ERAM Real Estate operates under formal governance and a complete compliance framework. The policies below sit on top of internal operating procedures available on request to auditors, regulators, banks and prospective institutional counterparties under non-disclosure.
Anti-Money Laundering and Counter-Terrorist Financing. Risk-based approach, CDD, EDD, suspicious activity reporting, MLRO, training, record-keeping.
Read policyCompliance with UN, EU, OFAC, UK and Kosovo sanctions. Continuous screening at onboarding and on existing relationships. Restricted-jurisdictions framework.
Read policyKnow Your Customer and Customer Due Diligence. Identification and verification of investors, beneficial owners and customers. Risk classification and review frequency.
Read policyZero-tolerance commitment. Facilitation payments prohibited. Gifts and hospitality framework. Third-party due diligence.
Read policyIdentification, disclosure and management of conflicts. Related-party transactions across the Kelmendi Holdings group on arm's-length terms.
Read policyThe standards of behaviour expected of every director, employee, contractor and partner. Integrity, respect for people, safety, speaking up.
Read policyConfidential channel for reporting suspected wrongdoing. Anonymous reports accepted. Strict prohibition of retaliation.
Read policyZero tolerance for forced labour, human trafficking and child labour in our operations and supply chain.
Read policyPrincipal risks of co-investing through the ERAM Investors Portal. Orientation document — read the full project Information Memorandum before subscribing. Capital is at risk.
Read policyHow to raise a complaint, our timelines for acknowledgement, investigation and outcome, and the escalation options available to you.
Read policyHow we collect, use and protect personal data, aligned with the Kosovo Law on Personal Data Protection and EU GDPR principles.
Read policyInvestor-specific data handling: KYC categories, legal bases, sub-processors, retention, rights and security.
Read policyCookies and similar technologies used on the website, how to manage them, and our approach to consent.
Read policyISO 27001-aligned principles, GDPR-aligned breach response procedure, and incident reporting channels.
Read policyFull compliance, no aggressive planning, arm's-length pricing for intra-group transactions, transparent engagement with the Tax Administration of Kosovo.
Read policyWCAG 2.1 Level AA conformance target, measures in place, known limitations, and feedback channels.
Read policyMinimum standards every supplier of goods or services must meet. Includes the explicit safeguards that apply when a Kelmendi Holdings group affiliate is engaged as a supplier — written disclosure, benchmarked pricing, Investment Committee approval, right of audit.
Read policyConstruction-specific extension of the Supplier Code. Addresses the engagement of KST Institute, Contech Group, APIS and Virtual Era as group affiliates with full related-party safeguards, FIDIC-style framework, site-level safety and anti-corruption controls.
Read policyThe public policy statements on this page sit on top of detailed internal operating procedures — AML procedure manual, sanctions screening procedures, KYC operating procedures, MLRO reporting tree, risk register, training records, board and committee charters, and document-retention schedules. Auditors, regulators, banks, and prospective institutional investors may request the full manual under non-disclosure.
Request the procedures manual