12. The Associated Person or third-party requests cheques to be made out to “bearer” or “cash” or seeks payment by other anonymous or unusual means of payment (such as barter transactions) or requests payments to be made outside of the usual process or accounting structure. 13. The Associated Person or third party wants to work without a contract (or vague contract) or refuses to confirm that they will abide by the Anti-Bribery Laws or disclose their identity. 14. The Associated Person asks for commissions that are substantially higher than the “going rate” in that country among comparable service providers or an Associated Person who is on commissions brings in an unusually high volume of business. 15. A potential government customer or authorizing agency recommends a specific partner or intermediary. - 17 -
Abc policy Page 16