Anti-Money Laundering (AML) Policy

Introduction

EasyB Srl, operating in the pharmaceutical sector through the LS Academy brand, recognizes the critical importance of preventing and combating money laundering and terrorism financing, in compliance with Italian regulations (including Farmindustria requirements) and European standards. This policy reflects our commitment to financial integrity, transparency, and the protection of our industry from illicit activities.

Scope of Application

This policy applies to all employees, collaborators, business partners, customers, and suppliers involved in EasyB’s operations, both in Italy and abroad, with particular attention to the specificities of the pharmaceutical sector.

Key Principles

  1. Legal Compliance and Sectoral Regulations: EasyB strictly adheres to Italian and European laws, including the Farmindustria Guidelines, Legislative Decree 231/2007 and subsequent amendments, as well as the recommendations of the Financial Action Task Force (FATF).
  2. Enhanced Due Diligence: We maintain a rigorous focus on clients, partners, and suppliers, paying particular attention to risks associated with transactions in the pharmaceutical sector and the supply chain.
  3. Transaction Monitoring: Advanced control systems are employed to monitor financial and operational transactions, detecting signs of potential money laundering or illicit behavior.

Responsibilities and Roles

  • Sole Director: Ultimately responsible for AML compliance and for fostering a corporate culture based on integrity.
  • Employees: Must immediately report suspicious activities to the Sole Director and participate in mandatory training.
  • Suppliers and Partners: Must adhere to EasyB’s ethical standards as a condition of the business relationship.

Key Procedures

  1. Identification and Verification of Customers and Partners:
    • Verification of the identity of customers and business partners.
    • Collection and assessment of information regarding reputation, corporate structure, and ultimate beneficiaries.
  2. Risk Assessment:
    • Specific risk analysis related to pharmaceutical sector clients and international financial flows.
  3. Reporting:
    • Any suspicious activities must be promptly reported to the competent authorities (e.g., the Financial Intelligence Unit - FIU) in compliance with Italian regulations.
    • Timely communications to Farmindustria in cases of significant discrepancies or suspicions regarding operations linked to the pharmaceutical supply chain.
  4. Specific Training:
    • Mandatory and periodic training programs for all personnel on AML regulations and risk detection practices.

Disciplinary Measures

Any intentional violation or negligence concerning the AML policy will result in severe disciplinary actions, up to and including termination of employment or contractual relationships, and may involve reporting to the competent authorities.

Monitoring and Review

The AML policy will be reviewed annually or in the event of regulatory updates to ensure continued alignment with national laws, Farmindustria guidelines, and international best practices.

Adoption

This policy has been approved by EasyB’s Management and is binding for all personnel and partners. It represents a cornerstone of our corporate ethics and our commitment to transparency in the pharmaceutical sector.