Contractor Terms and Conditions

These Contractor Terms and Conditions (“Contract”) is entered into by Project Recruit US Inc (“PRUS”), 16192 Coastal Highway, Lewes, Delaware 19958, USA and the individual or Limited Company stated in the associated SOW, hereinafter the “Contractor”.

 

THIS CONTRACT is made on the date as stated in the associated SOW.

DEFINITIONS

Assignment”                                                                       means the assignment specified in the SOW

 

“Client”                                                                                as for whom the final services will be received as                                                                                                         detailed in the SOW

“Contract”                                                                           the contractual agreement between both parties                                                                                                        formed by the signing of the SOW associated (via the                                                                                                  hyperlink in the SOW) with these terms and conditions

“Contractor”                                                                        Limited Company or Self-Employed individual

 

“Services”                                                                           services agreed to be provided by the Contractor to PRUS

“SOW(s)”                                                                             (Statement of Works) means the purchase order or such                                                                                               other document issued by PRUS to the Contractor                                                                                                       confirming the Contractor’s Assignment with the Client                                                                                                 including the details which are set out in the SOW. The                                                                                               SOW is associated with these terms via a hyperlink                                                                                                      specified in the SOW

“Day(s)”                                                                               a working day not including national or bank holidays or                                                                                            weekends (U.S. federal holidays will be used as the                                                                                                      reference for national holidays, unless otherwise specified                                                                                            in the SOW).

IT IS HEREBY AGREED as follows:

1. Orders

1.1 All orders placed by PRUS for the Contractor will be confirmed with a SOW setting out the full details of the services governed by these Terms and Conditions. SOW’s can be in the form of email, text or electronic signature application from a PRUS employee.

1.2 The Contractor agrees to accept email as a method by which PRUS can communicate business requirements and services. All communication using this method will be sent to the email address supplied by the Contractor at registration.

 

2. Relationship

Relationship between Contractor and Project Recruit

2.1 PRUS will engage the services of the Contractor on a demand basis only. This will result in work being carried out over a variety of working hours or days depending on the specific requirements of the SOW.

2.2 Contractor will not at any time be deemed as, or treated as, employee of PRUS or any client of PRUS. Neither PRUS nor the Contractor will consider their partnership as “exclusive” and as such will not enjoy a preferred status.

2.3 It is understood that the Contractor will be self-employed or a Limited company. Accordingly, PRUS will not at any time be liable for any local employment taxation or National Insurance (or similar local equivalent) liabilities arising on the Contractor as a result of completing any work for PRUS pursuant to these terms and conditions.

Reporting Relationship

2.4 The Contractor may coordinate directly with the Client for deliverables, but commercial terms must be confirmed through PRUS in writing Stories and correspondence will be submitted by the Contractor directly to the Client.

3. Expenses

3.1 Refer to the SOW or any Expense Policy referenced therein Accurate expense claims must be submitted before month end for payment in the proceeding month

4. Contractor’s Warranty and Indemnity

4.1 The Contractor is aware that PRUS’s mission is to provide “Service with Integrity and Professionalism” and agrees to obtain knowledge of and comply with all PRUS’ procedures and work instructions, which form part of its commitment to provide the highest levels of quality and service to customers.

4.2 The Contractor shall indemnify and keep PRUS indemnified against:

a) Any claims made against PRUS by any third party (including for the avoidance of doubt any Client of PRUS or any person engaged by that client) relating to the order set out in the SOW including, without limitation, all costs, damages, fees, judgment, expenses, and liability whatsoever incurred by PRUS in relation to any such claim.

b) All actions, proceedings, costs, claims, demands, awards, fines, orders, and liabilities whatsoever arising in connection with the Contractor’s provision of service pursuant to the SOW.

5. Payment Terms

5.1 The Contractor will invoice PRUS or use PRUS self-invoicing system PEP, upon completion of services. Payment of a valid invoice will be made within 14 days from the Friday of the week in which the invoice is approved for payment.

a) Where a Timesheet is required it must match the Contractor invoice for any authorized and accepted work as set out in the SOW.

5.2 PRUS shall be entitled to withhold or reduce any payment due to the Contractor in relation to the following:

a) Any liability arising directly or indirectly from the Contractor’s breach of any provision of these terms and conditions of business as notified in writing by PRUS to the Contractor;

b) Any damages suffered by PRUS and notified to the Contractor in writing pursuant to clause 3 of these terms and conditions of business;

c) The Contractors acknowledgment (whether by credit note, verbal or written confirmation) that PRUS are entitled to withhold or reduce a payment;

d) Any instance where PRUS shall be required to make a payment to a third party as a result of the Contractor’s breach of these terms and conditions of business.

5.3 Invoices submitted by the contractor after 60 days of completion of a project will not be paid by PRUS.

6. Price

6.1 The price at which subcontracted services are agreed between the parties, are contained in the SOW.

7. Termination

7.1 Either party giving the other party in writing the period of notice specified in the SOW may terminate an Assignment. Either party may terminate this Agreement and any active SOW(s) by providing the greater of 30 days or as required under local law notice to the other party.

7.2 Notwithstanding sub-clauses 7.1 and 7.5 of this Contract, where required by the Client, PRUS may without notice and without liability instruct the Contractor to cease work on any assignments at any time, where:

a) The Contractor has acted in breach of the rules, regulations, and policies applicable to the Client’s own staff that are applicable to independent contractors;

b) The Client reasonably believes that the Contractor has not observed any condition of confidentiality applicable to the Contractor from time to time;

c) The Contractor becomes insolvent, dissolved, or subject to a winding up petition;

d) For any reason, the Contractor proves unsatisfactory to the Client.

7.3 Failure by the Contractor to give notice of termination as required in the SOW shall constitute a breach of contract and shall entitle PRUS to claim damages for the length of the breached notice period from the Contractor for any resulting loss suffered by PRUS.

7.4 If the Contractor is unable for any reason to provide services for an Assignment, the Contractor should inform PRUS by no later than 8.00am on the first day of absence to enable alternative arrangements to be made.

7.5 The Contractor acknowledges that the continuation of an Assignment is subject to and conditioned by the continuation of the contract entered into between PRUS and the Client. In the event that the contract between PRUS and the Client is terminated for any reason, the Assignment shall cease with immediate effect without liability to PRUS.

8. Complete Agreement

8.1 This agreement is the entire agreement between the parties and any special terms and conditions are as specified in the SOW. All changes hereto are to be in writing and agreed between the parties.

8.2 If any provision of these terms and conditions of business is held by any Court or other competent authority to be invalid or unenforceable in whole or in part, the validity of the other provisions of these terms and conditions of business and the remainder of the provision in question should not be affected.

9. Confidentiality

9.1 By entering into this contract, the Contractor may from time to time be made aware of confidential information. All Confidential Information shall comply with U.S. privacy laws including CCPA and state equivalents.

9.2 PRUS regards the following categories of information as examples of material that would be considered as confidential:

a) Client lists or individual names

b) Pricing and rates structure

c) Supplier agreements

d) Technical developments

e) Employee records and financial records

f) Written content produced by the Contractor for any Client

g) Instructions from Clients or PRUS to the Contractor

The above list is a guide and is not intended to be exhaustive.

9.3 As a condition of this contract, the Contractor will not, during the continuance of this contract, nor after the termination thereof, disclose or in any way make use of or benefit from any of the confidential knowledge, financial or other information including but not limited to the information referred to in paragraph 9.2, or any other products or systems of PRUS, its parent, or associated companies or any other organisation or individual with whom their work brings them into contact.

9.4 All notes, memoranda or any other material whatsoever relating to the business of PRUS shall remain the property of PRUS and shall together with any copies be returned to PRUS on demand and in the event of the termination of this contract.

Contractor shall comply with U.S. data protection and privacy laws and ensure secure handling of personal data. PRUSPRUS

10. Non-Waiver

10.1 A waiver by PRUS of a breach of a provision of these terms and conditions of business should not be considered as a waiver of a subsequent breach of the same or another provision;

10.2 The rights to terminate these terms and conditions of business given by clause 8 shall not prejudice any other right or remedy of PRUS in respect of the breach concerned or any other breach;

10.3 On termination of these terms and conditions of business for any reason, subject as otherwise provided in these terms and conditions of business and to any rights or obligations which have accrued prior to termination, neither party shall have any further obligation to the other under these terms and conditions of business.

11. Personal Liability / Insurance Cover

11.1 PRUS will not provide to the Contractor, any insurance cover such as professional indemnity, public liability, travel, medical or personal accident insurance.

11.2 Contractor shall take out and maintain and shall ensure that its Personnel take out and maintain, adequate professional indemnity and public liability insurance and workers’ compensation where required by law, with a reputable insurance company against such liability. Contractor and Personnel shall, on request, promptly show PRUS such policies of insurance, the premium receipts and insurance certificates. Where possible, the Contractor shall notify its insurers of its interest on its insurance policies.

11.3 The risks to be covered are as follows:

a) not less than $1,000,000 or equivalent local currency for loss sustained by reason of death or personal injury by the Contractor or Personnel or any third party whilst performing the services required under this contract;

b) not less than $1,000,000 or equivalent local currency for any claims by any third party for which PRUS or the customer may become liable as a result of any act or omission of Contractor in providing the services required under this Agreement, including any claim which PRUS or the customer may have directly or indirectly, in respect of the performance of such services.

11.4 The Contractor shall (and shall procure that all Personnel shall) comply with all reasonable standards of health and safety and comply with the Client’s health and safety procedures in force at the premises where the Services are carried out and ensure that Personnel shall report to the Contractor any unsafe working practices, which the Contractor will then be obliged to address, provided that the Contractor informs and consults PRUS before contacting the Client about such an issue.

11.5 The Contractor shall have liability for and shall indemnify PRUS for all and any loss, liability, costs (including reasonable legal costs), damages or expenses arising from any negligent or reckless act, omission, or default in respect of the provision of the Services by the Contractor, its Personnel and/or any Substitute engaged pursuant to this Agreement.

12. Status and Tax Liability

12.1 Contractor acknowledges that it is engaged as an independent entity. Contractor controls methods, schedule, and tools and may serve other clients. Contractor acknowledges, and shall procure that its Personnel acknowledge, that nothing in this Agreement shall constitute or suggest a relationship of an employee, agent, director, or partner of PRUS and/or Client; and Contractor and Personnel are therefore not eligible for the benefits provided by PRUS or Client.

12.2 This agreement constitutes a contract for the provision of services and not a contract of employment and accordingly the Contractor shall be fully responsible for and shall indemnify PRUS for and in respect of:

a) Any income tax, national insurance, and social security contributions (local equivalent) and any other liability, deduction, contribution, assessment or claim arising from or made in connection with either the performance of the Services or any payment or benefit received by the Individual in respect of the Services, where such recovery is not prohibited by law. The Contractor shall further indemnify PRUS against all reasonable costs, expenses and any penalty, fine or interest incurred or payable by PRUS in connection with or in consequence of any such liability, deduction, contribution, assessment or claim;

b) Any liability arising from any employment-related claim or any claim based on worker status (including reasonable costs and expenses) brought by the Individual or any Substitute against PRUS arising out of or in connection with the provision of the Services.

12.3 PRUS may at its option satisfy such indemnity (in whole or in part) by way of deduction from payments due to the Contractor.

12.4 Neither Contractor nor any Personnel have authority to, and Contractor shall not, and shall ensure that none of its Personnel shall, make any representations or incur any liability or enter into any contracts or arrangements involving either PRUS or Client in any financial or other commitments.

12.5 This Agreement does not appoint Contractor or Personnel as agent of either PRUS or Client, nor does it create any partnership or joint venture or in any manner operate to create any obligation on PRUS or Client in respect of any liability of Contractor or Personnel.

12.6 Contractor shall indemnify PRUS and/or Client in respect of any claims that may be made against either of them by any person, firm, company, or government agency relating to the provision of Services by Contractor under this Agreement.

12.7 This Agreement shall not constitute a contract of employment for any purposes whatsoever, and Contractor will be solely responsible for National Insurance contributions for any Personnel, and for all or any taxes payable in respect of fees and reimbursements paid under this Agreement and will indemnify PRUS and/or Client in respect of any claims that may be made against either of them by the relevant authorities.

12.8 During the continuance of this Agreement, Contractor shall, and shall procure that its Personnel shall (unless prevented by accident or ill-health) devote such of its time, attention, and abilities to the business of PRUS as may be necessary for the proper provision of its Services as Contractor or Personnel. However, this will not prevent Contractor or Personnel from acting in a similar or any other capacity for any other person, firm, or corporation (but subject to the confidentiality and restriction clauses in this Agreement).

12.9 Contractor shall not, and shall procure that none of its Personnel shall, make any recommendations to a Client which would benefit or involve any third party in which the Contractor or Personnel or any person connected with either of them has a financial interest or material interest, unless it has fully disclosed such interest to PRUS and the Client and PRUS gives its written consent. All contractual protections granted to or reserved in this Agreement by PRUS, including warranties, limitation of liabilities, remedies, indemnification, and confidentiality, shall accrue to and are for the benefit of Client. 

12.10 Nothing in this Agreement limits any mandatory rights under the laws of the state in which the Services are performed. This Agreement and any dispute or claim (including any non-contractual dispute or claim) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the laws of the State of New York, United States of America, without regard to its conflict-of-law principles.

12.11 Each party irrevocably agrees that the courts of New York shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Contract or its subject matter or formation.

SCHEDULE 1

CRIMINAL BACKGROUND DISCLOSURE / CONFIDENTIALITY / DATA PRIVACY NOTICE

 

To be completed by all Contractor Personnel who will access client data or premises

Project Recruit US Inc.

Criminal Background Disclosure

Project Recruit US Inc. (“PRUS”) and its clients are committed to maintaining a safe and secure working environment.
If your assignment involves access to client facilities, systems, or sensitive data, a background check may be required in accordance with applicable federal and state laws (including the Fair Credit Reporting Act and relevant state privacy laws).

You are not required to disclose information about arrests or convictions that have been sealed, expunged, or otherwise legally removed from your record. However, you must truthfully disclose any other convictions or pending criminal charges if requested by PRUS or the client as part of a lawful background check.

Please note that no background screening will be conducted until after a conditional offer or engagement discussion has taken place, and only with your express written consent.

Do you have any criminal convictions that have not been sealed or expunged?
☐ Yes ☐ No

If yes, please provide details on the associated Statement of Work (SOW) or in a confidential attachment.

 

Confidentiality

As a contractor or supplier to PRUS, I agree that I will:

    • Keep confidential all information related to work results, intellectual property, or the business and affairs of PRUS, its clients, or any affiliated companies (“Confidential Information”).
    • Use Confidential Information solely for the purpose of performing services for PRUS or its clients.
    • Promptly execute any assignments or confidentiality undertakings required by PRUS or its clients regarding intellectual property created during the engagement.
    • Not remove, copy, or transmit any materials containing Confidential Information from client premises or systems without written permission.
    • Upon request, return or permanently delete all materials belonging to PRUS or its clients that contain Confidential Information.

This confidentiality obligation applies both during and after the engagement and survives the termination of any contract.

 

Data Privacy Notice

Project Recruit US Inc. complies with the California Consumer Privacy Act (CCPA), the Fair Credit Reporting Act (FCRA), and other applicable US privacy laws. Personal information collected during the engagement process may include contact details, identification information, background check results, tax information (e.g., IRS Form W-9), and other data necessary to engage and manage contractors.

We are committed to ensuring that personal data is accurate, relevant, securely stored, and used only for lawful business purposes.
You have the right, where applicable, to request access to, correction of, or deletion of your personal information, and to know how it is shared or disclosed.

By signing below, you consent to PRUS contacting you by email, phone, text, or other means for engagement management, compliance updates, and payment communications.

 

Disclosure Consent

I hereby give my express consent for Project Recruit US Inc. and/or its clients to:

(a) Verify the information I have provided, including conducting background and reference checks as permitted by law;
(b) Retain copies of any background check or screening results consistent with legal record-keeping requirements; and
(c) Disclose relevant information from my personnel or engagement file to authorized employees or clients where necessary for legitimate business or compliance purposes.

 

SCHEDULE 2

STANDARDS AND SAFEGUARDS

To be completed by all Contractor Personnel who will access client data or premises

 

Quality Charter

To provide the best service to you and our clients we require everyone who works with us to agree to the following conditions:

    • Represent yourself and PRUS in a courteous and professional manner;
    • Respect your colleagues and delegates irrespective of sex, age, color, religion, creed, disability or marital status, in accordance with our equal opportunities policy;
    • At all times respect the client’s rules, regulations, and policies applicable to independent contractors;
    • Honor the terms and conditions of your contract;
    • Inform us of any disputes or issues as soon as possible.

 

Policy Statement on Equal Opportunities

Diversity and Equal Opportunity is about those human qualities that are different from our own and outside the groups to which we belong. Diversity not only includes race, ethnicity, and gender, but also ability/disability, education, age, class, and many other differences.

PRUS is committed to a policy of equal opportunities for all. We do not discriminate on grounds of race, color, creed, ethnic or national origin or on grounds of sex, marital status, disability, or age.

It is the specific responsibility of all representatives of PRUS, to ensure that this policy is fully implemented, and they are aware of their responsibilities and the legal obligations that fall upon them and upon this company. All representatives of PRUS will comply with the legislation relating to sex and race discrimination. Discrimination against any person on the grounds of their ethnic origin, their sex or marital status will be regarded as serious misconduct and may result in dismissal.

 

Company Property and Copyright

All written material, whether held on paper, electronically or magnetically which was made or acquired by you during the course of your contract with us, is the property of our Client and, where appropriate, either the Client’s or our copyright. At the time of termination of your contract with us, or at any other time upon demand, you shall return to us any such material in your possession.

Any work produced and submitted by you to the Client shall be the property of the Client.  Any work produced and submitted by you to the Client is work made for hire under applicable copyright laws, specially commissioned by Client.  Any contribution you make to the work and all rights, title, and interest in the copyright thereon shall be the sole and exclusive property of the Client and shall be copyrighted solely in the name of the Client. To the extent that the work is not considered a work for hire, you assign to the Client the ownership of such work, including but not limited to, all copyright and intellectual property rights. These rights include, but are not limited to, the sole and exclusive right to print, publish, sell, copy, distribute, and license others to use the work in any form or medium, now, or hereafter existing, or in any language, during the full term of the copyright therein and throughout the world.

 

Password Protection

Passwords are an important aspect of computer security. A poorly chosen password may result in unauthorized access and/or exploitation of a company’s resources. All Contractors with access to company systems are responsible for taking appropriate steps to select and secure their passwords. Passwords must not be shared with anyone. All passwords are to be treated as sensitive, confidential information.

 

Monitoring

We reserve the right to monitor all email/IM and Internet activity on the PRUS or client network by you for the purposes of ensuring compliance with our policies and procedures and of ensuring compliance with the relevant regulatory requirements, and you hereby consent to such monitoring. Information acquired through such monitoring may be used as evidence in disciplinary proceedings.

 

Use of Social Networking Sites

Any work-related issue or material that could identify an individual who is a client or work colleague, which could adversely affect the Company, a client, or our relationship with any client, must not be placed on a social networking site. This means that work-related matters must not be placed on any such site at any time either during or outside of working hours and includes access via any computer equipment or mobile device.

 

SCHEDULE 3

ANTI-BRIBERY / WHISTLE BLOWERS POLICY AND PERSONAL HARRASSMENT POLICY

To be completed by all Contractor Personnel who will access client data or premises

 

ANTI-BRIBERY POLICY  

Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us, and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by associates or by third parties acting for or on behalf of the Company.

 

Policy

It is prohibited, directly or indirectly, for any associate or person working on our behalf to offer, give, request or accept any bribe, i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

 

Suspicion

If we suspect that you have committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may result in the cessation of our business arrangement with you.

 

Reporting

If you, as an associate or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to your PRUS contact. You may be asked to give a written account of events.

 

Gifts and Hospitality

We realize that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly. As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.

 

WHISTLE BLOWERS POLICY

Under certain circumstances, associates are protected from suffering any detriment or termination of employment if they make disclosures about organizations for whom they work.

 

Qualifying Disclosures

1. Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the associate genuinely and reasonably believes is in the public interest and shows that the Company has committed a “relevant failure” by:

    • committing a criminal offence;
    • failing to comply with a legal obligation;
    • a miscarriage of justice;
    • endangering the health and safety of an individual;
    • environmental damage; or
    • concealing any information relating to the above.

2. These acts can be in the past, present, or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. The Company will take any concerns that you may raise relating to the above matters very seriously.

3. We encourage you to use the procedure if you are concerned about any wrongdoing at work. However, if the procedure has been invoked for malicious reasons or in pursuit of a personal grudge, then you will be liable to immediate termination of contract or such lesser disciplinary sanction as may be appropriate in the circumstances.

 

The Procedure

1. In the first instance, you should report any concerns you may have to your Account Manager or a Company Director who will treat the matter with complete confidence. If you are not satisfied with the explanation or reason given to you, you should raise the matter with the appropriate official organization or regulatory body.

2. If you do not report your concerns to your Account Manager or a Company Director you should take them direct to the appropriate organization or body.

 

Treatment by others               

Bullying, harassment, or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

 

PERSONAL HARRASSMENT POLICY

    • Harassment or victimization on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation is unacceptable.
    • Personal harassment takes many forms ranging from tasteless jokes and abusive remarks to pestering for sexual favors, threatening behavior, and actual physical abuse. Whatever form it takes, personal harassment is always taken seriously and is unacceptable in the workplace.
    • We recognize that personal harassment can exist in the workplace, as well as outside, and that this can seriously affect associates’ working lives by interfering with their job performance or by creating a stressful, intimidating and unpleasant working environment.

 

Policy

    • We deplore all forms of personal harassment and seek to ensure that the working environment is sympathetic to all our associates.
    • We have published these procedures to inform associates of the type of behavior that is unacceptable and provide associates who are the victims of personal harassment with a means of redress.
    • We recognize that we have a duty to implement this policy and all associates are expected to comply with it.

 

Examples of Personal Harassment

Personal harassment takes many forms, and associates may not always realize that their behavior constitutes as harassment. Personal harassment is unwanted behavior by one associate towards another and examples of harassment include:

    • insensitive jokes and pranks;
    • lewd or abusive comments about appearance;
    • deliberate exclusion from conversations;
    • displaying abusive or offensive writing or material;
    • unwelcome touching; and
    • abusive, threatening, or insulting words or behavior.

These examples are not exhaustive and disciplinary action at the appropriate level will be taken against associates committing any form of personal harassment.

 

SCHEDULE 4

ANTI-MONEY LAUNDERING POLICY AND PROCEDURES

To be completed by all Contractor Personnel who will access client data or premises

These are the Anti-Money Laundering (AML) Policy and Procedures adopted by Project Recruit US Inc. (PRUS) in compliance with the Bank Secrecy Act (31 U.S.C. § 5311 et seq.), the USA PATRIOT Act, and all applicable regulations and guidance issued by the Financial Crimes Enforcement Network (FinCEN). PRUS is committed to actively preventing, detecting, and reporting any suspected money-laundering, terrorist-financing, or other financial-crime activities, and to implementing reasonable internal controls to ensure the business is not used to facilitate or conceal unlawful conduct.

To these ends:

    • The identities of all new and existing Contractors will be verified to a reasonable level of certainty
    • A risk-based approach will be taken to the monitoring of Contractor’s tax and accounting affairs
    • Any suspicious activity will be reported, and all AML activities recorded

AML Procedures

1. CUSTOMER DUE DILIGENCE

The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing Contractors are verified to a reasonable level of certainty. This will include all individual clients, all directors and shareholders with a stake holding of 25% or more of client companies, all partners of client partnerships, and every board member of client charities. Identities will be verified either online or face-to face or by a combination of both.

The following documentation may be presented by the individual:

In person

    • Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.
    • An original recent utility bill, or government issued document with the same and address matching those provided by the individual.

Not in person

As in person but additionally:

    • Any government issued document that provides the date of birth, Social Security or Tax number or other such government identifier.
      • Other forms of identity confirmation, such as evidence of a long-standing relationship with the client, or a letter of assurance from independent and reliable persons or organizations, who have dealt with the client for some time, may also provide a reasonable level of certainty.

If the business fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.

 

2. RISK ASSESSMENT AND ONGOING MONITORING

The business shall take a risk-based approach in monitoring the financial activities of its clients. This will be carried out whilst preparing the accounts or tax returns or conducting any other business with the client.  The business will actively not accept high-risk clients that are identified as follows:

    • Clients with businesses that handle large amount of cash (i.e., involving $15,000 or more, or the sterling equivalent) or complex unusually large transactions.
    • Clients with larger one-off transactions, or a number of transactions carried out by the same customer within a short space of time.
    • Clients with complex business ownership structures with the potential to conceal underlying beneficiaries.
    • Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime, or drug production/distribution.
    • Situations where the source of funds cannot be easily verified.
    • Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
    • Money sent to or received from areas known to have high levels of criminality or terrorist activity.

The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date, or information held evidencing the customer’s identity are kept up to date.

The following are examples of changes in a client’s situation that may be considered suspicious:

    • A sudden increase in business from an existing customer;
    • Uncharacteristic transactions which are not in keeping with the customer’s known activities;
    • Peaks of activity at particular locations or at particular times;
    • Unfamiliar or untypical types of customer or transaction.

Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners. No action need be taken if there is no cause for suspicion.


3. MONITORING AND MANAGING COMPLIANCE

    • Project Recruit US Inc. (“PRUS”) will regularly monitor its anti-money-laundering (“AML”) controls to ensure they are implemented and maintained in accordance with this Policy and all applicable U.S. laws and regulations.
      Compliance oversight will include the following procedures:
    • Client identification and verification (Know-Your-Customer / Customer Identification Program requirements);
    • Detection and internal reporting of suspicious transactions or activities; and
    • Record-keeping and retention consistent with Bank Secrecy Act requirements

PRUS will also monitor changes in relevant FinCEN rules, the Bank Secrecy Act, the USA PATRIOT Act, and any other applicable federal or state regulations.
The AML Policy and related procedures will be updated promptly whenever necessary to maintain full regulatory compliance.

 

4. SUSPICIOUS ACTIVITY REPORTING

When PRUS knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal activity or is intended to disguise such funds, evade reporting requirements, or finance terrorism, PRUS will file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) in accordance with 31 C.F.R. § 1022.320 (or other applicable provisions).

The designated AML Compliance Officer is responsible for determining whether a SAR filing is warranted and for ensuring timely submission through the BSA E-Filing System.

PRUS will cooperate fully with law-enforcement and regulatory authorities as required by law.
(Information about FinCEN and SAR filing is available at https://www.fincen.gov.)

RECORD-KEEPING

PRUS will maintain all records required under the Bank Secrecy Act for a minimum of five (5) years from the later of (a) the termination of the business relationship, or (b) the completion date of the transaction.
This includes:

    • Customer identification and verification documentation;
    • Transaction records; and
    • Copies of any SARs and supporting documentation filed with FinCEN.

All AML-related records will be handled confidentially, stored securely, and retrievable without undue delay upon request by regulatory or law-enforcement authorities.


(Last Updated: 17th October 2025.)