Compliance Policies and Procedures

Skinny Wrists Ltd trading as Metal Clay

 

1. Purpose and Scope

Skinny Wrists Ltd trading as Metal Clay is committed to conducting its business lawfully, responsibly and transparently.

These Compliance Policies and Procedures set out the company's approach to managing regulatory, financial and operational compliance risks and the procedures followed by directors and employees in the course of normal business activities.

The company's compliance framework is proportionate to the nature and size of the business and covers key areas including:

• Customer and supplier payments

• Supplier verification and due diligence

• International payments and foreign exchange

• Anti-money laundering and financial crime awareness

• Fraud prevention

• Financial sanctions

• Record keeping

• Import and international trade documentation

• Escalation of unusual or suspicious activity

These procedures should be read alongside the company's Anti-Money Laundering (AML) Policy and any other applicable internal policies.

2. Management Responsibility

Overall responsibility for company compliance rests with the directors of Skinny Wrists Ltd.

Responsible person: Jemma Woods
Position: Director

The responsible person oversees the company's compliance procedures and is responsible for ensuring that significant compliance concerns are appropriately reviewed, investigated and addressed.

3. General Compliance Policy

Skinny Wrists Ltd seeks to:

• Conduct business in accordance with applicable UK laws and regulations.

• Maintain accurate and appropriate business and financial records.

• Deal with legitimate customers, suppliers and business partners.

• Maintain appropriate controls over company payments.

• Take reasonable measures to prevent fraud, money laundering and other financial crime.

• Comply with applicable UK financial sanctions.

• Maintain appropriate records relating to international purchases and payments.

• Escalate and investigate unusual or suspicious activity where appropriate.

The company's procedures are reviewed periodically and updated where there are significant changes to the business or applicable regulatory requirements.

4. Supplier Verification

Skinny Wrists Ltd purchases products, tools, equipment and supplies from UK and international manufacturers, distributors and suppliers.

Before establishing a significant new supplier relationship, the company takes reasonable steps to establish that the supplier is a legitimate business.

Depending upon the supplier and nature of the relationship, these checks may include:

• Reviewing company or trading information

• Confirming business contact details

• Reviewing the supplier's website and commercial presence

• Reviewing invoices, quotations or purchase documentation

• Checking company registration details where appropriate

• Confirming bank and payment details

• Maintaining correspondence relating to the commercial relationship

The extent of the checks undertaken will be proportionate to the nature, value and risk of the relationship.

5. Supplier Payments

Supplier payments must relate to legitimate company expenditure.

Supporting documentation should normally be available for significant supplier payments, such as an invoice, purchase order, statement or other commercial documentation.

Payments should normally be made to a bank account held in the name of the supplier or contracting business.

Requests for payment to an unrelated third party or an unexpected bank account should be investigated and independently verified before payment is made.

Changes to established supplier bank details should also be verified before payment.

6. International Payments and Foreign Exchange

The company purchases products and supplies from international manufacturers and suppliers and therefore has a legitimate requirement to purchase foreign currency and make international payments.

Foreign-exchange transactions should relate to genuine business expenditure, principally the payment of supplier invoices and associated business costs.

Where appropriate, the company maintains supporting records demonstrating the commercial purpose of international payments.

The company does not knowingly use its business accounts or foreign-exchange facilities to:

• Transfer money on behalf of unrelated third parties

• Facilitate personal transactions unrelated to the business

• Conceal the origin or destination of funds

• Circumvent financial or regulatory controls

Funds used for foreign-exchange transactions are derived from legitimate company funds and business activities.

7. Bank Account and Payment Controls

Company payments are made through approved company bank accounts, payment providers and authorised foreign-exchange providers.

Access to company banking and payment facilities is restricted to authorised individuals.

Significant, unusual or unexpected payments should be reviewed before being authorised.

Bank statements and financial transactions are subject to the company's normal bookkeeping and accounting procedures.

8. Fraud Prevention

Employees and directors should remain alert to potential fraud, including:

• Unexpected changes to supplier bank details

• Requests for payment to unrelated third parties

• Unusual payment instructions

• Suspicious emails requesting payments

• Impersonation of suppliers or company personnel

• Unusual customer payment or refund requests

Where there is uncertainty regarding payment instructions, the details should be independently verified using established contact information before funds are transferred.

9. Refund Procedures

Where reasonably possible, customer refunds should be returned to the original payment method.

Requests to refund payments to a different person, unrelated third party, alternative bank account or substantially different payment method should be investigated before being authorised.

10. Financial Sanctions

Skinny Wrists Ltd will comply with applicable UK financial sanctions requirements.

Where a transaction, customer, supplier, destination or payment raises a potential sanctions concern, appropriate checks should be undertaken before proceeding.

The company will not knowingly make funds or economic resources available where doing so would breach applicable UK financial sanctions.

11. Anti-Money Laundering

The company maintains a separate Anti-Money Laundering Policy.

Skinny Wrists Ltd does not accept cash payments.

Employees and directors should nevertheless remain alert to unusual payment behaviour, unexplained third-party payments and other activity that could indicate financial crime.

Any concerns should be escalated to the person responsible for compliance.

12. Customer and Supplier Information

Information collected about customers and suppliers should be limited to information reasonably required for legitimate business, contractual, accounting, legal or compliance purposes.

Business information and personal data should be handled appropriately and access restricted where necessary.

13. Record Keeping

The company maintains appropriate records relating to its business activities.

Depending upon the transaction, these may include:

• Customer orders

• Sales invoices

• Supplier invoices

• Purchase orders

• Bank and payment records

• Foreign-exchange transaction records

• Shipping and import documentation

• Supplier correspondence

• Accounting records

Records are maintained in accordance with applicable UK legal, tax, accounting and business requirements.

14. Import and International Trade Documentation

Where products are imported into the United Kingdom, the company seeks to maintain appropriate commercial and customs documentation.

This may include supplier invoices, shipping documents, customs documentation, commodity information and evidence of payments.

The company seeks to provide accurate information to customs authorities, freight providers and other parties involved in the importation process.

15. Escalation of Compliance Concerns

Employees should raise any unusual or potentially suspicious activity with the responsible person.

Where necessary, a transaction may be delayed while additional information or verification is obtained.

The responsible person will determine whether further investigation, professional advice or reporting to an appropriate authority is necessary.

16. Staff Awareness

Relevant employees are expected to understand the procedures applicable to their roles.

This includes awareness of:

• Approved payment procedures

• Supplier verification

• Fraud prevention

• International payment controls

• The company's no-cash policy

• Escalation of unusual or suspicious activity

Compliance procedures will be communicated to relevant employees and updated where necessary.

17. Review

These procedures will be reviewed at least annually and sooner if there is a significant change to:

• The nature or scale of the business

• Payment methods

• International trading activities

• Supplier arrangements

• Relevant legislation or regulatory requirements

Approved by: Jemma Woods
Position: Director
Date approved: 04/08/2026

Signature: J. Woods