In the event that a potential sanctions match or ethical concern is identified during the screening process, Iguality follows a structured procedure to ensure that all risks are properly assessed and addressed before proceeding with any engagement.
Immediate Actions
- Suspension of engagement: Any transaction, contract, or collaboration involving the potential match is temporarily paused until the issue is fully investigated.
- Notification: The Director and President are informed immediately to oversee the assessment and determine the next steps.
Investigation and Due Diligence
- Conduct a thorough review to confirm whether the match is accurate and whether the individual or entity poses legal, ethical, or reputational risk.
- Consult additional reliable sources if necessary, including official lists, public records, and relevant third-party references.
- Document all findings in detail, including the sources consulted, the rationale for conclusions, and any recommendations.
Decision-Making
- For routine engagements with minor potential concerns, the Director and President may approve, reject, or request additional safeguards.
- For high-value, high-risk, or sensitive engagements, the case is escalated to the Board of Directors for review and final approval.
Documentation and Follow-Up
- All decisions and actions related to potential matches are formally recorded and stored securely for audit purposes.
- Corrective measures or risk mitigation actions are implemented as required, and ongoing monitoring of the entity is performed if engagement proceeds under specific safeguards.
This structured approach ensures that Iguality does not engage with individuals or entities that are subject to sanctions or pose significant legal or ethical risks, while maintaining transparency, accountability, and compliance with applicable laws and organizational values.