AML Policy

Thomas Kelly Holdings Limited

Last updated: December 2025

1. Introduction

The Proceeds of Crime Act 2002 (POCA) and related UK legislation establish the framework for preventing money laundering and the financing of criminal or terrorist activity.

Thomas Kelly Holdings Limited is committed to conducting its business with integrity and transparency and to complying with all applicable anti-money laundering and counter-terrorist financing legislation. We take reasonable and proportionate steps to minimise the risk of money laundering by implementing appropriate policies, procedures, and controls.

This Anti-Money Laundering Policy sets out the principles and safeguards adopted by Thomas Kelly Holdings Limited to help identify, assess, and report suspected money laundering activity.

2. Scope of This Policy

This Policy applies to all employees, officers, and relevant representatives of Thomas Kelly Holdings Limited.

The objective of this Policy is to maintain high standards of professional conduct and to ensure compliance with applicable UK anti-money laundering laws and guidance, including reporting obligations where suspicious activity is identified.

3. Definition of Money Laundering

Money laundering is the process by which criminal property or proceeds derived from criminal activity are concealed, disguised, converted, transferred, or otherwise made to appear legitimate.

Under the Proceeds of Crime Act 2002, offences include:

• Concealing, disguising, converting, transferring, or removing criminal property
• Entering into arrangements that facilitate the acquisition, retention, use, or control of criminal property
• Acquiring, using, or possessing criminal property

These offences apply regardless of whether the underlying criminal activity occurred in the UK or abroad.

4. Responsibilities

Thomas Kelly Holdings Limited is committed to ensuring that its management and staff comply with all relevant legislation and guidance designed to prevent money laundering and the funding of criminal or terrorist activity.

Thomas Kelly Holdings Limited will:

• Take reasonable steps to verify the identity of clients and counterparties where appropriate
• Apply risk-based due diligence and Know Your Customer (KYC) procedures in accordance with applicable law
• Retain identification and verification records in line with statutory and regulatory requirements
• Provide appropriate training to relevant staff to ensure awareness of AML obligations and reporting procedures
• Maintain this Policy in line with evolving legal and regulatory standards
• Report suspicions of money laundering to the appropriate authorities where required

We seek at all times to protect our staff, our organisation, and our reputation from the risks associated with financial crime.

5. Risk Assessment

Thomas Kelly Holdings Limited operates on a structured, relationship-led basis and does not provide banking, accounting, or secretarial services.

We do not directly handle or process client funds, except for fees charged in respect of our own services where applicable.

Our AML approach is risk-based and proportionate, taking into account:

• The nature of our services
• The type of clients and counterparties involved
• Geographic and jurisdictional considerations
• The complexity and structure of transactions

6. Due Diligence and KYC Procedures

Where required by law or regulation, Thomas Kelly Holdings Limited will undertake appropriate due diligence to verify the identity of clients and counterparties.

This may include:

• Verification of identity using government-issued documentation
• Confirmation of residential or business address
• Assessment of source of funds or wealth
• Ongoing monitoring where appropriate

Relevant records will be retained in accordance with UK AML legislation and data protection requirements.

7. Reporting Suspicious Activity

All employees must remain vigilant for indicators of money laundering or related financial crime.

Any suspicion of money laundering must be reported promptly to the designated Money Laundering Reporting Officer (MLRO).

Employees must not disclose, or “tip off”, any individual that a suspicion has been raised or that a report has been made, as this may constitute a criminal offence.

8. Legal Obligations and Protection

Failure to report suspected money laundering activity may result in serious criminal penalties.

Thomas Kelly Holdings Limited supports and protects employees who raise genuine concerns in good faith and ensures that reports are handled confidentially and appropriately.

9. Data Protection

All personal data collected for AML and KYC purposes is processed in accordance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018.

10. Review of This Policy

This Policy is reviewed periodically to ensure it remains appropriate, effective, and aligned with current legal and regulatory requirements.