  • Administrative Department
  • Legal Department
  • Internal Audit
Employees making reports must ensure that:
  • Reports are made in good faith and based on reasonable grounds
  • They cooperate with any internal investigations
  • Reports are not made with malicious intent
Nautical strictly prohibits retaliation against employees who report concerns in good faith. All reports will be handled confidentially and investigated appropriately.

12. Policy Review

This Policy will be periodically reviewed and updated to ensure compliance with evolving laws, regulations, and best practices relating to anti-money laundering and counter-terrorism financing.