It is the policy of Materion Advanced Materials Technologies and Services Inc. and its subsidiaries (Company) to prohibit and actively prevent money laundering and the funding of terrorist or criminal activities. We define money laundering as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.
Our policy has been developed in conformance with the requirements of rules promulgated by the U.S. Department of Treasury, Financial Crimes Enforcement Network, 31 CFR Part 103, Section 120.140c, under the Bank Secrecy Act. Our policy is based on four principles which are embodied in our Anti-Money Laundering (AML) Program (the program):
- Establish policies, procedures and internal controls based on our assessment of the risks associated with our business activities
- Appoint an AML Committee, led by an AML Compliance Officer who is responsible for ensuring that (i) the program is effectively implemented; (2) the program is updated as necessary to reflect changes in risk to the business unit, current requirements of applicable regulations and further guidance provided by the U.S. Department of Treasury; and (iii) appropriate staff are trained in the program and related procedures.
- Conduct independent testing to ensure the program is functioning as designed.
- Encourage all employees to report suspicious activity to the AML Compliance Officer
For more information regarding Materion’s AML Program and related procedures, email the AML Compliance Officer at [email protected].
