1. Introduction and Commitment

A & C Christofi Ltd (“ACC CY,” “we,” “us,” or “our”) is unwavering in our commitment to maintaining the highest standards of professional ethics, integrity, and regulatory compliance across all our accounting, auditing, tax, and advisory services. This Statement formalizes our dedication to ethical excellence and regulatory adherence, ensuring we meet both professional standards and client expectations globally.

1.1. Scope and Applicability

This Statement applies to all directors, officers, employees, contractors, trainees, and any other individuals acting on behalf of A & C Christofi Ltd. It extends to all services, business activities, jurisdictions in which we operate, and all client engagements conducted through our offices, digital platforms, and associated entities.

2. Adherence to Global Professional Standards

2.1. Comprehensive Professional Framework

We operate under and fully comply with:

• Institute of Certified Public Accountants of Cyprus (ICPAC): All applicable standards, guidelines, and ethical requirements
• International Financial Reporting Standards (IFRS): For financial reporting and accounting services
• International Standards on Auditing (ISA): For audit and assurance engagements
• International Ethics Standards Board for Accountants (IESBA): Code of Ethics for Professional Conduct
• International Standards on Quality Management (ISQM 1 and ISQM 2): For service quality and consistency

2.2. Continuous Professional Excellence

We ensure ongoing professional competence through:

• Mandatory Continuous Professional Development (CPD): Minimum annual requirements for all professional staff
• Technical Training Programmes: Regular updates on accounting, auditing, and regulatory developments
• Specialized Certifications: Maintenance and enhancement of professional credentials
• Knowledge Management System: Systematic dissemination of technical updates, regulatory updates and best practices
• Performance and Competence Monitoring: Regular assessment of professional performance, competence and development needs

2.3. Regulatory Registration and Licensing

A & C Christofi Ltd is duly licensed and regulated by the Institute of Certified Public Accountants of Cyprus (ICPAC) and complies fully with all regulatory obligations applicable to licensed audit and accounting firms, including licensing conditions, ongoing monitoring requirements, ethical requirements and regulatory inspections.

2.4. Cross-Border Professional Compliance

Where services are provided across multiple jurisdictions, we ensure compliance with all applicable local laws, regulatory frameworks, reporting obligations, and professional standards in each relevant jurisdiction. Conflicts between local requirements and international professional standards are addressed through formal internal escalation risk-assessment procedures.

3. Integrity and Professional Conduct Framework

3.1. Fundamental Ethical Principles

We uphold and demonstrate commitment to:

• Integrity: Honesty and straightforwardness in all professional and business relationships
• Objectivity: Impartiality and freedom from conflicts of interest in professional judgment
• Professional Competence and Due Care: Maintaining professional knowledge and skill at required levels
• Confidentiality: Respecting the confidentiality of information acquired through professional relationships
• Professional Behavior: Compliance with relevant laws, regulations professional standards and avoidance of discreditable conduct

3.2. Independence and Conflict Management

We maintain robust systems for:

• Independence Requirements: Strict adherence to independence standards for audit and assurance engagements
• Conflict Identification: Systematic procedures for identifying potential conflicts of interest
• Conflict Management Resolution: Clear protocols for addressing mitigating, managing, or resolving identified conflicts
• Disclosure Practices: Timely and transparent communication of circumstances that may affect objectivity
• Rotation Policies: Appropriate rotation of engagement team members as required by professional standards

3.3. Zero-Tolerance Ethical Policy

We maintain a strict zero-tolerance policy for unethical behavior, dishonesty, professional misconduct, non-compliance with applicable standards, or any actions that may jeopardize client trust, regulatory standing, or our professional reputation. Appropriate disciplinary measures are taken in cases of confirmed violations.

4. Confidentiality and Data Protection Excellence

4.1. Comprehensive Information Protection

We implement rigorous measures to protect client information, including:

• Legal and Regulatory Compliance: Adherence to the EU GDPR, Cyprus Data Protection Law 125(I)/2018, and other applicable data protection and privacy laws including UK GDPR (where relevant)
• International Standards: Implementation of global best practices in data protection
• Privacy by Design and by Default: Integration of privacy considerations into all business processes and information systems
• Regular Assessments: Ongoing privacy impact assessments and compliance audits

4.2. Advanced Information Security Measures

Our information security framework includes:

• Data Encryption: Advanced encryption for data in transit (TLS 1.3) and at rest (AES-256)
• Access Controls: Role-based access permissions and multi-factor authentication
• Network and System Security: Enterprise-grade firewalls, intrusion detection, and regular security updates
• Physical Security: Secure facilities with comprehensive access control systems
• Personnel Awareness and Training: Regular confidentiality and data protection awareness programs

4.3. Data Retention and Secure Destruction

Client information is retained only for the minimum periods required by applicable laws, regulatory obligations, and professional standards. Upon expiry of the applicable retention period, information data is securely destroyed using approved methods to ensure complete and irreversible disposal.

5. Anti-Money Laundering and Regulatory Compliance

5.1. Robust AML Framework

We maintain comprehensive anti-money laundering procedures in accordance with:

• Cyprus Legislation: Prevention and Suppression of Money Laundering Activities Laws
• EU Directives: Full compliance with EU Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Directives and Regulations
• International Standards: Adherence to global AML/CFT standards and best practices
• Regulatory Guidance: Implementation of guidance from relevant supervisory authorities

5.2. Client Due Diligence Excellence

Our enhanced due diligence procedures include:

• Client Identification: Thorough verification of client identity and beneficial ownership
• Risk Assessment and Profiling: Comprehensive risk profiling and ongoing monitoring
• Enhanced Due Diligence: Additional measures for higher-risk clients and relationships
• Record Keeping: Complete documentation in compliance with regulatory requirements
• Ongoing Monitoring: Continuous assessment of client relationships and transactions

5.3. Suspicious Activity Management

We maintain effective procedures for:

• Activity Monitoring: Systematic identification and assessment of unusual or potentially suspicious transactions
• Reporting Protocols: Timely reporting to the Cyprus Unit for Combating Money Laundering (MOKAS) and other relevant authorities as required
• Investigation Procedures: Thorough documentation and investigation of potential concerns (specifically those of AML/CFT)
• Staff Training: Comprehensive education on recognizing and reporting suspicious activities

5.4. Sanctions and Financial Crime Compliance

We comply with all applicable EU, UN, UK, and U.S. sanctions regimes besides financial crime obligations. We perform screening against relevant sanctions lists and maintain controls to prevent involvement in prohibited transactions, entities, or jurisdictions.

6. Professional Responsibility and Quality Assurance

6.1. Comprehensive Quality Management

Our Quality Management System (QMS) encompasses:

• Leadership and Governance: Strong tone at the top and ethical leadership
• Ethical and Independence Requirements: Strict compliance with independence and ethical standards
• Client and Engagement Acceptance: Rigorous evaluation of clients and engagement terms
• Resource Allocation: Appropriate assignment of qualified personnel and technological resources
• Engagement Performance: Consistent application of professional standards
• Monitoring and Remediation: Ongoing evaluation of engagement quality, and continuous improvement

6.2. Complaints and Grievance Procedures

We maintain transparent and effective procedures for:

• Complaint Reception: Multiple accessible channels for raising concerns
• Investigation Process: Thorough, objective, and timely investigation of all complaints
• Whistleblower Protection: Robust protections against retaliation for good faith reports
• Resolution Communication: Clear communication of outcomes and remedial actions
• Continuous Process Improvement: Learning from complaints to enhance our practices

6.3. Regulatory Engagement and Compliance

We are committed to:

• Transparent Cooperation: Open and cooperative engagement with regulatory authorities
• Timely Reporting: Compliance with all regulatory reporting requirements
• Guidance Implementation: Prompt implementation of regulatory guidance and requirements
• Professional Contribution: Active participation in professional standard-setting processes

7. Implementation and Oversight Framework

7.1. Governance Structure

Our ethics and compliance framework is supported by:

• Board Oversight: Regular reporting and accountability at the board level
• Compliance Committee: Designated committee with clear terms of reference
• Compliance Officers: Appointed officers with defined responsibilities and authority
• Independent Review: Regular independent assessment of the effectiveness of our compliance

7.2. Monitoring and Continuous Improvement

We conduct systematic:

• Internal Reviews: Regular compliance audits and control assessments
• External Assessments: Independent external reviews or inspections where appropriate
• Benchmarking: Comparison against industry best practices and standards
• Policy Updates: Continuous enhancement of policies and procedures
• Performance Measurement: Regular evaluation of compliance program effectiveness

8. Contact Information and Reporting Mechanisms

8.1. Designated Compliance Contacts

For ethics, compliance questions, or to report concerns:

Chief Compliance Officer
A & C Christofi Ltd
Email: compliance@acccyp.com
Telephone: +357 25 000000
Address: 37 Nicou and Despinas Pattichi Avenue, Evi Court, 3rd Floor, Offices 302–303, Limassol, CY-3071, Cyprus

8.2. Confidential Reporting Channels

We provide multiple secure reporting options:

• Direct Contact: Access to designated compliance officers
• Secure Portal: Encrypted online reporting platform
• Confidential Hotline: Dedicated telephone reporting line
• Written Submissions: Secure mail and email options
• External Ombudsman: Independent external reporting channel

8.3. Non-Retaliation Commitment

We guarantee absolute protection against retaliation for individuals who:

• Report concerns in good faith
• Participate in compliance investigations
• Exercise their rights under professional standards
• Raise questions about ethical practices

9. Policy Administration and Communication

9.1. Regular Review and Updates

This Statement is subject to:

• Annual Review: Comprehensive assessment by the compliance committee
• Regulatory Updates: Immediate updates for significant legal or regulatory changes
• Stakeholder Consultation: Engagement with relevant stakeholders for major revisions
• Version Control: Systematic documentation of all changes and updates

9.2. Communication and Training

We ensure a comprehensive understanding through:

• Staff Training: Mandatory ethics and compliance training for all employees
• Management Briefings: Regular updates for leadership on compliance matters
• Client Communication: Appropriate disclosure of our ethical framework to clients
• Public Availability: Access to this Statement through our public platforms

9.3. Implementation and Enforcement

We maintain:

• Clear Accountability: Defined responsibilities for implementation
• Performance Integration: Inclusion of ethical conduct in performance assessments
• Disciplinary Procedures: Consistent enforcement of compliance requirements
• Continuous Monitoring: Ongoing assessment of implementation effectiveness

This Professional Ethics & Regulatory Compliance Statement was formally adopted on October 11, 2024, and becomes effective December 1, 2025. It represents the comprehensive ethical and compliance framework for A & C Christofi Ltd and replaces all previous ethics and compliance statements. Replace +357 25 000000 with your official business telephone number before publication and implementation.