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Financial Crimes Policy

Thinking4Media Limited

Financial Crime Policy – Employee Guide

1. Why this policy exists

Thinking4Media is committed to doing business honestly and responsibly. Financial crime harms our clients, our reputation, and our people. This guide explains what we expect from everyone who works with us.

2. What counts as financial crime

Financial crime includes:

  • Fraud

  • Bribery or corruption

  • Money laundering

  • Tax evasion

  • Sanctions breaches

  • Theft or misuse of company funds

If something feels dishonest or “not quite right,” treat it as a red flag.

3. Your responsibilities

Everyone at Thinking4Media must:

  • Act with integrity

  • Follow our financial processes

  • Be honest in all client and supplier dealings

  • Report anything suspicious immediately

  • Complete required training

You don’t need to be an expert — just stay alert and speak up if unsure.

4. Working with clients and suppliers

Before we start working with a new client or supplier, we may need to check:

  • Who they are

  • What they do

  • Whether they pose any financial or reputational risk

If something feels unusual (e.g., odd payment instructions, unclear ownership), raise it with your manager.

5. Gifts, Hospitality & Entertainment

We work in a creative industry where relationship‑building is normal — but we must avoid anything that could look like bribery or improper influence.

Giving Gifts or Hospitality

You may offer reasonable, proportionate gifts or hospitality only when:

  • It is for legitimate business purposes

  • It is not intended to influence a decision

  • It is modest in value

  • It is approved and recorded according to company procedures

Lavish or frequent gifts are not allowed.

Receiving Gifts or Hospitality

You may accept gifts or hospitality only when:

  • It is modest and appropriate

  • It does not create a sense of obligation

  • It is not cash or cash‑equivalent (e.g., vouchers)

  • It is declared and approved

If you’re unsure, ask your manager before accepting.

Always Decline

  • Cash or vouchers

  • Expensive items

  • Anything offered during a tender, pitch, or negotiation

  • Anything that feels uncomfortable or “too much”

When in doubt, check first.

6. Spotting suspicious activity

Tell your manager or the Compliance Lead if you notice:

  • Unusual payment requests

  • Pressure to skip normal processes

  • Requests to pay third parties not named in the contract

  • Clients unwilling to provide basic information

  • Anything that feels dishonest

There is no penalty for raising a concern in good faith.

7. Reporting concerns

You can report concerns to:

  • Your line manager

  • The Managing Director

  • The whistleblowing channel

We do not tolerate retaliation against anyone who speaks up.

8. Consequences

Breaking this policy may lead to:

  • Disciplinary action

  • Ending your employment or contract

  • Reporting to authorities

9. Annual review

This policy is reviewed every year to keep it up to date with laws and industry standards.

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