Mantera Trust Capital KB
BOX 1739 - 116 74 STOCKHOLM
Authorised Activity: Trust and Foundation Management and activities related therewith
Cash Deposits (No Currency Restrictions)
Any type of Securities including structured products
Investments in General
Gifts, entertainment or other commercially promotional activities;
Payment or reimbursement of expenses to an employee;
Offers of employment or other benefits to a family member or friend of the
Contributions from political parties and candidates;
Charitable contributions and sponsorships.
Other less obvious elements provided to a public official may also violate anti-corruption laws. Examples include in-kind contributions, investment opportunities, stock options or positions in joint ventures and favourable or directed subcontracts. The prohibition applies regardless of whether an item directly benefits the agent or another person, such as a family member, friend or business associate.
Under the law, Mantera and the individual officer(s) or employee(s) may be held liable for undue payments made by an agent or other intermediary if they know or have reason to know that a bribe will be paid. Deliberate ignorance, including failure to conduct a reasonable investigation in the event of suspicious circumstances, is not a defence and it is irrelevant whether the intermediary is itself subject to anti-bribery laws. All employees should therefore be alert to potential "red flags" in transactions with third parties. Mantera and its subsidiaries must maintain accurate books and records that reflect transactions and asset disposals in reasonable detail, supported by an appropriate system of internal accounting controls and our software Ebanq. These requirements are implemented through Mantera's standard accounting rules and procedures that all personnel are required to follow without exception. Particular attention is paid to transactions that may involve payments to local or foreign government officials. Off-book accounts should never be used. Facilitation or other payments to government officials shall be promptly reported and properly recorded as to purpose, amount and other relevant factors. Requests for false invoices or payment of unusual, excessive or inadequately described expenses must be rejected and reported promptly. Misleading, incomplete or false entries in the books and records of Mantera are never acceptable.
Mantera has established detailed procedures for the selection, appointment
and monitoring of agents, consultants and other third parties. These rules
and procedures must be followed in all cases, paying particular attention to
"red flags" that may indicate possible legal or ethical violations.
Due diligence typically includes appropriate reference and background
checks, written contractual provisions that confirm a business partner's
responsibilities, and appropriate follow-up controls. Personnel working with
agents and other third parties may indicate possible legal or ethical issues,
commonly referred to as "red flags. The presence of red flags in a
relationship or transaction generally requires the prior approval of an
appropriate senior officer, a description of the nature and extent of services
provided in a written contract, and appropriate contractual safeguards
against potential violations of law or company policy.
This policy imposes specific responsibilities and obligations on all company
personnel, which will be implemented through standard disciplinary
measures and will be given due consideration by staff.- All employees and agents are responsible for understanding and complying
with the policy in the course of their work. Every employee has an obligation
to do so:
Know the applicable aspects of the policy and communicate them to
Ask questions if the policy or the actions to be taken in a particular situation
are not clear enough;
Be alert to indications or evidence of possible wrongdoing;
Properly manage and control the business activities of third parties;
Promptly report violations or suspected violations through appropriate
Any employee who has reason to believe that a violation of this policy has been or may be committed, must promptly inform his or her supervisor, the next level of supervision or the Mantera compliance officer. Information will always be communicated on a confidential basis.
Retaliation in any form against an employee who has, in good faith, reported a violation or possible violation of this policy is strictly prohibited. Employees who violate this policy will be subject to disciplinary action up to and including termination of employment. Violations may also result in prosecution by law enforcement authorities and severe criminal and civil penalties. PRIVACY
When you interact with our Website, we may collect the following categories of personal information. Information You Provide to Us Registration and Your Information. If you want to use certain features of the Website, you will have to create an account (“Account”) using your email address. You may also receive an invitation to proceed with the registration via the email used to register an account.
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable law.
CHANGES TO OUR PRIVACY NOTICE We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.