Ethical Policy

AML-CFT & ETHICAL CONDUCT POLICY


Entity: Alesya de Monaco Ltd.

Brand: ADM Club

Company Number: 15370330 (England & Wales)

Registered Office: The Engine Room, Battersea Power Station, 18 Circus Road Street, London, SW11 8BZ, United Kingdom

VAT Number: 469 0469 56

Website: https://adm.club


1. This policy affirms the company’s commitment to legal compliance, human dignity, and integrity in all high-value transactions, especially those involving art, collectibles, and cultural assets.

2. No activity may begin on the platform before onboarding and verification are completed.

3. All transactions must be conducted via traceable banking channels (cash and cryptocurrency are strictly prohibited)

4. We will endeavour to monitor for anomalies, suspicious behaviour, and potential abuse

5. Data is stored within GDPR-compliant environments in the UK or EEA

6. Alesya de Monaco Ltd. is committed to upholding the highest ethical standards across all operations.

7. We will always try to ensure that:

a. All forms of forced, bonded, or child labour are strictly prohibited

b. Our partners, makers, and dealers must provide fair wages, safe working conditions, and non-discriminatory environments

c. Diversity, dignity, and human rights are respected at every level of the ADM ecosystem

d. Non-compliance may result in immediate suspension or termination of the relationship, and if appropriate, escalation to authorities

8. This ethical stance is not only a legal duty but a cornerstone of the ADM Club’s identity and responsibility to the global cultural and luxury landscape.

9. This policy is reviewed:

a. Annually, and

b. Immediately, upon material legal or regulatory change.

10. The current version is available upon request.