DUE DILIGENCE POLICY

OVERVIEW

This Due Diligence Policy (hereinafter referred to as” Policy”) is effective from [INSERT DATE ON WHICH THE POLICY COMES INTO FORCE] and applies to all the Employees of the [INSERT COMPANY NAME] (hereinafter referred to as “Us” or “We” or “Company”).

This Policy outlines set guidelines and procedures for assessing and managing risks associated with financial transactions and clients. This policy establishes a comprehensive framework for the systematic and effective management of financial integrity and risk mitigation, ensuring adherence to regulatory standards, fostering ethical conduct, and maintaining the trust and confidence of clients.

1. PURPOSE
   1. The purpose of this policy is to provide clear and structured guidelines for the management of financial transactions at [INSERT COMPANY NAME].The Policy emphasizes accurate verification of vendor’s invoices, prompt resolution of discrepancies, adherence to payment terms and recordkeeping. It also addresses fraud preventive measures and compliance with legal regulations. By prioritizing accuracy, efficiency and transparency, this policy aims to ensure the timely and secure handling of business invoices while promoting financial control and fraud prevention within the organization.
2. SCOPE
   1. This policy applies to all our employees, contractors, vendors or any individual involved in company’s financial activities and accounts management.
3. CUSTOMER DUE DILIGENCE(CDD)
   1. Company will conduct CDD procedures, to assess and manage risks associated with our customers. Our Company will identify all customers before establishing a business relationship or conducting any transactions with the customers. This includes individuals, legal entities, and beneficial owners.
   2. Company will verify the identity of customers using reliable and independent sources of information, which may include government-issued identification documents, official databases, or other trusted sources.
   3. Company will continuously monitor customer transactions and activities to ensure they align with their established profiles and business relationships. Any discrepancies or unusual patterns will be investigated promptly.
   4. All CDD documentation, including customer identification records and verification results, will be maintained securely and retained as per regulatory requirements
4. ENHANCED DUE DILIGENCE (EDD)
   1. Company will conduct enhanced due diligence, using a risk based approach to address events with a high possibility of money laundering, fraud or other major financial crimes.
   2. Company will conduct a more detailed and thorough investigations during EDD, requiring additional documentation including site visits, third-party verification and enhanced transaction monitoring.
5. RISK ASSESSMENT
   1. Company will conduct potential risk assessments to identify and evaluate the risks that could impact the Company’s financial and operational activities.
   2. Company will analyze and document all the risks associated within and outside the Company and will take necessary steps to mitigate those risks.
   3. Company will ensure that all risk assessments align with applicable financial regulations and industry standards.
   4. Company will conduct monitoring mechanisms to track the effective implementation of risk mitigation strategies.
   5. Employees are expected to protect all valuable and sensitive company data, including personal and financial information from threats and data loss.
6. ONGOING MONITORING
   1. Company will periodically review Client’s information and financial activities to ensure it remains current and accurate.
   2. Our Company will implement periodic assessments of customer risk profiles based on evolving business transactions and activities.
7. REPORTING SUSPICIOUS ACTIVIES
   1. All Employees have a responsibility to promptly report any suspicious activities they encounter or become aware of during the course of their duties, to the Company.
   2. Company will investigate the reported activity to determine if they warrant further action, including filing suspicious activity with the appropriate authorities.
   3. All Suspicious Activity reports and related information will be kept confidential to the extent required by law and used solely for the required purposes.
   4. Company will take reasonable measures to protect employees involved in reporting suspicious activities from potential threats or retaliation.
8. RECORD-KEEPING
   1. All information collected during and CDD and EDD, including customer identification records and monitoring records will be maintained securely and retained in accordance with regulatory requirements.
   2. Confidential information should only be collected for specific, legitimate purposes and should not be used or disclosed for other purposes without obtaining consent, unless required by law.
   3. Access to personal information during CDD and EDD should be restricted to authorized personnel on a need-to-know basis.
9. CONFIDENTIALITY, INFORMATION SECURITY, PROPRIETARY INFORMATION AND INTELLECTUAL PROPERTY
   1. We are committed to business information confidentiality, integrity and accessibility, we implement proper technical security measures this and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorized parties. All members must handle any such information as secret. It also covers that, no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have impact on the securities. Every rule ensuring information security must be followed all times.
   2. Employees must maintain the confidentiality of the company and information. Sharing sensitive information with unauthorized individuals is strictly prohibited.
10. TRAINING AND AWARENESS
    1. We will develop training and awareness programs to educate employees, contractors, and other individuals on due diligence procedures, regulatory requirements and the importance of accurate assessments.
11. COMPLIANCE
    1. Compliance with this policy and applicable anti-money laundering and financial laws should be regularly monitored and audited to identify and address any potential gaps or non-compliance.
    2. Any identified breaches or non-compliance should be promptly investigated and appropriate corrective actions will be taken.
12. CHANGES TO THE POLICY
    1. We reserve to right to update and make changes to this policy from time to time based on the working conditions of the Company. The Company on updating this policy will inform the members of the Company.
13. FURTHER INFORMATION
    1. For any queries or further Information regarding our Company or about this Policy, the concerned person can contact us through email[INSERT EMAIL ADDRESS OF THE COMPANY].
14. ACKNOWLEGEMENT
    1. We expect all employees to adhere to this policy of the Company. The Company will apply this policy consistently and fairly to ensure a harmonious and productive workplace for all.
    2. By signing below, you acknowledge that you have carefully read and understood the terms and contents of this policy.

COMPANY                  

Authorized Signature

Print Name and Title

[INSERT SIGNING AUTHORITY AND DESIGNATION]