| 1. |
VASPs shall implement and provide an anti-bribery and corruption training programme for the Board and all Staff on a regular basis and monitor their compliance with all established procedures. All members of the Board and Staff must participate in all such trainings provided by the VASP. |
| 2. |
VASPs shall ensure that all members of the Board and Staff to have full access at all times to the most up-to-date anti-bribery and corruption policy and will be informed of any changes to such policy. |
| 3. |
Training on the anti-bribery and corruption policy should form part of the induction programme made available to all new Board members and Staff. |
| 4. |
In addition to relevant requirements in the Market Conduct Rulebook, a zero-tolerance approach to bribery and corruption and all relevant policies must be disclosed by all VASPs to the public and communicated at the outset of all business relationships as appropriate.
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