Luno (Luno Group Holdings Limited and any wholly owned subsidiaries) and its employees at all levels, including directors, officers, agency workers, seconded workers, volunteers, interns and agents (henceforth “Lunauts”), are committed to high standards of ethical behaviour and have a zero tolerance towards bribery and corruption. 

Compliance with all anti-bribery and corruption laws in all markets and jurisdictions in which Luno operates is therefore essential for us. These laws include the UK Bribery Act 2010 and the Criminal Finances Act 2017.

In order to comply with these requirements, Luno considers and understands the risk of bribery and corruption throughout its operations. Through risk and control assessments, all parts of the business must identify bribery and corruption risks and the controls that are applied to those risks. Monitoring of key risk indicators and an assurance program to test the ongoing effectiveness of the control environment is also applied.

Policies and Standards
Luno has established clear principles in our Anti-Bribery and Anti-Corruption Policy, which is applicable to all Lunauts across the business. Luno’s Anti-Bribery and Anti-Corruption compliance programme and policies are overseen by the Board and this policy incorporates the results of regular risk assessments and emphasises that all Lunauts, including the Board of Directors, must comply with the principles in this policies in the performance of their services for or on behalf of Luno.  We also expect that outsourcers and other companies providing services to Luno will adhere to equivalent standards.

Transparency in our dealings
Lunauts are committed to transparency in all its dealings. This includes transparency in managing actual, potential or perceived conflicts of interest, and transparency in our dealings with our customers. Transparency also extends to the way in which we manage relationships with people who are politically exposed, our recruitment and remuneration processes, and our dealings with regulators.

Knowing our partners
Lunauts must know who it is doing business with and who is conducting business on its behalf. All parts of the business must conduct appropriate due diligence prior to engaging contractors, making donations, entering into business relationships with, or acquiring other entities. Lunauts must ensure that gifts and entertainment, payments to vendors/contractors or payments for other goods and services are proportionate, appropriate and in line with market rates.

Communicating our commitment
Lunauts are required to comply with the Luno Group Policy on Anti-Bribery and Corruption. This commitment applies from the top down. These requirements must be adhered to by all staff and a breach of the policy constitutes misconduct and Lunauts may face disciplinary action, including termination of employment and/or legal action.

Training our people
Lunauts are required to undertake mandatory training on Anti-Bribery and Anti-Corruption control measures.

Whistleblowing
Lunauts are committed to maintaining an ethical work environment and embedding a culture of speaking up. Our Whistleblowing Hotline is available for any Lunauts, temporary staff, contractor, supplier or service provider to raise a concern relating to any suspicion or act of unethical behaviour, via a dedicated email address. Our Group's Anti-Bribery and Corruption Policy and procedures ensure that reports are treated appropriately and that the person raising the concern is protected. It reinforces the message from Luno’s senior management and Board that those making a disclosure can trust the matter will be dealt with honestly, professionally and confidentially. This Policy ensures that any person making a disclosure is not personally disadvantaged or discriminated against. Also, through ongoing internal communications and training, our people are regularly encouraged to report any suspicions or incidents of unethical behaviour and speak with their line manager should they have any concerns.

Notifying us of bribery, corruption or other unethical behaviour
Service providers, suppliers and their employees with information relating to any suspicion or act of unethical behaviour by Luno staff should report the issue to the Whistleblowing channel on this link.