Welcome to Sirona Seychelles LTD

  Sirona  is fully committed to support its customers, suppliers and agents in being ‘Conflict-Free’ compliant by implementing appropriate ‘known origin’ systems. The World Gold Council has developed the Conflict-Free Gold Standard, an industry-led approach to combat the potential misuse of mined gold to fund armed conflict. The Standard has been developed with its member companies, comprising the world’s leading gold producers, and with extensive input from governments, civil society and supply chain participants. It is hoped that the Standard will promote responsible mining practices throughout the gold mining industry. This is an open standard that is available for use by any party involved in the extraction of gold. Responsibly undertaken, gold mining can play an important role in contributing to sustainable development and alleviating poverty in many of the world’s developing countries. The direct and indirect economic contribution of professional gold mining creates new possibilities for these nations, their communities and citizens. However, when there is armed conflict, even the best managed operation will need to take additional steps to ensure that both the gold it produces and its broader activities do not contribute to the conflict. Where a company can demonstrate that it is operating in an area assessed to be ‘conflict-affected or high-risk’ in a way that does not support or benefit unlawful armed conflict, it should be encouraged to continue its operations. Indeed, the closure or suspension of a major source of employment and government revenue may accentuate the crisis. Gold produced in conformance with the Conflict-Free Gold Standard will provide confidence that it has been extracted in a manner that does not cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law. The Standard is based upon internationally recognized benchmarks and conformance will be subject to external assurance. It has been widely recognized as credible and workable. http://www.gold.org/about_gold/sustainability/conflict_free_standard  

Sirona Seychelles LTD 

The Management 

  SIRONA herein cooperates with, and enhances worldwide efforts to ensure that precious metals come from legitimate, ethical sources, and that they are not and have not been associated with crime, armed conflict or human rights abuse. Our policy aims to do business with law-abiding and legitimate customers only, and to deny our product and services to all others. This policy, as well as the program and due diligence procedures that implement it, are founded upon our general standards of business conduct. As a result we are committed to:  

- Conducting our business in a culture of honesty and opposition to fraud and corruption; 

- Maintaining high moral, ethical and social standards in our business and activities;  

- Maintaining proper business relationships with all individuals, including government officials and   employees. We implement this policy throughout the firm and are committed to the following code: 

1. We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

 • torture, cruel, inhumane and degrading treatment; • forced or compulsory labour; • the worst forms of child labour; • human rights violations and abuses; • war crimes, violations of international humanitarian law, crimes against humanity or genocide.

 2. We will not deal with, and will immediately discontinue engagement with, upstream suppliers where we identify a reasonable risk that they are committing, or are sourcing from or linked to any party committing abuses described above.

 3. We will not tolerate support, direct or indirect, to non-state armed groups, including but not limited to:  procuring precious metals from making payments to or otherwise providing assistance or equipment to non-state armed groups or their affiliates who illegally control mine sites, transportation routes, points where precious metals are traded and upstream participants in the supply chain and/or tax or extort money or precious metals at mine sites, along transportation routes or at points where they are traded, or from intermediaries, export companies or international traders. 

4. We will not deal with, and will immediately discontinue a relationship with, upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as described above. 

5. We maintain that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide support, may it be direct or indirect, to public or private security forces that commit abuses or act illegally as described above. 

6. We will not attempt to  improperly influence  others or offer, promise, give or demand bribes or kickbacks in any form. We will resist their solicitation, and will not permit Company funds, assets or property to be used to benefit any individuals, including government officials, customers, contractors and suppliers illegally or in ways that violate this policy. 

7. We do not and will not change the origin of precious metals, or accept fraudulent  payments of taxes, fees and royalties paid to governments for the purposes of extraction trade, handling, transport and export of gold.  

8. We support efforts and contribute to the effective elimination of money laundering where we identify a reasonable risk of money laundering resulting from, or connected to, the extraction, trade handling, transport or export of precious metals. We require our employees, agents, consultants, and business partners to comply with this policy, and will enforce it with appropriate disciplinary measures, up to and including termination of employment or contracts. 

CONTACT INFORMATION:  If you have any questions or concerns regarding this policy, or its implementation please contact:  ceo@sironaltd.com.

 March, 2018

 Issued by  SIRONA 

Introduction and Scope 

As  a responsible  company, because of products and services offered by  SIRONA  there is a risk that our products and services  might be used to launder money and finance terrorism.  International and Kenyan law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. 

We do this not only to protect the reputation of our company , but rather to protect ourselves, Customers, Partners,  and associates, and  to comply with relevant laws and to be a responsible corporate citizen. 

Failure to do so  is not an acceptable nor a tolerated possibility;  such failure comes with significant penalties, including legal and regulatory action. Our policy sets out how  SIRONA complies with its legislative obligations. 

This applies to all business divisions and employees (permanent, temporary and third-party providers) working for  SIRONA  in KENYA and  Worldwide.

 Definitions :

Money laundering is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the financial system. Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime. 

Terrorism financing differs from money laundering in 3 main ways: Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin, It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption. Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.  Our Customer Identification  (KYC) procedures comply with all INTERNATIONAL requirements , KENYAN Law , American law ,  and European AML regulations. b Before receiving any of our designated services, customers will be required to provide proof of identity or similar documentation.  SIRONA is required to collect and verify this information, depending on the type of customer.  Personal:  an individual person of any nationality, a  sole trader - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business;   Domestic company: a company, incorporated  anywhere in the world , including proprietary, public and listed public companies, or a foreign company incorporated outside KENYA;  Partnership:  a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit;  Trust:  a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company;  Association:  a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated;  Registered co-operative: a legal entity owned and controlled by the people for whom it was established and who benefit from using its services;  Government body:  this can be a domestic or foreign government body. Please note that SIRONA  complies with the National Privacy Principles and SIRONA code of obligations.  We act on  ‘suspicion’ -  are not obligated to validate;  however, we must have reasonable grounds to believe ML/TF activity may be occurring. To support this, employees receive training in identifying and reporting suspicious matters.  

Our  principles 1. Comply with AML/CTF legislation in the countries we operate in. 

2. Always  fulfill international standards as detailed in the jurisdiction in which we operate.  

3. Work in conjunction with the KENYAN  Government and the governments of the countries in which we operate, as well as  support their objectives in relation to the prevention, detection and control of ML/TF. 

4. SIRONA  may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate  responsibility. 

5. Maintain and comply with an AML/CTF program, as required by SIRONA and  Kenyan/international AML/CTF legislation. Policy Roles and Responsibilities.  SIRONAS , Directors and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviors.  SIRONA  AML/CTF Program:  The design and implementation of this program was tailored to our ML/TF risk profile, applying specific systems and controls, including: • ML/TF risk assessment, • Employee training, • Employee and customer due diligence, • Transaction monitoring.  Monitoring and Reporting:  We also may report the following information to either  SIRONA or any regulator whose purpose is to assist in the prevention of and the fight against Money laundering in relation with the Kenyan  Government Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector. 

For any further question please contact our Management Team at : ceo@sironaltd.com 

For our KYC form or any other forms including a copy of our policies and procedures please email us at  :Isaac@sironaltd.com