Anti-Money Laundering & Financial Crime Awareness
Last updated: 20/01/2026
Purpose
Wellbeing Places Equip Limited ("WBP Equip") is committed to conducting its business with integrity and to preventing the misuse of its operations for financial crime.
This Statement sets out the Company's awareness-based approach to anti-money laundering ("AML"), fraud, bribery, corruption, and related financial crime risks, in a manner proportionate to its activities and risk profile.
Proportionate Approach
WBP Equip is not a regulated financial institution and does not provide financial services.
However, the Company recognises that all businesses have a responsibility to remain alert to the risk of financial crime, particularly in relation to:
- investment and funding arrangements;
- supplier and partner relationships;
- misuse of company funds or assets; and
- reputational and legal risk arising from improper conduct.
Accordingly, the Company applies proportionate measures to promote awareness, oversight, and escalation.
Risk Awareness
WBP Equip's governance framework includes consideration of financial crime risk alongside other operational and ethical risks. Areas of awareness include:
- the source and use of funds received by the Company;
- the identity and credibility of investors, counterparties, and suppliers;
- unusual, unexplained, or inconsistent payment arrangements; and
- conflicts of interest or inducements that could compromise decision-making.
Governance and Oversight
Responsibility for oversight of financial crime awareness sits with the Company's Board as part of its wider governance and risk framework. The Board is responsible for:
- setting expectations regarding ethical conduct and financial integrity;
- ensuring appropriate controls and reporting arrangements exist; and
- responding appropriately to concerns or identified risks.
Third-Party and Transactional Considerations
Where the Company engages with investors, advisers, suppliers, or other third parties, it seeks to apply reasonable and proportionate consideration to:
- the nature of the relationship;
- the purpose of payments or transfers; and
- any indicators of elevated risk.
This approach is intended to support sound decision-making rather than to replicate formal AML regimes applicable to regulated sectors.
Escalation and Reporting
WBP Equip encourages the prompt escalation of concerns relating to suspected fraud, financial crime, or improper conduct.
Concerns may be raised through the Company's governance or whistleblowing arrangements and will be reviewed appropriately.
The Company does not tolerate retaliation against individuals who raise concerns in good faith.
Relationship with Other Policies
This Statement should be read alongside:
- the Governance & Compliance Statement;
- the Supplier & Independent Assurance Statement; and
- the Whistleblowing & Speaking Up Policy.
Together, these documents reflect the Company's commitment to ethical conduct and responsible governance.
Transparency and Limitations
This Statement provides a high-level overview of the Company's approach to AML and financial crime awareness.
For commercial, security, and confidentiality reasons, detailed internal controls, checks, or procedures are not disclosed publicly.
Review
This Anti-Money Laundering & Financial Crime Awareness Statement is reviewed periodically to ensure it remains appropriate to the Company's activities and risk profile.
All revisions must be approved by the Board and recorded in the Policy Register.