Rules of Engagement

TERMS AND CONDITION

Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

RELTANCE ON INFORMATION POSTED & DISCLAIMER

the material’s contained on our site are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such.

We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this site and to the fullest extent permitted by English law, we exclude all liability for loss or damages direct or indirect arising from use of this site.

INTELLECTUAL PROPERTY RIGHTS AND RESTRICTIONS ON USE

THE AFRIONE NETWORK grants to you a limited non-exclusive, non-transferable license to view, copy and print the material on this website (other than the design or layout of this website) for your non-commercial or personal use only. All copies that you make must retain all copyright and other notices that are on this website.

Our status and that of any identified contributors as the authors of material on our website must always be acknowledged. Except as provided in the previous sentence, you may not use, distribute, sell, modify, transmit, revise, reverse engineer, republish, post, or create derivative works (where applicable) of the trade-marks, trade names, logos, patent, information, software or other intellectual property, material or content in these ‘Terms of Use’, referred to (collectively, as the “content”) of this website without The AfriOne Network.’s prior written permission.

You acknowledge and agree that this website, its content including all software used on this website are the property of The AfriOne Network., its affiliates, or their respective service providers, suppliers, or licensors and you will not acquire any rights or licenses in or on this website or in its content. This website and its content are protected by copyright, both individually and as a collective work or compilation and by trade-mark law, patent law, and other applicable laws.

TRADEMARKS

The AfriOne Network, and other marks used on this website belong to The AfriOne Network. You are not permitted to use any of the trademarks displayed on this website (including without limitation those listed above) without the prior written consent of The AfriOne Network and all it product offering which includes, AfriOne Foundation, AfriOne Invest, AfriOne Radio etc. or the third party that owns the trademark.

YOUR AUTHORITY TO USE THIS WEBSITE

By using this website, you are representing to us that you have the power and authority to accept these Terms of Use and to enter into this agreement with us, that you are capable of assuming and do assume any risks related to the use of this website and its content, and that you understand and accept the terms, conditions, and risks relating to their use. If you are dissatisfied with this website or its content, your sole and exclusive remedy is to stop using it.

DISCLAIMERS AND EXCLUSION OF LTABILITY

The following provisions exclude or limit our liability for this website. They all apply only so far as the law allows. In particular, we do not exclude or limit any of our responsibilities under the Financial Services and Markets Act 2000 and the Financial Conduct Authority rules for the conduct of business. The content of this website is for information purposes only. The AfriOne Network has taken care in preparing the content of this website. However, except as set out below, The AfriOne Network and each of its affiliates, licensors, service providers, and suppliers shall not be liable for any inaccurate, delayed, or incomplete information, or any omission nor for any actions taken in reliance thereon. 

The information contained in this website provided by any third party, including without limitation, the information obtained through any link, has been supplied without verification by us. Neither The AfriOne Network nor any of its affiliates, licensors, service providers or suppliers makes or has made any recommendations or endorsements regarding the products, Investments, or services of any third party mentioned or referred to in this website. Please note that all third-party products, Investments, or services must be ordered or purchased directly from the third party. Commentary and other materials posted on our site are not intended to amount to advice on which reliance should be placed. This website could include technical or other inaccuracies or typographical errors and it is provided to you on an “as is” basis without warranties or representations of any kind. To the extent permitted by law The AfriOne Network , its affiliates, licensors, service providers, and suppliers expressly exclude all representations, guarantees, warranties, conditions, and terms of any kind, whether express or which might otherwise be implied by statute, common law, or equity [including without limitation, representations, guarantees, warranties, conditions or terms regarding accuracy, timeliness, completeness, non-infringement, satisfactory quality, merchantability, merchantable quality or fitness for any particular purpose or those arising by law, statute, usage of trade, or course of dealing. 

The AfriOne Network  and each of its affiliates, licensors, service providers, or suppliers to the fullest extent permitted by law also expressly exclude any liability for any direct, indirect, consequential, or special loss or damage incurred by any user in connection with our website or in connection with the use, inability to use or results with the use of our website or any websites linked to it and any materials posted on it including without limitation any liability for loss of income or revenue, loss of business, loss of profits or contracts, loss of anticipated savings, loss of data, loss of goodwill, damage to reputation, wasted management or office time and for any other loss or damage of any kind however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable. Nothing in these ‘Terms of Use’ shall operate to limit or exclude our liability for death or personal injury arising from our gross negligence nor any other liability which cannot be excluded or limited under applicable law. 

The AfriOne Network does not guarantee that access to and use of the website will be uninterrupted or error-free. From time to time The AfriOne Network may suspend or restrict access to the website in order to carry out repairs, maintenance or to introduce new facilities. The AfriOne Network reserves the right, in its sole discretion, to correct any errors or omissions in any portion of this website.

CHANGES TO TERMS OF USE

The AfriOne Network reserves the right to update and revise these ‘Terms of Use’ at any time without notice to you. You are bound by such updates and revisions so we encourage you to visit this page frequently to keep yourself updated. Your continued use of this website will mean that you agree to any changes.

ACCESSING OUR SITE

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period.

INTELLECTUAL PROPERTY RIGHTS

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organisation to material posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of materials on our site must always be acknowledged.

You must not use any part of the materials on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

OUR SITE CHANGES REGULARLY

We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

OUR LIABILITY

The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude:

All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.

Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:

loss of income or revenue;

loss of business;

loss of profits or contracts;

loss of anticipated savings;

loss of data;

loss of goodwill;

wasted management or office time; and

for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

INFORMATION ABOUT YOU AND YOUR VISITS TO OUR SITE

We process information about you in accordance with our privacy policy. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

VIRUSES, HACKING, AND OTHER OFFENSES

You must not misuse our website by knowingly introducing viruses, Trojans, worms, logic bombs, or other material which is malicious or technologically harmful. You must not attempt to gain unauthorized access to our website, the server on which our Website is stored, or any server, computer, or database connected to our website. You must not attack our website via a denial-of-service attack or a distributed denial-of-service attack. By breaching this provision, you will commit a criminal offense and we will report any such breach to the relevant law enforcement authorities and will cooperate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our website will cease immediately. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, or other technologically harmful material that may infect your computer equipment, computer programs, data, or other proprietary material due to your use of our Website or to your downloading of any material posted on it or on any website linked to it. This website (excluding linked sites) is controlled by The AfriOne Network from its offices. By accessing this website, you and The AfriOne Network agree that all matters relating to your access to, or use of, this website shall be governed by the statutes and laws of England and Wales, as applicable, without regard to the conflicts of laws principles thereof. You and The AfriOne Network also hereby submit to the exclusive jurisdiction and venue of the courts of England and Wales with respect to any and all matters arising in connection with these Terms of Use.

LINKS FROM OUR SITE

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. When accessing a site via our website we advise you check their terms of use and privacy policies to ensure compliance and determine how they may use your information.

JURISDICTION AND APPLICABLE LAW

The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our site.

These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales. This site is hosted, run and managed in London, United Kingdom.

WHO ARE WE?

Privacy Policy

This privacy policy sets out how The AfriOne Network Pty Ltd uses and protects any information that you give The AfriOne Network (A1) when you use its website or services. The AfriOne Network owns all it product under the company and its website and so all it terms, policy etc applies to every product and people. A1 may change this policy from time to time by updating this page. You should check regularly to ensure that you are happy with any change. Our registered office is at 2 Baanbreker Avenue, Helderkruin, Roodepoort, Johannesburg, South Africa and we are a company registered in South Africa under company number K2018597185.

INFORMATION THAT WE COLLECT

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. The personal data that we collect from you may include: contact information included in our membership forms, such as your name, job title, postal address, including your home address, business address, telephone number, mobile phone number, and email address; information collected from publicly available resources, integrity databases and credit agencies; if required by relevant laws or regulations, personal information such as: Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number); Passport details, driving licence and utility bills; Details of the services you request from us; Payment details, including credit/debit card numbers, security code numbers, and other related billing information; And other personal data regarding your preferences where it is relevant to the services that we provide.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect personal information about you in a number of circumstances, including when you apply to use any of our services, become our client, or contact us in person, by telephone, by email, or by post. In some circumstances, we collect personal data about you from a third-party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, an information or service provider, or from a publicly available record.

LAWFUL GROUNDS FOR THE PROCESSING OF PERSONAL DATA

Under the Data Protection Laws, we need a lawful basis to collect and use your personal data. The law allows for six lawful bases to process people’s personal data, and one of them allows personal data to be legally collected and used if it is necessary for a legitimate interest of the organisation – as long as it is fair and balanced and does not unduly impact the rights of individuals. Due to the nature of our business and the size of our database, it is not practical for us to ask every individual for his/her consent. We have assessed our interests in carrying out our business activities and we have carefully considered the impact the collection and use of personal data could potentially have on individuals’ rights. Our database contains mainly data about individuals solely in their business capacity, which is used for the purposes of our normal business activities. Such activities are unlikely to affect the fundamental rights and freedoms of individuals concerned. We have therefore concluded that the most appropriate lawful ground for the processing of your personal information is our legitimate interest in maintaining our business database, and promoting, running, and managing our business. A1 uses the legitimate interest’s legal basis for processing the type of data listed below: Email and other addresses for communicating with our members for the purpose of administering their membership with A1 Email addresses and telephone numbers to communicate with individuals who raise a membership inquiry on our website Use of email addresses to send newsletters and marketing material to members and other individuals who have recently interacted with A1 or used A1’s services on the basis that these categories of individuals would reasonably expect to receive this type of material. Any individual is able to object to receiving such material through the use of the unsubscribe facility contained in each email communication Individual names of attendees at conferences or events organised by A1 or held at A1 or its partners’ premises are used to create a list of delegates.

SHARING AND DISCLOSING YOUR PERSONAL INFORMATION

All information you provide to us is stored on our secure servers located in the United Kingdom. The data we collect may be transferred to and stored at, a destination outside the United Kingdom. It may also be processed by staff operating outside the United Kingdom who work for us or for one of our suppliers. We will take the necessary steps to ensure that your data is treated securely and that any such transfer outside the United Kingdom is in accordance with the Data Protection Laws. Keeping personal information secure is very important to us and we take appropriate precautions to protect against the loss, misuse, and alteration of personal information. However, no data transmission over the internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which is sent via the internet. We may disclose your personal information to any of our affiliated companies, to our suppliers, agents, or representatives, or to other users for the purposes associated with our legitimate interests (see above). We may also disclose your personal information to third parties where this is necessary for connection with the services we provide or our legitimate interests. If our services are provided in conjunction with, or by the involvement of third parties, such third parties may need to have your personal information in order to fulfill your request. We do not sell, trade, or rent personal information to third parties.

HOW LONG WE KEEP YOUR DATA

We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent. These retention periods vary depending on the location, type of data, product type and the extent of our interaction with you. 

We use the following criteria to determine the retention period: 
           Has the customer provided personal data with the expectation that we will retain such data until they specifically ask for its erasure?

           In such cases, The AfriOne Network will follow the guidelines of applicable law and keep data for no longer than is necessary for the purpose for which it is being processed, or until you request for the erasure of your data

          Has The AfriOne Network contractually agreed to a retention period?

          Organisations may ask that we retain data for at least a specified period. Your rights are not affected. Personal erasure requests will take priority in such circumstances.

 Is The AfriOne Network under a legal obligation to retain or delete the data?

Examples of this include, but not limited to; mandatory data retention laws set by governing bodies or data retained for the purposes of litigation.

WHERE WE STORE AND PROCESS PERSONAL DATA

We may store or process personal data collected by The AfriOne Network in any country that we operate. This includes, but not limited to; South Africa, the United Kingdom, Italy, Germany, France, Sweden, the United Arab Emirates, the United States of America, Canada, Mexico, Singapore, Australia, Hong Kong and Tokyo.
A full list of our countries of operation can be found here
The AfriOne Network ’s primary data storage location is London, however, services such as our CRM, Identity and Access Management system and website are hosted in the United Kingdom. We will ensure that ‘adequate safeguards’ are in place when transferring data between regions, following the guidance of applicable laws. Company entities of The AfriOne Network may also process personal data following Applicable Law.

YOUR RIGHTS

You have the following rights:

Right of access to personal data that we process about you, which includes the right to obtain confirmation as to whether or not
we process any of your personal data, and if this is the case, you have the right to request a copy of your personal data, and the
details of our processing of your personal data;

to require us to correct any inaccuracies in your data;

to object to our processing of your personal data (including for direct marketing purposes) or to withdraw your consent if you
have previously given us your consent;

in certain circumstances you may have the right to request the erasure of your personal data (often referred to as the “right to
be forgotten”), for example, if we no longer have any legal ground for processing your personal data, e.g. we no longer need it for
our legitimate interests (as set out above);

instead of erasure, you can request the restriction of processing of your personal data (i.e. limit the use of your data by us), for
example when the accuracy of your data is being verified by us, or if we no longer need your data for our legitimate interests but
we need to hold some of it for the purpose of legal proceedings; and

you may request the transfer of any personal data you have provided to us to a different organisation.

If you wish to exercise any of the above rights, you should:

put your request in writing and email it to us at a1@afrione.africa; 

include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill).

This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
provide the details of the request that you are making, for example by specifying the personal data you want to access, the information that is incorrect, and the information with which it should be replaced.

You should not provide The AfriOne Network with any personally identifiable information or submit or post any personally identifiable information to the site unless you would like that information to be used by The AfriOne Network in accordance with this policy.

Likewise, you should not submit or post any personally identifiable information to the website unless you want that information to be accessible by other users of the website, as information posted on the website may be made available to other users of the website.
Personally, identifiable information posted to the service site is not accessible by other users of the service site who do not belong to your peer user group or organisation and who are also registered on the service site.

The personally identifiable information that The AfriOne Network  collects from users of the Sites (both registered and unregistered) may be used for a variety of purposes, for example, to provide the services and products offered through the Sites to users of the Sites, to customise content and/or layout of the Sites for each individual user of the Sites, to notify users of the Sites about updates to and activities on the Sites and about goods and services that we feel may be of interest to you, to improve the content of the Sites, to analyse data and patterns regarding usage of the Sites, to contact users of the Sites for marketing purposes, and to contact users of the Sites for information verification purposes.

The AfriOne Network may collect and publish statistics and usage information related to the Users’ consumption and feedback of content only in Anonymous Information cases. We may publish consumption data associated with a certain keyword or piece of content, but never in relation to your Account. We may collect certain information from visitors to the Site and users of the Services, such as Internet addresses. This information is logged to help diagnose technical problems and prevent security breaches.

LODGING A COMPLAINT

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

CHANGES TO THIS POLICY

We may change this Policy from time to time. The current version of this Policy will always be available from us in hard copy or on our website. We will post a prominent notice on our website to notify you of any significant changes to this Policy or update you by other appropriate means.

NOTIFICATION OF CHANGES

If we decide to change the Policy, we will either notify users by way of an email or post material changes on the Sites so our users are aware of what information we collect, how we use it, and if we disclose it. Unless we seek and receive your consent, we will use information in accordance with the Policy under which the information was last collected. Users may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at ‘a1@afrione.africa

SECURITY

We will use at least industry standard measures on the Sites to protect the loss, misuse or alteration of the information under our control. We use a secure server hosting location, firewall protection, controlled access and secure data storage to protect your data. We do not store your passwords in plaintext, nor do we store your credit card information on our systems. The Sites fully support SSL and current encryption standards. We also limit access to your data to our employees whom we believe reasonably need to come into contact with that information. While no system is guaranteed to be completely secure, we work hard to ensure our security measures protect all information in a responsible manner.

COOKIES

The AfriOne Network uses “cookies” to improve the experience of the Sites. A cookie is a text file that is placed on your hard disk by a web page server, often including an anonymous unique identifier. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies for various purposes, for example, to save user preferences, customise Site content for individual users, to ensure that users are not repeatedly sent the same content, to record session information, to alert users to new areas that might be of interest upon return to the Site, and to save certain information about users of the Site and others who visit the Site. We also use cookies to record current login information; however, you are still required to log in to your account after a certain period of time has elapsed to protect you against others accidentally accessing your Account.

IP ADDRESSES AND COOKIES

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual and we will not collect personal information in this way.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

To estimate our audience size and usage pattern.

To store information about your preferences, and so allow us to customise our site according to your individual interests.

To speed up your searches.

To recognise you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. 

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to member needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. When someone visits we use Google Analytics and Google Console to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website. When you register as a The AfriOne Network member or request to join our mailing lists, we collect personal information. We use that information for a couple of reasons: to update you on activities pertinent to the interests you have advised us of; to contact you if we need to obtain or provide additional information; to check our records are up-to-date and to monitor your satisfaction. We use Constant Contact, to deliver our newsletter. We gather statistics around email opening and clicks using industry-standard technologies to help us monitor and improve our e-newsletter. For more information, please see Constant Contact’s privacy notice. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing a1@afrione.africa

When you purchase a ticket (or tickets) or register for events online, your name, address data, email, and contact number will be stored in Eventbrite or other payment platform we use now or in the future which is integrated into our internal CRM and CMS systems. Please be assured that we do not share your personal details with any other company without your consent. For more information please see Eventbrite’s privacy policy. In order to deliver our information and data services to members, we share limited member email information with our partners and others. These relationships are supported by relevant Non-Disclosure Agreements. Their respective privacy policies can be found here and here. You may opt out of these services by contacting our data protection officer. Data is stored until such date as you cease using our services or request that it be deleted. You are entitled to view, amend, or delete the personal information that we hold.

DISCLOSURE AS REQUIRED BY LAW

Though we make every reasonable effort to preserve user privacy, we may need to disclose personally identifiable information of certain users of the Sites when we have a reasonable and good-faith belief that the disclosure is necessary to comply with a current judicial proceeding, a court order, or legal process served on The AfriOne Network or the Sites. In this situation, we will use reasonable efforts to provide notice of this disclosure to all affected users, to the extent reasonably possible under the circumstances.

POPI, PATA & CPA

By using our Website, you have given us consent to share and use your information for anything that seeks to advance the cause of AFRIONE NETWORK PTY LTD and its 3rd party, either for marketing, information and any other thing.

SERVICE ANNOUNCEMENTS

On occasion, it is necessary to send out service-related announcements. For instance, if the Sites or any of the services offered through the Sites are temporarily suspended for maintenance, we might send users an email. Generally, users may not opt out of these communications, though they can deactivate their account. These communications are not promotional in nature.

SPECTAL OFFERS AND UPDATES

We send all new registrants of the Sites a welcoming email to verify passwords and usernames. Subscribing users will occasionally receive information on products, services and special deals, and periodic newsletters in accordance with their subscription agreements. We may occasionally send existing and expired subscribers’ information on products, services and special deals, and periodic newsletters which are not part of their subscription.

NON-PERSONALLY IDENTIFTABLE INFORMATION

Where possible, our server automatically recognises each visitor’s Internet Protocol addresses. We also collect information about how visitors use the Sites (for example what pages are viewed and products and services are purchased). This information, which is collected and maintained in an anonymous and non-personally identifiable form, allows us to improve the content of the Sites and facilitate market research. Sometimes, we utilise the services of a third party to help us understand this information better, although the information that is disclosed to these entities remains at all times in anonymous and non-personally identifiable form. Other than improving the Sites and the experience of visitors to the Sites, we make no other use of this information.

TRANSFER OF INFORMATION

As we continue to develop our business, we may participate in corporate transactions such as mergers and acquisitions, and it is possible that another company may acquire The AfriOne Network Ltd. or its business assets in the future. If The AfriOne Network elects, in its reasonable discretion, to transfer ownership or control of the Sites to a third party, whether or not in the context of an acquisition of The AfriOne Network or a merger of The AfriOne Network  with a third party, you consent to the transfer of your personally identifiable information and non-personally identifiable information to that third party, provided that all use of your information by that third party remains subject to the terms of this Policy.

ACCESS, REVIEW, UPDATE

Users may review, delete/deactivate and update the personal information that was previously provided to us by emailing us at ‘a1@afrione.africa. We may ask you to provide identification before progressing with your enquiry.

OTHER WEBSITES; LINKS

Third-party websites may be accessible through the Sites. These third-party websites have their own privacy and data collection policies and practices. The AfriOne Network is not responsible for any actions or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing personally identifiable information through linked websites.

CONSENT TO THE USE OF THIRD-PARTY PROVIDERS

In addition to the specific third parties noted in this Policy, The AfriOne Network may also contract with other third parties to provide various services to The AfriOne Network relating to the Sites on an outsourced basis rather than performing the services itself. For example, The AfriOne Network may contract with an email provider to handle the distribution of email messages to subscribers of the Sites. Likewise, The AfriOne Network may contract with a website hosting provider to host all or a portion of the Sites for Oxford Economics. By visiting the Sites, all visitors consent to The AfriOne Network providing both personal and non-personal information received from those visitors to these third-party providers for the purpose of enabling the third-party provider to provide these outsourced services to Oxford Economics. In addition, all visitors consent to the collection, maintenance, and processing of their personal and non-personal information by The AfriOne Network and these third-party providers.

CONTACT INFORMATION 

Any questions or suggestions about this Privacy Policy should be addressed A1 email to: “a1@afrione.africa
This notice is reviewed intermittently and may be updated at any time. We are regulated by the Information Commissioner’s Office You can contact them for advice and support.

AML KYC PRIVACY NOTICE

We will process your identifying data and profile data within operations such as identification (Know your Customer, also known as KYC) and profiling (Customer Due Diligence, also known as CDD) for the execution of our Anti Money Laundering (also known as AML) and Counter-Terrorism Financing (also known as CTF) customer identification and verification process obligations.

When AfriOne Invest Crowdfunding asks for CDD, what this refers to is proof of address and proof of identification. This along with information gathered at the application stage paints a picture of any customer (KYC). Without KYC, AfriOne Invest Crowdfunding may unknowingly become involved with illicit activities and therefore subject to reputational, operational, and legal risks, which can result in significant financial costs or the eventual winding up of the institution. KYC is most closely associated with the fight against money laundering.

Specific proof of address, proof of Identification, source of funds, and/or AML-CTF questionnaires that are aimed at fulfilling KYC and CDD obligations are compulsory to AfriOne Invest Crowdfunding users and the failure to be replied might lead (in extreme cases) the blocking of their accounts or the refusal of services.

In response to the scale and effect of money laundering, the European Union has passed Directives designed to combat money laundering and terrorism. These Directives, together with national regulations as read below, form the cornerstone of our AML/CTF obligations, establish the legal basis for us to process this data, and outline the offenses and penalties for failing to comply.

Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market;

Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for money laundering or terrorist financing;

Council Decision of 17 October 2000 concerning arrangements for cooperation between financial intelligence units of the Member States in respect of exchanging information (2000/642/JHA);

Crime Proceeds of Crime Act 2015;

Terrorism Act 2018;

Drug Trafficking Offences Act 1995;

ANTI-MONEY LAUNDERING (AML) POLICIES

Our AML policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. Our AML policy sets out the minimum standards which must be complied with and includes:

1.   Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules, and industry guidance;
2.   Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm. The requirement to provide CDD-related data throughout an RBA that will always take into account different factors such as the status of the client, the nature of the transactions, the financial product, or the financial flows involved;
3.   Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification, and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
4.   Establishing and maintaining risk-based systems and procedures for the monitoring of ongoing customer activity;
5.   Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
6.   Maintaining appropriate records for the minimum prescribed periods;
7.   Providing training for and raising awareness among all relevant employees.

As a regulated financial institution, AfriOne Invest Crowdfunding has specific requirements regarding AML systems and procedures. This reflects senior management’s desire to prevent money laundering.

ANTI MONEY LAUNDERING AND COMBATING TERRORIST FINANCING

Money laundering is defined as the process where the sources of funds are disguised so that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicion.

SANCTIONS POLICY

AfriOne Invest Crowdfunding is prohibited from transacting with individuals, companies, and countries that are on prescribed sanctions lists. AfriOne Invest Crowdfunding will therefore screen against the United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

AUTOMATED DECISION MAKING

We use semi-automated processes which include but are not limited to, screening Know-Your-Customer (KYC) and Anti-Money Laundering (AML) data you provide to us to assess whether or not we are legally able to allow you to use our services.

All automated screening matches are manually reviewed by AfriOne Invest Crowdfunding compliance analysts. The analyst will review the triage cases to determine if they should be cleared or escalated to the MLRO.

THIRD PARTIES AML-KYC

Where the processing of personal data is carried out on behalf of AfriOne Network by a third-party provider, we conclude a separate contract with the processor concerning this processing. This contract ensures compliance with European data protection regulations and defines sufficient guarantees for the implementation of appropriate technical and organizational measures, which ensure the protection of your rights.

SECURITY MEASURES

We have put in place appropriate security measures to prevent your Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We have taken precautions to ensure the security of your data. The Personal Data you have entered on HTML pages (contact forms) and that is stored by us, shall be transmitted to AfriOne Network in encrypted form (TLS - Transport Layer Security) via the public data network, and stored and processed at AfriOne Network.

In addition, we limit access to your Data to those employees, agents, contractors, and other third parties strictly needed under the provisions made within a service agreement signed with them. They will only process your Data on our instructions and they are subject to a duty of confidentiality and a duty to comply with data protection procedures.

We have put in place procedures to deal with any suspected or actual Personal Data breach. We will notify you and any applicable authority of a Personal Data breach where we are legally required to do so.

INFORMATION ABOUT BACKGROUNDS

We envisage that we will process and store information about background investigations and certificates of good conduct issued by policing authorities and due diligence of all candidates. Once a decision has been made regarding interest in hiring an applicant any offer will be made contingent upon the satisfactory completion of reference checks and criminal background checks.

We will only process information about criminal records, convictions, and offenses where we have obtained your explicit consent, where necessary for performing or exercising our or your obligations or rights under applicable laws and regulations, and where it is necessary for the prevention and detection of an unlawful act or reasons of substantial public interest.

Where we are processing personal information based on your consent, you have the right to withdraw that consent at any time where there is no other legal basis for the processing, by contacting us at a1@afrione.africa

CONTACT INFORMATION 

Any questions or suggestions about these Terms and conditions should be addressed via email to: “a1@afrione.africa”. This notice is reviewed intermittently and may be updated at any time. We are regulated by the Information Commissioner’s Office You can contact them for advice and support.

Thank you

Privacy & Compliance Department.

2 Baanbreker Avenue, Helderkruin, Roodepoort South Africa

THE AFRIONE INVEST – EVERYONE IS INVESTABLE

KNOW YOUR CUSTOMER / CUSTOMER DUE DILIGENCE, ANTI-MONEY LAUNDERING, COUNTER FINANCING OF TERRORISM AND PROLIFERATION FINANCING POLICY AND PROCEDURES

INTRODUCTION AFRIONE

THE AFRIONE NETWORK  (hereinafter referred to collectively as “AfriOne”, “Company”, “Our”, AfriOne Invest", “AfriOne Crowdfunding”, “Us” and “We”) AFRIONE INVEST is an active business arm of the AfriOne Network that serves as emerging market focused all in one marketplace seeking for funding, support or donation to emerging business, startups or ideas. The AfriOne Network incorporated in the jurisdiction of South Africa and operated at No. 2 Baanbreker Avenue, Helderkruin, Roodepoort, Johannesburg, South Africa in accordance with the company act of south Africa with the registration number K2018597185 and We are register with the Financial Intelligence Centre (FIC) - SHREG-230419-0000077. The company website address are www.afrione.africa and www.invest.afrione.africa

The core activity of company is to trade (“crowdfunding” & “Invest”) of Crowdfunding and has been serving customers through our various products and services i.e. digital wallet, Sales & Service, API payment gateway, buy and sell of digital assets. AfriOne is a API facilitation company, making service reach the ordinary and every citizen where we find ourselves, except otherwise stated below and by operational jurisdiction.

The core activity of our company is unified next generation feature rich, secured, scalable, robust, and services platform enabling South Africans, Africans, Governments, business, individual and Aggregators to efficiently roll out and scale services through offering a wide range of use cases for the consumers through multiple transaction channels and creating a digital eco system by integrating the digital assets to various other digital service system. e.g. Operating custody accounts for third parties, offering payments services, executing payments transactions, operating an online currency exchange platform, clearing and settling transactions between third parties, decentralized trading platform and marketplace offering and various other services. Our Company is an all in one delivery extension to which will help to build delivery business and platforms for the entrepreneurs and the general public.

AUTHORITY & SCOPE OF THE AML/CTF POLICY

This Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy (the Policy) is issued under the authority of AFRIONE Directors (the “Board” or “BOD”). This Policy applies to all of the Company’s (“AFRIONE NETWORK” and It “SUBSIDIARIES” or “Product”) employees, staff, officers and directors in accordance with the regulatory requirement of South African regulations and guidelines and subsequent amendments or additions, constitute and form part of the terms shall also be applicable on the conditions of their employment.

This Policy establishes the compliance framework by which all AFRIONE comply with all applicable laws and regulations in the south Africa entity have AML/CTF or suspicious activities obligations. This Policy is used by the Board as a guide to ensure that the stable business is conducted in a manner that is compliant with all applicable laws and regulations. The company has created and developed products and services with a compliance and security focus in mind in an effort to combat any attempted use of AFRIONE for illegal or illicit purposes. AFRIONE is committed to maintaining the highest possible compliance with all applicable laws and regulations relating to AML and the prevention of terrorism financing. All company’s personnel will be required to complete annual compliance training programs to support compliance focus. In all circumstances, company will maintain rigorous AML/CTF controls in accordance with applicable laws.

Adherence to this Policy is the responsibility of all employees directly or indirectly facing customers, executing or overseeing transactions, contractual documentation, systems and tools or other sources of information that may provide or reveal indications of possible money laundering or terrorism financing. All employees, including full-time, temporary or part-time employees, interns and contractors, if they have access to information or tools or are involved in the processes described in this document, are expected to be familiar with this policy as it relates to their responsibilities, and act in accordance with its provisions. The Board of Directors of company is ultimately responsible for approving this policy, ensuring compliance with this policy and creating the culture of compliance within the company.

Company has adopted a risk-based approach to mitigate the risk of being used for the purpose of money laundering or terrorism financing. This means assessing the ML/TF risks to which company is exposed to as a result of the nature and complexity of its business and the ML/TF risk to which is exposed to as a result of entering into a business relationship or carrying out a particular transaction. The rules, requirements and procedures set out in this Policy must be complied with at all times. The Company reserves the right to take disciplinary action (including dismissal) for non-compliant employees or contractors.

The AML/CTF function at company is an independent function executed and managed by the appointed Money Laundering Reporting Officers (MLRO) in each of its regulated entity worldwide, as applicable, who will regularly update local management and BOD on all material issues. The AML/CTF program encompasses but is not limited to the following activities: customer identification processes, defining the scope of eligible and non-eligible activities, sanctions screening, transactional monitoring, regular risk assessments, suspicious activities reporting, record keeping, training and other pertinent aspects, as required by applicable laws and regulations.

This Policy is reviewed on every addendum/SROs/Circular of the regulations issued by South African government under regulations, to ensure that it incorporates recently enacted rules and regulations, provides guidance in relation to said products, systems or tools introduced by the company, and addresses most recent learning and best practices in the areas of AML and CTF.

AML/CTF POLICY OBJECTIVES

This AML/CTF Policy protect AFRIONE being used by money launderers, terrorists, and those financing terrorist activities. Specifically, this Policy:

• Definespecific roles and responsibilities for company AML/CTF compliance personnel
• Createan AML/CTF risk assessment process
• Outlinecompany AML/CTF internal control processes
• Createa Know Your Customer (referred as “KYC”) framework that provides for risk-based customer identification, verification and due diligence
• Createa transaction monitoring and suspicious activity reporting program
• Establish controls to ensure compliance with sanctions requirements and the regular screening against official public financial sanctions lists
• Establish aprocess to ensure adherence to all AML/CTF requirements, including filing of suspicious activities reports to the authority as per law, performing AML/CFT risk assessments, responding to information requests and maintaining records
• Ensurethat company documents its efforts to meet its legal and regulatory obligations, including any applicable recordkeeping requirements
• Providea training program for all personnel of the Company
• Requireperiodic independent testing; and
• Requireregular reporting to the Board about company AML/CTF efforts.

KEY TERMS AND DEFINITIONS

The key terms and definitions of this Policy are: Money laundering shall mean:

“knowingly facilitating by any means the false justification of the nature, the origin, the emplacement, the position, the movement or the propriety of the goods, which are constituting the object or the direct or indirect proceeds, or constituting a patrimonial benefit of any nature whatsoever from one or several of the designated predicate offences;”

“knowingly assisting in a placement, dissimulation or conversion transaction of digital assets constituting the object or the direct or indirect proceeds, or constituting a patrimonial benefit of any nature whatsoever from one or several of the predicate offences;” and ―having acquired, held or used the digital assets i.e. Crowdfunding constituting the object or the direct or indirect proceeds, or a patrimonial benefit of any nature whatsoever from one or several of the predicate offences, knowing, at the time they received them, that they originated from one of the designated offences or from the participation in one or several of these offences.”

The above references both define the money laundering offence by listing the facts constituting this offence and also specify the categories of predicate offences which may give rise to this offence. Money laundering presupposes the existence of a predicate offence whose object or proceeds may give rise to a money laundering offence.

The predicate offences are classified within this policy according to the list of designated categories of offences set forth in the glossary of the FATF Recommendations. The predicate offences include, but are not limited to:

• Involvementwith an organized criminal gang, racket, or terrorism, including the financing thereof
• Humantrafficking and illicit trafficking of immigrants
• Illicittrafficking in narcotic drugs and psychotropic substances
• Armstrafficking;
• Illicittrafficking in stolen goods and other goods
• Corruption
• Fraudand swindle
• Forgeryof money
• Forgeryand product piracy
• Kidnapping
• Illegaldetention and taking of hostages
• Theft
• Smuggling
• Extortion
• Forgery
• Aggravated tax fraud and tax evasion
• Piracy.

Money laundering consists of any act relating to the proceeds of or the object of any predicate offense (i.e. any act from which any economic benefit is drawn from the predicate offence).

The legal definition of money laundering is very broad and encompasses a whole set of devices which all serve the purpose to provide a false justification of the origin of the property forming the object or proceeds of the predicate offences. The money laundering offense requires that the actor knowingly launders the proceeds.

The FATF has identified a three-step process that is commonly used to launder money:

• Placement: The disposal of cash obtained from illegal activity by depositing it with or sending it through a financial institution. Illegal activities usually generate large amounts of cash that need to beplaced into the financial system, the retail economy or transferred out of the country (e.g., the sale of illegal drugs, where payment is commonly made in cash).
• Layering: Moving illegally obtained funds through various layers of financial transactions in order to disguise the illicit source of funds confuse any audit trail and provide anonymity for the criminal.
• Integration: The placement of laundered funds back into the financial system in a manner that makes such funds appears to be “clean”and legally earned.

A Politically Exposed Person (PEP) shall mean: An individual who is or has been entrusted with a prominent public function such as a Head of State or Government, a senior politician, senior government/judicial/military officer, senior executive of a state-owned corporation, important political party officials or family member and/or close relative of a PEP.

Know Your Customer (“KYC”) is the process of identifying and verifying the identity of its customers and ascertain relevant information required for doing business with them. KYC involves:

1. Seeking evidence of identity and address from the customer and independently confirming that evidence at the start of a relationship with the Company and periodically updating the information as per customer risk classification; and
2. Seeking information regarding the sources of income and nature of business etc. of thecustomer.

Customer Due Diligence (“CDD”) information comprises the facts about a customer that should enable an organization to assess the extent to which the customer exposes it to a range of risks. These risks include money laundering, terrorist financing and having business relationship with sanctioned individuals/entities or designated terrorists under South Africa Anti-Terrorism law.

(i)     Money Laundering (“ML”) is the involvement of any transaction or series of transactions seeking to conceal or disguise the nature or source of proceeds derived from illegal activities, including narcotics trade, human trafficking, terrorism, ransom, extortion money, organized crime, fraud, and other crimes.

(ii)   Financing Terrorism (“TF”) refers to activities that provide financing or financial support to individual terrorists or non-state actors.

(iii) Customer means any natural person, legal person or legal arrangement to whom financial services have been extended by a regulated person.

(iv)  Beneficial Owner A natural person who is the owner of the Customer (a legal entity or a foreign undertaking) or controls the Customer and/or the natural person on whose behalf a transaction or activity is being conducted.

(v)    Legal Persons mean entities other than natural persons whether incorporated or not or a legal arrangement that can establish a permanent customer relationship with a regulated person or otherwise own property and include companies, bodies corporate, foundations, Limited Liability partnership (LLP), partnerships, or associations and other relevantly similar entities.

AML/CTF RISK ASSESSMENT AND ASSOCIATED CONTROLS AND MEASURES

AFRIONE will identify and assess the money laundering risks and the terrorism financing risks that may be associated with its unique business, services, and customers. More specifically, company will:

• Carry out a business-wide ML/TF risk assessment on semiannually basis, assessing the risks to which company is exposed as a result of the nature and complexity of its business;
• Assess the risks to which company is exposed as a result of entering a business relationship or carrying out transactions to buy remittances.

Each of the above risks assessments will consist of two separate, but related steps: The identification of the ML/TF risk factors, and the assessment of any such factors. The Company shall take reasonable steps to manage them and shall focus resources on the areas of its business that management believes pose the greatest risks.

Having identified its AML/CTF risks, the Company has following strengths:

• Developed and implemented policies, procedures and controls, which are approved by the Board of Directors to enable it to manage and mitigate the risks;
• Monitorthe implementation of those policies, procedures and controls, and enhance them if necessary;
• Perform enhanced/reinforced measures where higher risks are identified, to effectively manage and mitigate those higher risks; and
• Ensure the performance of measures or enhanced measures to effectively manage and mitigate theidentified risks to address the risk assessment and guidance from the relevant authorities.

Company will perform its semiannual risk assessment, where AML/CTF risks must be fully addressed. Based on the outcome of such risk assessment, an appropriate compliance plan must be developed and executed. The outcome of the AML/CTF risk assessment must be presented to and reviewed by the Board of Directors.

The risk assessment is based on total customer risk assessment scoring system. Score in the client’s overall risk profile is 100 points.

The above number of points in the customer risk assessment scoring system upon the assessment of the nature of company socioeconomic activity and the client ‘s MLTF risk is broken down by risk assessment as follows:

• customerrisk—33 Points
• nationaland geographic risk— 2O points
• riskrelated to services and products used by the client — 27points
• serviceand product delivery channel risk—20 Points

For each risk segment considered within the assessment, the risk score can never be zero. Whilst the risk within a factor can be extremely low, there is always an inherent money laundering and terrorist financing risk which needs to be acknowledged by the South African Financial Intelligence Centre [FIC].

The monitoring employees ensure updates of the customer’s risk profile by applying the customer risk assessment scoring system each time when it is required to carry out due diligence of the customer. The customer risk assessment scoring system is utilized to apply risk mitigation measures pursuant to this AML and TF Policy or when FIC has obtained (through reports, customer service or due diligence, mass media Etc) Information concerning the customer, its beneficial owner, personal or economic activity as well.

The monitoring employee, based on the risk assessment and the risk Profile of the customer awarded score, determines the necessary due diligence measures and their regularity. The client’s due diligence measures and their regularity is determined based on the existing level of risk.

In order to perform regular update of the numerical score assigned to the risk factor, the customer compliance and monitoring department head selects at least 10 (ten) clients (focus group) and the relevance of the numerical score assigned to each risk factor, as well as the necessary changes in the numerical score assigned to each risk factor is based on the monitoring of the activity of the focus group.

Before the implementation of a new customer risk assessment scoring system or significant changes to the existing client risk assessment scoring system, the company shall inform the commission in a written form. The customer risk assessment scoring system shall include the following client identification information:

• nameof the customer
• countryof registration of the customer
• registrationnumber of the customer
• representativesof the customer
• beneficialowners of the customer

Company will put these following measures in place to ensure its business-wide and individual risk assessments remain up to date:

• Set a date for every six months of each calendar year, on which the next business-wide risk assessment update will take place
• Set a risk-sensitive date for individual risk assessments to ensure that new or emerging risks are included
• Reflect the emergence of new, or an increase in existing ML/TF risks in business-wide and individual risk assessments as soon as possible, and
• For eachrisk assessment period, record issues that could have a bearing on risk assessments, such as suspicious transaction or activity reports, compliance failures and intelligence from front office staff.

OBLIGATION TO ASSESS NEW PRODUCTS, PRACTICES AND TECHNOLOGIES PROCESS

The Company must identify and assess the money laundering and terrorism financing risks that may arise in relation to:

• Newproducts and new business practices, including new delivery mechanisms
• Impactof new AML regulations on existing products and services

This must be done prior to the launch or use of such products and practices, where applicable, paying particular attention to products or practices that favor anonymity.

OBLIGATION TO CONDUCT CUSTOMER DUE DILIGENCE (“CDD”) & KNOW YOUR CUSTOMER (“KYC”)

Company must exercise due diligence when dealing with new and existing clients. It will, under applicable laws, assist and cooperate with regulators and relevant law enforcement authorities in detecting and preventing money laundering and terrorism financing.

AFRIONE will periodically, and at least after six months of year, review the adequacy of the existing CDD information and procedures, in accordance with the business-wide risk assessment and ensure these remain relevant and kept up-to-date.

Under CDD, company shall apply risk-sensitive measures to identify the customer and, where applicable, the customer’s beneficial owner, and verify that identity on the basis of reliable and independent sources in a satisfactory manner, including the identity of beneficial owners. Finally, company shall establish the purpose and the intended nature of the business relationship.

OBLIGATION TO IDENTIFY AND REPORT SUSPICIOUS ACTIVITIES, CONDUCT CLIENT DUE DILIGENCE (“CDD”) & KNOW YOUR CUSTOMER (“KYC”)

Company AML team will file Suspicious Activity Reports or Suspicious Transaction Reports (hereinafter “SARs” or “STRs”) with the relevant FIC (and other authorities, where applicable) when we know, suspect or have reasonable grounds to suspect that money laundering or terrorism financing is being committed or has been committed or attempted, in particular in consideration of the person concerned, its development, the origin of the funds, the purpose, nature and procedure of the operation.

CUSTOMER IDENTIFICATION:

(i)     No account shall be opened in the name of person who fails to disclose his/her true identity or fails to provide valid identity document. To authenticate identity of new customer:

1. The photocopies of identity documents shall be validated through regulatory authority, identifyingpresence of any adverse remarks in the comments.
2. Incase of an individual with shaky/immature signatures, in addition to Passport, a passport size photograph of the new account holder will be obtained.

(ii)   Source of income shall be essentially disclosed by the customer.

1. In case source of customer’s income is business / employment, name of the business / employershall also be disclosed.
2. Incase of a salaried person copy of his service card or salary slip or certificate or letter on letter head of the employer will be obtained.

(iii) All prospective customers must be seen either face to face by the Company’s customer service representative or trader or on video call through communication tool like Skype, WhatsApp etc. and details verified over a recorded call on registered phone number.

(iv)  For any new account opening form, the Compliance Department shall match the particulars of the customer from the followings:

UNSC Sanctions list obtained daily from UNSC website under consolidated sanction list (https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list); If any matching name is found the account is being declined and reported to FIC simultaneously in the form of STR.

PROGRAM AND SYSTEMS TO PREVENT ML AND TF:

(i)     The Company will establish and maintain programs and systems to prevent, detect and report ML/TF. The systems will be appropriate to the size of the Company and the ML/TF risks to which it is exposed and will include:

1. Adequate systems to identify and assess ML/TF risks relating to persons, countries and activities whichshould include checks against all applicable sanctions lists;
2. Policiesand procedures to undertake a Risk Based Approach (RBA);
3. Internalpolicies, procedures and controls to combat ML/TF, including appropriate risk management arrangements;
4. CustomerDue Diligence measures;
5. Recordkeeping procedures;
6. Group-wideAML/CFT programs;
7. Anaudit function to test the AML/CFT system;
8. Screeningprocedures to ensure high standards when hiring employees; and
9. Anappropriate employee-training program.

(ii)   It will be the responsibility of the Senior Management to ensure that appropriate systems are in place to prevent, detect and report ML/TF and the Company is in compliance with the applicable legislative and regulatory obligations.

GOVERNANCE OF AML/CTF COMPLIANCE PROGRAM

Chief Compliance Officer (CCO) and Money Laundering Reporting Officer (“MLRO”)

The Designated Chief Compliance Officer appointed by AFRIONE or a Board of Directors Member responsible for regulatory and compliance matters (―CCO‖) is responsible for proper execution of the company Anti-Money Laundering and Counter Terrorism Financing Policy and related processes. Key Responsibilities of CCO and respective regional MLROs are:

• Oversightof effective implementation of AML/CTF Policy and related controls
• Making necessary changes and improvements to the AML/CTF Policy, arising, for example, from implementationof new regulations, introduction of new products, findings and learnings arising from AML/CTF testing and monitoring
• Organizationof AML Trainings for employees and retention of attendance records
• ManagingSuspicious Activities Reporting process and cooperating with law enforcement agencies
• Monitoringof rules and regulations concerning AML/CTF matters and ensuring that company AML/CFT systems and tools remain up-to-date and meet current regulatory requirements
• Reportingon AML/CTF matters to the Authorized Managers and Board of Directors, and providing support and guidance to senior management to ensure that AML/TF risks are adequately addressed
• Assistancein resolving AML/CTF issues escalated by AML or Risk Teams, and
• Participationin risk reviews and customer termination decisions

The CCO and MLROs will act as a main point of contact for external supervisors, law enforcement, and any other competent authorities in relation to AML/CTF prevention and related matters.

COMPLIANCE FUNCTION

In addition to CCO and MLROs, there are dedicated teams responsible for execution of certain AML/CTF tasks and activities within company and constituting the first line of defense (―FLOD‖) in relation to AML/CTF matters:

• Operations and Customer Support is responsible for the quality of customer on boarding and due diligence, performing reviews of customer information and analysis of triggering events, assessing customer screening results, evaluating suspicious transactions indications and responding to questions, escalated by other teams and internal departments regarding AML/CTF matters.
• Risk, Fraud and Transaction Monitoring is responsible for monitoring of incoming and outgoing transactions, risk alerts and triggering events in order to identify potential fraud or ML/TF suspicious transactions.
• Business Development and Account Management is responsible to gather necessary information from company partners and service providers to ensure that all financial, payments or technical partners and counterparties of company have adequate licensing and proper controls in place.
• Product Development is responsible for ensuring that the technical and policy recommendations of company and MLROs are appropriately understood, implemented, tested and monitored at the technical and product level.

SENIOR MANAGEMENT OVERSIGHT

The MLRO or CCO for each of the regulated entities will send regular reports to the Authorized Management of their entity and the Board of Directors in which a summary of all significant compliance matters is presented. MLROs will also prepare ad-hoc reports regarding important matters relating to AML/CTF as needed (i.e. change of regulatory framework, specific AML findings, detected risks etc.).

Every material change in AML/CTF Policy needs to be formally approved by the Board of Directors. Small tactical changes (sanctions list updates, slight modification of internal tools) can be implemented via on- going SOP updates and on-the-job trainings for relevant teams.

In order for the AML/CTF Compliance function to be effective, senior management should, as far as practicable, ensure that:

• Compliance function operates as an independent, permanent function, able to escalate any important issues or risks directly to the BOD
• Compliance function has adequate budget that can be allocated to processes, products or issues as needed based on the level of identified ML/TF risk; and equipped with sufficient resources, including tools and headcount.
• CCO/MLRO is of a sufficient level of seniority and authority within the company
• Compliance teams are capable of accessing, on a timely basis, all available information (both from internal sources, such as customer or transactional records, and external sources, such as circulars from relevant authorities)

RISK ASSESSMENT AND APPLYING A RISK BASED APPROACH (“RBA”):

The RBA enables the Company to ensure that AML/CFT measures are commensurate to the risks identified and allow resources to be allocated in the most efficient ways. RBA is applied keeping into consideration the Company’s size, geographical coverage, structure and business activities e.g. daily system-based sanction screening. As a part of the RBA, The Company:

1. IdentifyML/TF risks relevant to it;
2. AssessML/TF risks in relation to-
3. Itscustomers (including beneficial owners);
4. i)Countryor Geographic area in which its customers reside or operate and where the Company operates;
5. ii)Products,Services and Transactions that the Company offers; and

iii)    Their Delivery Channels.

1. iv)Design and implement Policies, Controls and Procedures that are approved by its Board to manage and mitigate the ML/TF risks identified and assessed;
2. Monitorand evaluate the implementation of mitigating controls and improve systems where necessary;
3. Keepits risk assessments current through ongoing reviews and, when necessary, updates;
4. Implementand monitor procedures and updates to the RBA; and
5. Haveappropriate mechanisms to provide risk assessment information to the Commission.

Under the RBA, the following mechanism will be applied:

1. where there are higher risks, the Company takes enhanced measures to manage and mitigate those risks; and
2. Correspondingly, where the risks are lower, simplified measures are permitted. However, simplified measures are not permitted whenever there is a suspicion of ML/TF.

In the case of some very high-risk situations or situations which are outside the Company’s risk tolerance, the Company may decide not to take or accept the customer, or to exit from the relationship. CO in such cases will consider need to raise an STR to FIC

In view of the fact that the nature of the TF differs from that of ML, the risk assessment must also include an analysis of the vulnerabilities of TF. Many of the CFT measures the Company has in place will overlap with its AML measures. These may cover, for example:

1. a)riskassessment;
2. b)CDDchecks;
3. c)transactionmonitoring;
4. d)escalationof suspicions; and
5. e)Liaisonrelationships with the 

The process of ML/TF risk assessment has four stages:

1. a)Identifyingthe area of the business operations susceptible to ML/TF;
2. b)Conductingan analysis in order to assess the likelihood and impact of ML/TF;
3. c)Managingthe risks;
4. d)Regularmonitoring and review of those risks; and
5. e)Identification,Assessment and Understanding 

1. The first step in assessing ML/TF risk is to identify the risk categories, i.e. Customers, Countries or Geographical locations, Products and Services, Transactions and Delivery Channels that are specific to the Company.
2. In the second stage, the ML/TF risks that can be encountered by the Company need to be assessed, analyzed as a combination of the likelihood that the risks will occur and the impact of cost or damages if the risks occur. This impact can consist of the followings:

1. i)Financial loss to the Company from the crime and monitory penalties from regulatory authorities or the process of enhanced mitigation measures.
2. ii)Reputationaldamages to the business or the entity 

iii)    The analysis of certain risk categories, their combination and the conclusion on the total risk level must be based on the relevant information available.

For the analysis, the Company will identify the likelihood that these types or categories of risk will be misused for ML and/or for TF purposes. This likelihood is for instance:

1. a)High,if it can occur several times per year;
2. b)Mediumif it can occur once per year; and
3. c)Lowif it is unlikely, but 

In assessing the impact, the Company will, for instance, look at the financial damage by the crime itself or from regulatory sanctions or reputational damages that can be caused. The impact can vary from minor if that are only in short-term or there are low-cost consequences, to very major, when they are found to be very costly inducing long-term consequences that affect the proper functioning of the institution.

1. Company will allow for the different situations that currently arise in its business or are likely to arisein the near future. For instance, risk assessment should consider the impact of new products, services or customer types, as well as new technology. In addition, ML/TF risks will often operate together and represent higher risks in combination. Potential ways to assess risk include but are not limited to:
2. a)How likely an event is;
3. b)Consequenceof that event;
4. c)Vulnerability,threat and impact;
5. d)Theeffect of uncertainty on an event;
6. The assessment of risk will be informed, logical and clearly recorded. Further, the risk assessmentshould indicate how the Company arrived at this rating.

5.1 RISK ASSESSMENT MECHANISM:

RISK ASSESSMENT (LOWER COMPLEXITY):

The Company will assess risk by only considering the likelihood of ML/TF activity. This assessment will involve considering each risk factor that have been identified, combined with business experience and information published by the Commission and international organizations such as the FATF. The likelihood rating will correspond to:

1. a)Unlikely - There is a small chance of ML/TF occurring in this area of thebusiness;
2. b)Possible - There is a moderate chance of ML/TF occurring in this area of the business;
3. c)Almost Certain - There is a high chance of ML/TF occurring in this area of the business

RISK ASSESSMENT (MODERATE COMPLEXITY):

• Another wayto determine the level of risk is to work out how likely the risk is going to happen and cross- reference that with the consequence of that risk.
• Using likelihood ratings and consequence ratings can provide the Company with a more comprehensive understanding of the risk and a robust framework to help arrive at a final risk rating. These ratings, in combinationwith structured professional opinion and experience, will assist the Company in applying the appropriate risk management measures as detailed in the program.
• Cross-referencingpossible with moderate risk results in a final inherent risk rating of moderate. The program should then address this moderate risk with appropriate control measures. Company will need to undertake this exercise with each of the identified risks.

RISK ASSESSMENT (HIGHER COMPLEXITY)

1. a)TheCompany will further assess risk likelihood in terms of threat and 
2. b)Determining the impact of ML/TF activity can be challenging but to focus AML/CFT resources in a more effective and targeted manner. When determining impact, Company can consider a number of factors, including:

1. Natureand size of your business (domestic and international);
2. Economicimpact and financial repercussions;
3. Potentialfinancial and reputational consequences;
4. Terrorism-related impacts;
5. Widercriminal activity and social harm; 6) Political impact;
6. Negativemedia.
7. The Company wills more weight to certain factors to provide a more enhanced understanding of your ML/TF risk.
8. Inaddition, Company may consider how its risks can compound across the various riskfactors.

APPLYING THE RISK ASSESSMENT:

The risk assessment will assist in ranking and prioritizing risks and providing a framework to manage those risks. The risk assessment will enable the Company to prepare a comprehensive program. It will enable to meet relevant obligations under the regulations, including obligations to conduct CDD, monitor accounts and activities and report suspicious activity.

The assessment will help in determining suspicion and consequently assist in the decision to submit an STR to the FIC The Company will submit an STR to the FIC if it thinks that activities or transactions are suspicious.

The Company will conduct ongoing CDD. The risk assessment will help target and prioritize the resources needed for ongoing CDD.

The Company will undertake account monitoring. The risk assessment will help to design the triggers, red flags and scenarios that can form part of account monitoring.

1. a)MATERIALCHANGES AND RISK ASSESSMENT:

The risk assessment will adapt when there is a material change in the nature and purpose of the business or relationship with a customer. A material change could present an increase, or decrease, in ML/TF risk.

Material change could include circumstances where the Company introduces new products or services or have customers (or their beneficial owner) based in new jurisdictions. Material change can include when the Company starts using new methods of delivering services or have new corporate or organizational structures. It could result from deciding to outsource CDD functions or changing your processes for dealing with PEPs. In these circumstances, the Company will need to refresh its risk assessment.

The Compliance resources are accordingly allocated to the areas with higher Inherent Risk to bring the Residual Risk within tolerable band. This risk assessment is an ongoing process and is reviewed on semiannual basis to factor in new and emerging risks due to business dynamics and changes in regulatory framework. This include changes in risk levels as new products are offered, as new markets are entered, as high-risk customers open or close accounts, or as the products, services, policies, and procedures change. The Company also have appropriate mechanisms to provide risk assessment information to the Commission, if required. This is done through a specially designed document which is provided as Annexure 1 to these policy and procedures.

RISK CLASSIFICATION FACTORS:

Below are some examples that can be helpful indicators of risk factors / indicators that may be considered while assessing the ML/TF risks for different risk categories relating to types of customers, countries or geographic areas, and particular products, services, transactions or delivery channels. However, this list is not exhaustive and staff should use critical thinking in determining risk of ML/TF.

1. High-RiskClassification Factors:

1. The Customer risk factors: Risk factors that may be relevant when considering the risk associated with a customer or a customer’s beneficial owner’s business include:

1. i)Thebusiness relationship is conducted in unusual circumstances (e.g. significant unexplained geographic distance between the Company and the customer):
2. ii)Non-residentcustomers;

iii)    Politically Exposed Persons (PEPs);

1. iv)Legalpersons or arrangements;
2. v)Companiesthat have nominee shareholders;
3. vi)Businessthat is cash-intensive;

The ownership structure of the customer appears unusual or excessively complex given the nature of the customer’s business such as having many layers of shares registered in the name of other legal persons;

1. i)shell companies, especially in cases where there is foreign ownership which is spread across jurisdictions (i) trusts and other legal arrangements which enable a separation of legal ownership and beneficial ownership of assets;
2. ii)Requested/Appliedquantum of business does not match with the profile/particulars of client;

iii)    Not-For-Profit organization (NPOs) with association with political parties or religious groups;

1. iv)RealEstate Dealers;
2. v)Dealersin precious metal and stones, and
3. vi)Designated Non-Financial Business and Professionals (DNFBPs) such as Lawyers/notaries, 

SCENARIOS OF CUSTOMER TYPES

Small and Medium Sized Enterprises:

Small and medium business enterprise customers usually entail domestic companies with simple ownership structures. Most of these businesses deal with cash and multiple persons that can act on its behalf. The likelihood that funds deposited are from an illegitimate source is HIGH, since it can‘t easily be identified and can have a major impact on a large number of SME customers. Thus, the risk assessment and risk rating result is HIGH.

International Corporations:

International corporate customers have complex ownership structures with foreign beneficial ownership (often). Although there are only a few of those customers, it is often the case that most are located in offshore locations. The likelihood of Money Laundering is High because of the limited number of customers of this type and the beneficial ownership could be questionable, with two criteria that in this scenario result in a possible risk impact of moderate and a moderate risk assessment.

Note: The above risk analysis is a general one for types or categories of customers. It is the starting point for the risk classification of an individual customer. Based on the circumstances of an individual customer, such as its background or information provided, the risk classification of an individual customer can be adjusted. Based on that individual risk classification, customer due diligence measures should be applied.

1. Countryor geographic risk factors:

Country or geographical risk may arise because of the location of a customer, the origin of a destination of transactions of the customer, but also because of the business activities of the Company itself, its location and the location of its geographical units. Country or geographical risk, combined with other risk categories, provides useful information on potential exposure to ML/TF. The factors that may indicate a high risk are as follow:

1. i)Countries identified by credible sources, such as mutual evaluation or detailed assessment reports or published follow-up reports by international bodies such as the FATF, as not having adequate AML/CFT systems;
2. ii)Countriessubject to sanctions, embargos or similar measures issued by, for example, the United Nations;

iii)    Countries identified by credible sources as having significant levels of corruption or other criminal activity  

1. iv)Countries or geographic areas identified by credible sources as providing funds or support for terrorist activities, or that have designated terrorist organizations operating within their country;
2. v)Entitiesand individuals from jurisdictions which are known tax heavens;

1. PRODUCT,SERVICE, TRANSACTION OR DELIVERY CHANNEL RISK FACTORS:

The Company, while doing its ML/TF risk assessment, takes into account the potential risks arising from the products, services, and transactions that the Company offers to its customers and the way these products and services are delivered. In identifying the risks of products, services, and transactions, the following factors are considered:

1. i)Anonymoustransactions (which may include cash);
2. ii)Transactionfor which payments are made from more than two bank accounts of a customer;

iii)    Products that involve large payment or receipt in cash of more than or equivalent R24,999.99

1. LOWRISK CLASSIFICATION FACTORS:
2. Customerrisk factors:

Ø  The customer is a regulated person or bank and is subject to requirements to combat money laundering and terrorist financing consistent with the FATF recommendations and are supervised for compliance with those requirements; or

Ø  Public listed companies that are subject to regulatory disclosure requirements to ensure adequate transparency of beneficial ownership;

1. Product,service, transaction or delivery channel risk factors:

Financial products or services that provide appropriately defined and limited services to certain types of customers.

1. Countryrisk factors:

Ø  Countries identified by credible sources, such as mutual evaluation or detailed assessment reports, as having effective AML/CFT systems.

Ø  Countries identified by credible sources as having a low level of corruption or other criminal activity.

In making a risk assessment, the Company could, when appropriate, also take into account possible variations in ML/TF risk between different regions or areas within a country.

1. RISKMATRIX

In assessing the risk of money laundering and terrorism financing, the Company will establish whether all identified categories of risks pose a low, moderate, high or unacceptable risk to the business operations. The Company will review different factors, e.g., number and scope of transactions, geographical location, and nature of the business relationship. In doing so, it must also review the differences in the manner in which it establishes and maintains a business relationship with a customer (e.g., direct contact or non-face-to-face). It is due to the combination of these factors and the variety of their combinations, that the level of money laundering and terrorism financing differs from institution to institution. The geographical risk should be seen in correlation with other risk factors in order to come up with an assessment of the total money laundering and terrorism financing risk.

The Company will use a risk matrix as a method of assessing risk in order to identify the types or categories of customers that are in the low-risk category, those that carry somewhat higher, but still acceptable risk, and those that carry a high or unacceptable risk of money laundering and terrorism financing.

The development of a risk matrix can include the consideration of a wide range of risk categories, such as the products and services offered by the Company, the customers to whom the products and services are offered, the size and organizational structure, etc. A risk matrix is not static: it changes as the circumstances of the Company change. A risk analysis will assist the Company to recognize that ML/TF risks may vary across customers, products, and geographic areas and thereby focus its efforts on high-risk areas in its business.

Note: When conducting risk assessment, the Company does not have to follow the processes in this document. As long as it complies with the obligations under the Act and any other applicable laws or regulations, the Company has a choice to select the method of risk.

1. RISKMANAGEMENT:

1. RiskMitigation

1. The Company will develop appropriate policies, procedures and controls that will enable it to manage and mitigate effectively the inherent risks that it has identified, including the national risks. Company will monitor the implementation of those controls and enhance them, if necessary. The policies, controls and procedures will be approved by the senior management of the Company, and the measures will be taken to manage and mitigate the risks (whether higher or lower) to ensure that measures are consistent with legal and regulatory requirements.

The nature and extent of AML/CFT controls the Company puts in place depends on a number of aspects, which include:

1. Thenature, scale and complexity of the Company’s business;
2. Diversity,including geographical diversity of the Company’s operations;
3. TheCompany’s customer, product and activity profile;
4. Volumeand size of transactions;

Extent of reliance or dealing through third parties or intermediaries, which is minimal in case of Company and restricted to Administration department related services;

Some of the risk mitigation measures that the Company may consider include:

1. i)Determiningthe scope of the identification and verification requirements or ongoing monitoring based on the risks posed by particular customers;
2. ii)settingtransaction limits for higher-risk customers or products;

iii)    requiring senior management approval for higher-risk transactions, including those involving PEPs;

1. iv)determiningthe circumstances under which they may refuse to take on or terminate/cease high risk customers/products or services;
2. v)Determiningthe circumstances requiring senior management approval (e.g. high risk or large transactions, when establishing relationship with high risk customers such as PEPs).

1. Evaluating Residual Risk and Comparing with the Risk Tolerance:

Subsequent to establishing the risk mitigation measures, the Company will evaluate its residual risk, which is the risk remaining after taking into consideration the risk mitigation measures and controls. Residual risks are kept in line with the Company’s overall risk tolerance and this sets the cornerstone of accepting and continuing business relations.

2. MONITORINGAML/CFT SYSTEMS AND CONTROLS:

The Company will have systems in place to monitor the risks identified and assessed as they may change or evolve over time due to certain changes in risk factors, which may include changes in customer conduct, development of new technologies, new embargoes and new sanctions. The Company will update their systems as appropriate to suit the change in risks.

Additionally, the Company will assess the effectiveness of their risk mitigation procedures and controls, and identify areas for improvement, where needed. For that purpose, the Company will need to consider monitoring certain aspects which include:

1. the abilityto identify changes in a customer profile or transaction activity/behaviour, which come to light in the normal course of business
2. the potential for abuse of products and services by reviewing ways in which different products and services may be used for ML/TF purposes, and how these ways may change, supported by typologies/law enforcement feedback, etc.;
3. theadequacy of employee training and awareness;
4. theadequacy of internal coordination mechanisms i.e., between AML/CFT compliance and other functions/areas;
5. thecompliance arrangements (such as internal audit);
6. changesin relevant laws or regulatory requirements; and
7. changesin the risk profile of countries to which the Company or its customers are exposed to.

DOCUMENTATION AND REPORTING:

Documentation of relevant policies, procedures, review results and responses will enable the Company to demonstrate to the Commission:

1. riskassessment systems including how the Company will assess ML/TF risks;
2. detailsof the implementation of appropriate systems and procedures, including due diligence requirements, in light of its risk assessment;
3. willmonitor and, as necessary, improves the effectiveness of its systems and procedures; and
4. arrangementsfor reporting to senior management on the results of ML/TF risk assessments and
5. implementationof its ML/TF risk management systems and control processes.

Ø  The Company will note that the ML/TF risk assessment is not a one-time exercise and therefore, they must ensure that their ML/TF risk management processes are kept under regular review which is at least annually. Further, the Company management should review the program’s adequacy when the reporting entity adds new products or services, opens or closes accounts with high-risk customers, or expands through mergers or acquisitions.

Ø  The Company will demonstrate to the Commission, the adequacy of its assessment, management and mitigation of ML/TF risks; its customer acceptance policy; its procedures and policies concerning customer identification and verification; its ongoing monitoring and procedures for reporting suspicious transactions; and all measures taken in the context of

Ø  AML/CFT, during the on-site inspection. The Company will maintain Risk Assessment Tables (Annexure 1), AML/CFT Compliance Assessment Template (Annexure 2) and Control Assessment Template (Annexure 3) within the period as required by the Commission from time to time.

NEW PRODUCTS AND TECHNOLOGIES:

The company provides electronic verification should also have processes that allow the Firm to record and store the information they used to verify an identity

1. Electronicverification of documentation;
2. Dataand transaction screening systems; or
3. Theuse of virtual or digital currencies

• The Company will undertake a risk assessment prior to open the account and take appropriate measures to manage and mitigate therisks.
• Thesepolicy and procedures provides governance framework to prevent the misuse of technological development in ML/TF schemes, particularly those technologies that favor anonymity. For example, securities trading and investment business on the Internet, add a new dimension to the Company’s activities. The unregulated nature of the Internet is attractive to criminals, opening up alternative possibilities for ML/TF, and fraud.
• To insulate itself against risk of anonymity of customer, Company offer an on-line account opening only after appropriate identification checks and fulfillment of its all applicable KYC requirements.
• To maintain adequate systems, the Company will ensure that its systems and procedures will bekept up to date with such developments and the potential new risks and impact they may have on the products and services offered by the Company. Risks identified must be fed into the Company business risk assessment.

3. CROSS-BORDERCORRESPONDENT RELATIONSHIP:

Cross-border correspondent relationships are the provision of services by one institution to another institution (the respondent institution). Correspondent institutions that process or execute transactions for their customer ‘s (i.e. respondent institution ‘s) customers may present high ML/TF risk and as such may require Enhanced Due Diligence (EDD).

4. CUSTOMERDUE DILIGENCE:

According to Section 21C of the Financial Intelligence Act 2001, “If an accountable institution suspects that a transaction or activity is suspicious or unusual as contemplated in section 29, and the institution reasonably believes that performing the customer due diligence requirements in terms of this section will disclose to the client that a report will be made in terms of section 29, it may discontinue the customer due diligence process and consider making a report under section 29.”.

The Company will take steps to know who their customers are. The Company as a policy matter will not open anonymous accounts or accounts in fictitious names and alias. Hence, for customers which are natural person, names contained in their national registration card or Passports will be used as title of account, and same is verified from regulatory authority record. For entities the title of account offered is same as the one contained in their establishing/incorporation document. The Company will conduct CDD, which will comprise of identification and verification of customers including beneficial owners (such that it is satisfied that it knows who the beneficial owner is), understanding the intended nature and purpose of the relationship, and ownership and control structure of the customer.

Additionally, Company will conduct ongoing due diligence on the business relationship and scrutinize transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the Company‘s knowledge of the customer, its business and risk profile (Annexure 4), including, where necessary, the source of funds. The Company will conduct CDD when establishing a business relationship if:

There is a suspicion of ML/TF, Annexure 5 gives some examples of potentially suspicious activities or ―red flags‖ for ML/TF. Although these may not be exhaustive in nature, it may help the Company to recognize possible ML/TF schemes and may warrant additional scrutiny, when encountered. The mere presence of a red flag is not by itself evidence of criminal activity. Closer scrutiny will assist in determining whether the activity is unusual or suspicious or one for which there does not appear to be a reasonable business or legal purpose; or

1. There are doubts as to the veracity or adequacy of the previously obtained customer identification information.

• Incase of suspicion of ML/TF , the Company will:

1. i)Seek to identify and verify the identity of the customer and the beneficial owner(s), irrespective of any specified threshold that might otherwise apply; and
2. ii)Filean STR with the FIC, in accordance with the requirements under the Law if the amount is equivalent or more than EU 15,000 or in foreign

Ø  The Company will monitor transactions of foreign exchange operations in cash amounting to equivalent or more than EU 3,000 or equivalent to foreign currency amount to determine whether they are linked. Transactions could be deliberately restructured into two or more transactions of smaller values to circumvent the applicable threshold.

Ø  The Company will verify the identification of a customer using reliable independent source documents, data or information including verification.

Ø  Similarly, the Company will identify and verify the customer’s beneficial owner(s) to ensure that the Company understands who the ultimate beneficial owner is.

Ø  The Company will ensure that it understands the purpose and intended nature of the proposed business relationship or transaction. The Company will assess and ensures that the nature and purpose are in line with its expectation and use the information as a basis for ongoing monitoring.

Ø  The Regulations require the Company to identify and verify the identity of any person that is purporting to act on behalf of the customer (―authorized person‖). In this regard Company will also verify whether that authorized person is properly authorized to act on behalf of the customer by demanding an authorization letter in Company’s designed pro-forma (which requires reason for using third person) and matching customer signatures against those in Company’s record. Customer Call Back confirmation will also perform where customer signatures would be doubtful. The Company will conduct CDD on the authorized person(s) using the same standards that are applicable to a customer.

Ø  When performing CDD measures in relation to customers that are legal persons or legal arrangements, the Company identifies and verifies the identity of the customer, and understands the nature of its business, and its ownership and control structure.

The purpose of the requirements set out regarding the identification and verification of the applicant and the beneficial owner is twofold: first, to prevent the unlawful use of legal persons and arrangements, by gaining a sufficient understanding of the applicant to be able to properly assess the potential ML/TF risks associated with the business relationship; and second, to take appropriate steps to mitigate the risks. In this context, the Company will identify the customer and will verify its identity. The type of information that will be needed to perform this function shall be as specified in Annexure 6.

Ø  In the case of several monetary operations which appear to be linked, the customer must be identified immediately after establishing that several monetary operations are linked. Several operations shall be considered to be linked if the customer carries out within 2 days several virtual currency exchange operations or transactions in virtual currency with funds amounting to R24,999.99 or more, or the equivalent amount in foreign or virtual currency, or carries out within 2dyas several operations of depositing virtual currency to or withdrawing virtual currency from the depository virtual currency wallet in the amount equal to or exceeding EUR 1 000, or the equivalent amount in foreign or virtual currency.

If the Company will have any reason to believe that an applicant has been refused facilities by another exchange house of digital assets due to concerns over illicit activities of the customer, it will consider classifying that applicant as higher-risk and will apply enhanced due diligence procedures to the customer and the relationship, filing an STR and/or not accepting the customer in accordance with its own risk assessments and procedures.

1. TIMINGOF VERIFICATION:

The Company will undertake verification prior to entry into the business relationship or conducting a transaction.

Where CDD checks will raise suspicion or reasonable grounds to suspect that the assets or funds of the prospective customer may be the proceeds of predicate offences and crimes related to ML/TF, the Company will decline trading accounts to such customers. In such situations, the Company will consider filing an STR with the FIC and will ensure that the customer is not informed, even indirectly, that an STR has been, is being or shall be filed.

CDD SHALL BE PERFORM FOR THE FOLLOWING OCCASIONAL TRANSACTIONS:

1. A single operation or several operations which appear to be linked or transactions the value whereof equals or exceeds EUR 15,000 or an equivalent amount in foreign currency;
2. currency exchange operations (buying or selling currency) in cash, where the amount of cash being acquired or sold amounts to or exceeds EUR 3,000 or an equivalent amount in foreign currency, whether the transaction is carried out in a single operation or in several operations which appear to be linked;
3. Virtual currency exchange operations or transactions in virtual currency the value whereof equals or exceeds R24,999.99 or an equivalent amount in foreign or virtual currency, or before depositing identified. or withdrawingvirtual currency amounting to or above EUR 1,000 or an equivalent amount in foreign or virtual currency, whether the transaction is carried out in a single operation or in several operations which appear to be linked (the value of the virtual currency is determined at the time of the monetary operation or transaction), unless the Customer and BO have already been Identified.
4. For the purposes of effective ongoing monitoring of the Business Relationship and Occasional Transactions referred and timely determination of the several related monetary operations ortransactions, the Firm has to perform Identification on the payer and the payee carrying out the transaction, and screen the payer and the payee against the relevant financial sanctions list even where the transaction is performed below the thresholds.

1. EXISTINGCUSTOMERS:

The Company will apply CDD/EDD measures to existing customers on the basis of materiality and risk, and to conduct due diligence on such existing relationships at appropriate times, taking into account whether and when CDD measures have previously been undertaken and the adequacy of data obtained. For this purpose, Company will perform CDD/EDD measures on its existing customers at the frequency as defined in the following section of Period Risk Reviews.

1. Further, if the Company will have suspicion of ML/TF or will become aware at any time that it lacks sufficient information about an existing customer, it will take steps to ensure that all relevant information is obtained as quickly as possible irrespective of CDD/EDD revised information collection frequency set as per risk classification of customer.
2. The Company will rely on the identification and verification steps that it has already

undertaken, unless it has doubts about the veracity of that information. Examples of situations that might lead Company to have doubt include significant change in the value of injections into his/her trading account, or change in correspondent address to an area / country with high susceptibility to money laundering, terrorist financing or other predicated offences.

   III.            Where the Company will be unable to complete and comply with ongoing CDD/EDD requirements as specified above, the Company will terminate the relationship. Additionally, the Company will consider filing an STR to the FIC.

REFUSAL TO ON-BOARD / TERMINATION OF A BUSINESS RELATIONSHIP OR OCCASIONAL TRANSACTIONS

In case of a new Customer, if the company is unable to fulfil its CDD obligations (e.g. verify the Customer ‘s identity) because the data or documents allowing the Identification and/or verification of a Customer or BO‘s identity, or determination of a purpose and intended nature of the Business Relationship or Occasional Transactions adhering to the criteria CDD cannot be obtained due to the fact that:

1. i)The Customer is uncooperative and/or does not provide the requested data or information necessary to perform CDD; and/or
2. ii)If there are no relevant reliable and independent sources to verify the information provided by the Customer, the company must duly assess the ML/TF risk and take appropriate measures to mitigate such risk which may include the refusal to on-board such a Customer or perform the Occasional Transaction adhering to the criteria in CDD.

The termination of the Business Relationship or Occasional Transaction adhering to the criteria specified in CDD must be taken only if it is proportionate and should be possible only after the other appropriate measures are exhausted and the Firm is still unable to comply with the AML/CFT requirements.

IDENTIFICATION AND VERIFICATION OF THE CUSTOMER WHEN THE CUSTOMER IS NOT PHYSICALLY PRESENT:

The Customer and BO can be identified and their identities verified without the Customer being physically present for identification in one of the following alternative ways:

1. whenusing the Third Party information on the Customer and BO;
2. Whenusing electronic means allowing video-streaming by one of the following methods:
3. Theoriginal of the identification document or the equivalent residence permit in South Africa

is captured through video streaming and the Customer’s identity is confirmed by at least the advanced electronic signature in line with the requirements.

1. The Customer’s facial image and the original of the identification document or the equivalent residence permit in South Africa produced by the Customer are captured by way of video-streaming,
2. incases where:

Before commencing the use of the services of the Firm, a payment order is made to the payment account of the Firm from the account held on behalf of the Customer in the credit institution which is registered in South Africa State which applies the requirements equivalent to the requirements of the Law and which is monitored by competent authorities as to the compliance with such requirements; and

TIPPING-OFF & REPORTING:

1. The Law prohibits tipping-off any information about the suspicious matter to the concerned customer or to a person not relevant in the process of filing an STR. However, a risk exists that customers could be unintentionally tipped-off when the Company is seeking to complete its CDD obligations or obtain additional information in case of suspicion of ML/TF. The applicant/customer’s awareness of a possible STR or investigation could compromise future efforts to investigate the suspected ML/TF operation.
2. Therefore, if the Company will form a suspicion of ML/TF while conducting ongoing CDD/EDD, it will take into account the risk of tipping-off when performing the CDD process. If the Company reasonably believes that performing the CDD or on-going process will tip- off the applicant/customer, it might not pursue that process, and will file an STR. For this Company will ensure that its employees are aware of, and sensitive to, these issues when conducting CDD or ongoing CDD/EDD.

NO SIMPLIFIED DUE DILIGENCE FOR HIGHER-RISK SCENARIOS:

The Company will not adopt simplified due diligence measures where the ML/TF risks are high. The Company will identify risks and have regard to the risk analysis in determining the level of due diligence to be performed in each case.

5. PERIODRISK REVIEW (“PRR”):

The Company will perform periodic customer profile updating exercise every years for customers classified as high risk while perform this exercise every four years for Low risk classified customers.

The Company will consider updating customer CDD records as a part its periodic reviews (within the timeframes set by the Company based on the level of risk posed by the customer) or on the occurrence of a triggering event, whichever is earlier. Examples of triggering events include:

1. Materialchanges to the customer risk profile or changes to the way that the account usually operates;
2. Where it comes to the attention of the Companythat it lacks sufficient or significant information on that particular customer;
3. Where a significant transaction takes place;
4. Where there is a significant change in customer documentation standards;

                         iii.            Significant changes in the business relationship.

6. ON-GOINGMONITORING OF BUSINESS RELATIONSHIPS:

Once the identification procedures will be completed and the business relationship will be established, the Company will monitor the conduct of relationship to ensure that it is consistent with the nature of business stated when the relationship/account was opened. The Company will conduct ongoing monitoring of their business relationship with their customers. Ongoing monitoring helps the Company to keep the due diligence information up-to-date, and review and adjust the risk profiles of the customers, where necessary.

The Company will conduct an on-going due diligence which will include scrutinizing the transactions undertaken throughout the course of the business relationship with a customer. Further, the Company’s risk department has put in place a weekly review mechanism which includes comparison of client deposits and available KYC/CDD clients ‘information to confirm that the clients have disclosed adequate income sources to justify the value of deposits. Where inadequacy is identified additional documents/information is obtained from the clients by sending emails and making follow-up calls. Where clients provide the required document, their profile is updated. In cases where clients do not provide the requisite information, the same is discussed with Head of Risk on a client to client basis and recommendation is made to CO for necessary course of action including re- categorization of client’s risk category and/or filing STR with FIC.

The Company will stay vigilant for any significant changes or inconsistencies in the pattern of transactions. Inconsistency is measured against the stated original purpose of the accounts and the customer updated KYC profile. Possible areas to monitor could be:

1. transactiontype;
2. frequency;
3. amount;
4. geographicalorigin/destination;
5. accountsignatories;
6. mandate

It is recognized that the most effective method of monitoring of accounts is achieved through a combination of computerized and human manual solutions. A corporate compliance culture, and properly trained, vigilant staff through their day-to-day dealing with customers, will form an effective monitoring mechanism. Hence, Company take support of the technology to the extent possible while uses manual procedures where current technology does not support certain report types and analysis. For example, screening against UNSC consolidate sanctions list is performed daily through an internally developed matching and alerts-based solution while individual transactions of customers are matched against customer profiles using Microsoft Excel spreadsheet analytical tool.

7. SIMPLIFIEDDUE DILIGENCE MEASURES (“SDD”)

According to the Financial Action Task Force guideline, the Company may conduct SDD in case of lower risks identified by it. However, the Company will ensure that the low risks is identified commensurate with the low risks identified by the country or the Commission. While determining whether to apply SDD, Company pays particular attention to the level of risk assigned to the relevant sector, type of customer or activity. The simplified measures Company will apply shall be commensurate with the low risk factors. The Company however will not use SDD procedures in higher-risk scenarios where there is an increased risk, or suspicion that the applicant is engaged in ML/TF, or the applicant is acting on behalf of a person that is engaged in ML/TF. Where the Company to take SDD measures on an applicant/customer, it will document the full rationale behind such decision and maintain its record to make it available to the Commission on request.

8. ENHANCEDCDD MEASURES (“EDD”)

According to Amendment of section 42 of Act 38 of 2001, as amended by section 27 of Act 1 of 2017 of South Africa wherein Section 42(e) of Financial Intelligence Centre Act 2001, provide for the manner in which and the processes by which the accountable institution conducts enhanced due diligence [is conducted] for higher-risk single transactions and business relationships and when simplified customer due diligence might be permitted in the institution.

The Company will examine, as far as reasonably possible, the background and purpose of all complex, unusual large transactions, and all unusual patterns of transactions, that have no apparent economic or lawful purpose. Where the risks of ML/TF are higher, or in cases of unusual or suspicious activity, the Company will conduct enhanced CDD measures, consistent with the risks identified. In particular, the Company will increase the degree and nature of monitoring of the business relationship, in order to determine whether those transactions or activities appear unusual or suspicious.

Examples of enhanced CDD measures that could be applied for high-risk business relationships include:

1. a)Obtainingadditional information on the applicant/customer (e.g. occupation, volume of assets, information available through public databases, internet, etc.).
2. b)Updatingmore regularly the identification data of applicant/customer and beneficial owner;
3. c)Obtainingadditional information on the intended nature of the business 
4. d)Obtaining additional information on the source of funds or source of wealth of theapplicant/customer.
5. e)Obtainingadditional information on the reasons for intended or performed 
6. f)Obtainingthe approval of senior management to commence or continue the business 

Conducting enhanced monitoring of the business relationship, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.

HIGH-RISK COUNTRIES:

Certain countries are associated with crimes such as drug trafficking, fraud and corruption, and consequently pose a higher potential risk to the Company. Conducting a business relationship with an applicant/customer from such a country exposes the Company to reputational risk and legal risk.

The Company will exercise additional caution and conduct enhanced due diligence on individuals and/or entities based in high-risk countries. Caution will also be exercised in respect of the acceptance of certified documentation from individuals/entities based in high-risk countries/territories and appropriate verification checks will be undertaken on such individuals/entities to ensure their legitimacy and reliability.

The Company therefore will consult publicly available information to ensure that they are aware of the high-risk countries/territories. While assessing risk of a country, the Company will also consider among the other sources, sanctions issued by the UN, the FATF high risk and non- cooperative jurisdictions, the FATF and its regional style bodies (FSRBs) and Transparency international corruption perception index. Useful websites include: FATF website at www.fatf-gafi.org and Transparency International, www.transparency.org for information on countries vulnerable to corruption. Information about these high-risk geographies will be provided to employees in on-going trainings and will be disseminated through pan-Company broadcast messages once every six months.

POLITICALLY EXPOSED PERSONS:

According to Schedule 3A to the financial Intelligence centre Act 2001 the political exposed person Is referred as:

(a)     by the substitution for the heading of the following heading: “DOMESTIC [PROMINENT INFLUENTIAL] POLITICALLY EXPOSED PERSON”; and by the substitution for the words preceding paragraph (a) of the following words:

(b)    A domestic [prominent influential] politically exposed person is an individual who [holds, including in an acting position for a period exceeding six months, or has held at any time in the preceding 12 months, in the Republic]— ‘‘;

(c)    by the substitution in paragraph (a) for the words preceding subparagraph (i) of the following words:

“holds, including in an acting position for a period exceeding six months, or has held a prominent public function in the Republic, including that of—

(d)    by the substitution in paragraph (a) for subparagraph (xiv) of the following subparagraph:

“(xiv) an officer of the South African National Defense Force above the rank of major-general; or‘‘;

(e) by the deletion of paragraph (b); and (f) by the substitution for paragraph (c) of the following paragraph: “(c) holds, including in an acting position for a period exceeding six months, or has held the position of head, or other executive directly accountable to that head, of an international organisation [based in the Republic].‘‘.

According to Schedule 3B to the Financial Intelligence Centre Act, 2001, is hereby amended— (a) by the substitution for the heading of the following heading: “FOREIGN [PROMINENT PUBLIC OFFICIAL] POLITICALLY EXPOSED PERSON‘‘; and (b) by the substitution for the words preceding paragraph (a) of the following words: “A foreign [prominent public official] politically exposed person is an individual who holds, or has held [at any time in the preceding 12 months], in any foreign country a prominent public function including that of a-”

Business relationships with individuals holding important public positions and with persons or companies clearly related to them may expose the Company to significant reputational and/or legal risk. The risk occurs when such persons abuse their public powers for either their own personal benefit and/or the benefit of others through illegal activities such as the receipt of bribes, grease money or commit fraud. Such persons, commonly referred to as PEPs and defined in the Regulations, an include inter-alia, heads of state, ministers, influential public officials, judges and senior military officials and includes their family members and close associates, hereinafter referred to as linked PEPs.

Family members of a PEP are individuals who are related to a PEP either directly (consanguinity) or through marriage or similar (civil) forms of partnership. Close associates to PEPs are individuals who are closely connected to PEP, either socially or professionally.

Provision of financial services to corrupt PEPs exposes the Company to reputational risk and costly information requests and seizure orders from law enforcement or judicial authorities. Hence, Company will remain extra vigilant in relation to PEPs from all jurisdictions, who are seeking to establish business relationships. The Company should, in relation to PEPs, in addition to performing normal due diligence measures will:

1. haveappropriate risk management systems to determine whether the customer is a PEP;
2. obtainsenior management approval for establishing business relationships with such customers; (3) take reasonable measures to establish the source of wealth and source of funds; and
3. Conductenhanced ongoing monitoring of the business relationship.

The Company will obtain senior management approval to continue a business relationship once a customer or beneficial owner is found to be, or subsequently becomes, a PEP.

The Company will take a risk-based approach to determine the nature and extent of EDD where the ML/TF risks are high. In assessing the ML/TF risks of a PEP, Company will consider factors such as whether the customer who is a PEP:

1. a)Isfrom a high-risk country;
2. b)Hasprominent public functions in sectors known to be exposed to corruption;
3. c)Hasbusiness interests that can cause conflict of interests (with the position held).

The other red flags that the Company will consider include (in addition to the above and the red flags that they consider for other applicants):

1. a)Theinformation that is provided by the PEP is inconsistent with other (publicly available) information, such as asset declarations and published official salaries;
2. b)Fundsare repeatedly moved to and from countries to which the PEP does not seem to have ties;
3. c)APEP uses multiple bank accounts for no apparent commercial or other reason;
4. d)ThePEP is from a country that prohibits or restricts certain citizens from holding accounts or owning certain property in a foreign country.

The Company will take a risk-based approach in determining whether to continue to consider a customer as PEP who is no longer PEP. The factors that they should consider include:

1. a)thelevel of (informal) influence that the individual could still exercise; and
2. b)Whether the individual ‘s previous and current function are linked in any way (e.g., formally byappointment of the PEPs successor, or informally by the fact that the PEP continues to deal with the same substantive matters).

RECORD-KEEPING PROCEDURES:

The Company will ensure that all information obtained in the context of CDD is recorded. This includes both;

1. i)recording the documents, the Company is provided with when verifying the identity of the customer or the beneficial owner, and
2. ii)Transcriptioninto the Company owns IT systems of the relevant CDD information contained in such documents or obtained by other means.

The Company will maintain, for at least five years after termination, all necessary records on transactions to be able to comply swiftly with information requests from the competent authorities. Such records should be sufficient to permit the reconstruction of individual transactions, so as to provide, if necessary, evidence for prosecution of criminal activity.

Where there has been a report of a suspicious activity or the Company becomes aware of a continuing investigation or litigation into ML/TF relating to a customer or a transaction, records relating to the transaction or the customer will be retained until confirmation is received from the relevant authority in writing that the matter has been concluded.

The Company will also keep records of identification data obtained through the customer due diligence process, account files and business correspondence that would be useful to an investigation for a period of five years after the business relationship has ended. This includes records pertaining to enquiries about complex, unusual large transactions, and unusual patterns of transactions. Identification data and transaction records should be made available to relevant competent authorities upon request.

Beneficial ownership information will be maintained for at least five years after the date on which the customer (a legal entity) is dissolved or otherwise ceases to exist, or five years after the date on which the customer ceases to be a customer of the Company.

Records relating to verification of identity will generally comprise:

1. a)adescription of the nature of all the evidence received relating to the identity of the verification subject; and
2. b)the evidence itself or a copy of it or, if that is not readily available, information reasonably sufficient to obtain such a copy. Records relating to transactions will generally comprise:
3. detailsof personal identity, including the names and addresses, of
4. a)thecustomer; and
5. b)thebeneficial owner of the account or product
6. detailsof securities and investments transacted including: a. the nature of such securities/investments;
7. valuation(s)and price(s);
8. memorandaof purchase and sale;
9. source(s)and volume of funds and securities;
10. destination(s)of funds and securities;
11. memorandaof instruction(s) and authority(ies);
12. bookentries;
13. custodyof title documentation;
14. thenature of the transaction;
15. thedate of the transaction;
16. Theform (e.g. cash, cheques) in which funds are offered and paid out.

REPORTING OF SUSPICIOUS TRANSACTIONS / CURRENCY TRANSACTION REPORT

According to Section 52 of Financial Intelligence Act 2001 clause 4 states that:

An accountable institution, reporting institution or any other person that reasonably ought to have known or suspected that any of the facts referred to in section 29(1)(a), (b) or (c) or section 29(2) exists, and who negligently fails to report the prescribed information in respect of a suspicious or unusual transaction, 5, 10 15 19, 20, 25, 30, 35, 40, 45, 50, 55, or series of transactions or enquiry, is non-compliant and is subject to an administrative sanction.

A suspicious activity will often be one that is inconsistent with a customer’s known, legitimate activities or with the normal business for that type of account. Where a transaction is inconsistent in amount, origin, destination, or type with a customer's known, legitimate business or personal activities, the transaction will be considered unusual, and Company will put the case “on enquiry”. The Company will also pay special attention to all complex, unusual large transactions, and all unusual patterns of transactions, which have no apparent economic or visible lawful purpose.

Where the enquiries conducted by the Company do not provide a satisfactory explanation of the transaction, it may be concluded that there are grounds for suspicion requiring disclosure and escalate matters to the CO.

Enquiries regarding complex, unusual large transactions, and unusual patterns of transactions, their background, and their result will be properly documented, and made available to the relevant authorities upon request. Activities which will require further enquiry may be recognizable as falling into one or more of the following categories. This list is not meant to be exhaustive, but includes:

1. a)anyunusual financial activity of the customer in the context of the customer’s own usual activities;
2. b)anyunusual transaction in the course of some usual financial activity;
3. c)anyunusually-linked transactions;
4. d)anyunusual method of settlement;
5. e)anyunwillingness to provide the information 

Where cash transactions are being proposed by customers, and such requests are not in accordance with the customer's known reasonable practice, the Company will need to approach such situations with caution and make further relevant enquiries. Company will set its own parameters at R24,999.99 or equivalence to the foreign currency amount for the identification and further investigation of cash transactions.

Where the Company will be unable to satisfy that any cash transaction is reasonable it will be considered as suspicious. The Company will also be obligated to file Currency Transaction Report (―CTR‖), to FIC for a cash based transaction involving payment.

The process for identifying, investigating and reporting suspicious transactions to the FIC is clearly specified in the Company’s KYC/CDD SOPs and communicated to all personnel through regular training.

The Company will also be required to report total number of STRs filed to the Commission on a bi- annual basis within seven days of close of each half year. The CO will ensure prompt reporting in this regard.

The Company will evolve a vigilance system for the purpose of control and oversight, which requires maintenance of a register of all reports made to the FIC. Such registers will be maintained and updated by CO and will contain details of:

1. a)thedate of the report;
2. b)theperson who made the report;
3. c)theperson(s) to whom the report was forwarded; and
4. d)Referenceby which supporting evidence is 

The Company as a matter of policy will turn away business where an applicant or a customer is hesitant/fails to provide adequate documentation (including the identity of any beneficial owners or controllers), consideration will be given to filing an STR to the FIC For existing customers, once suspicion has been raised in relation to an account or relationship, in addition to reporting the suspicious activity, the Company will ensure that appropriate action is taken to adequately mitigate the risk of the Company being used for criminal activities. This will include a review of either the risk classification of the customer or account or of the entire relationship itself. In such cases an escalation will be made to the Chief Executive Officer to determine how to handle the relationship, taking into account any other relevant factors, such as cooperation with law enforcement agencies or the FIC.

SANCTIONS COMPLIANCE

The company always take care to obliged to comply with the national, Financial Intelligence Centre, United Nations sanctions regime in accordance to the Law on the Implementation of Economic and Other Sanctions of the Republic of South Africa and its implementing legal acts, in particular, with the Instructions on the Supervision of the Appropriate Implementation of International Financial Sanctions in the Field of Regulation of the Financial Crime Investigation Service and In accordance with Section 50 of FIC ,2001 of clause 2 states that ― An accountable institution, reporting institution or any other person that fails to inform the Centre in accordance with section 27 is non-compliant and is subject to an administrative sanction.

According to Section 52 of FIC, 2001 states that (3)) An accountable institution, reporting institution or any other person that fails, within the prescribed period, to report to the Centre the prescribed information in respect of a suspicious or unusual transaction or series of transactions or enquiry in accordance with section 29(1) or (2), is non-compliant and is subject to an administrative sanction. (4) An accountable institution, reporting institution or any other person that reasonably ought to have known or suspected that any of the facts referred to in section 29(1)(a), (b) or (c) or section 29(2) exists, and who negligently fails to report the prescribed information in respect of a suspicious or unusual transaction or series of transactions or enquiry, is non-compliant and is subject to an administrative sanction. ‘‘.

AFRIONE must screen the Customer, the person performing the Occasional Transactions, the Customer’s representative, the persons that make up the Customers ownership structure and its BO against the relevant sanctions lists. When the Customer performs a monetary operation or transaction as a part of the Business Relationship or performs Occasional Transactions, the company will always screen both parties of the monetary operation or transaction, as well as screen the other payment details (in case a payment is made), against the sanctions lists.

The company must screen its clients against the relevant sanctions list not only upon the on-boarding, but the company’s Customer base should also be periodically, at least every day, screened against the relevant sanctions list to ensure the correct implementation thereof. The screening of the Customer base must include the screening of the Customer, its representative, the persons that make up the Customer’s ownership structure and the BO.

The AFRIONE must screen the relevant parties against at least the following sanctions list:

1. Theconsolidated list of individuals, groups and entities subject to financial sanctions;
2. TheUnited Nations Security Council sanctions list;
3. TheOffice of Foreign Assets Control (OFAC) sanctions list.

Company chooses to use automated checks for the sanctions screening, they should ensure that relevant software includes checks against the lists relevant to the Firm and that such lists are kept up to date. The types of sanctions that may be imposed include:

1. a)targeted sanctions focused on named persons or entities, generally freezing assets and prohibitingmaking any assets available to them, directly or indirectly;
2. b)economicsanctions that prohibit doing business with, or making funds or economic resources available to, designated persons, businesses or other entities, directly or indirectly;
3. c)currencyor exchange control;
4. d)armsembargoes, which would normally encompass all types of military and paramilitary equipment;
5. e)prohibitinginvestment, financial or technical assistance in general or for particular industry sectors or territories, including those related to military or paramilitary equipment or activity;
6. f)importand export embargoes involving specific types of goods (e.g. oil products), or their

movement using aircraft or vessels, including facilitating such trade by means of financial or technical assistance, brokering, providing insurance etc.; and (7) visa and travel bans.

1. g)Targetedfinancial sanctions relating to the prevention, suppression and disruption of proliferation of Weapons of Mass Destruction (WMD) and its financing.

As required by Regulations Company will screen all its customers against consolidated sanctions list available on UNSC’s website and will decline business relationship with the individuals/entities and their associates that are either, sanctioned under UNSC Resolutions adopted by Afghanistan or proscribed under the Anti-Terrorism Act, 1997.

The UNSC Resolution 1267 (1999), 1989 (2011), 2253 (2015) and other subsequent resolutions, which impose sanctions covering; asset freeze, travel ban and arms embargo, against individuals and entities associated to Al- Qaida, Taliban, and the Islamic State in Iraq (Daésh) organizations. The regularly updated consolidated lists are available at the UN sanctions committee‘s website, at following link;https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list The UNSC Resolution 1373 (2001), 1998 (2011) on terrorism and financing of terrorism requiring member states to proscribe individual and entities, who commit or attempt to commit terrorist act, freeze without delay the funds and other financial assets or economic resources, and prohibit making any funds or financial or other related services available to such proscribed persons and entities.

The UNSC Resolution 1718(2006), 2231(2015) and its successor resolutions ¹ on proliferation of WMD and its financing, and Targeted Financial Sanctions (TFS) on countries and specifically identified individual and entities associated with it. The resolution requires, inter-alia freezing without delay the funds or other assets of, any person or entity designated, or under the authority of UNSC. The regularly updated consolidated lists of person and entities designated under UNSCRR 1718(2006) and its successor resolutions (on the DPRK) and listed under UNSCR 2231 (2015) (on Iran) is available at the UN sanctions committee‘s website, at following link; https://www.un.org/sc/suborg/en/sanctions/1718/materials |https://www.un.org/sc/2231/list.shtml

The Company will, taking note of the circumstances where customers and transactions are more vulnerable to be involved in TF and PF activities², identify high-risk customers and transactions, and apply enhanced scrutiny. Company will conduct checks on the names of potential and new customers, as well as regular checks on the names of existing customers, beneficial owners, transactions, and other relevant parties against the names in the abovementioned lists, to determine if the business relations involve any sanctioned person/entity, or person associated with a sanctioned person/entity/country.

The Company will also screen its entire customer database when the new names are listed through UNSC Resolution or the domestic NACTA list. Company will undertake reasonable efforts to collect additional information in order to identify, and avoid engaging in prohibited activities and, to enable follow-up actions.

Where there is a true match or suspicion, Company will take steps that are required to comply with the sanction’s obligations including immediately –

1. Freezewithout delay³ the customer’s fund or block the transaction, if it is an existing customer;
2. Rejectthe customer, if the transaction has not commenced;
3. Lodgea STR with the FIC; and (d) notify the FIC.

The Company will submit an STR when there is an attempted transaction by any of the listed persons. The Company will ascertain potential matches with the UN Consolidated List to confirm whether they are true matches to eliminate any ―false positives‖. The reporting institution must make further enquiries from the customer or counter-party (where relevant) to assist in determining whether it is a true match. In case there is not 100% match but sufficient grounds of suspicion that customer/ funds belong to sanctioned entity/ individual, the Company will consider raising an STR to FIC. Notwithstanding the funds, properties or accounts are frozen, Company will continue receiving dividends, interests, or other benefits, but such benefits shall still remain frozen, so long as the individuals or entities continue to be listed.

The Company will make their sanctions compliance program an integral part of their overall AML/CFT compliance program and accordingly should have policies, procedures, systems and controls in relation to sanctions compliance. Company will provide adequate sanctions related training to their staff. When conducting risk assessments, Company will take into account any sanctions that may apply (to customers or countries).

The obligations/ prohibitions regarding proscribed entities and persons mentioned in the above lists are applicable, on an ongoing basis, to proscribed/ designated entities and persons or to those who are known for their association with such entities and persons, whether under the proscribed/ designated name or with a different name. Therefore, to mitigate the risk of having a sanctioned individual / entity in the portfolio of customer Company has implemented an in-house solution to screen the updated customer portfolio against Alerts are raised by the system on daily basis, which are reviewed and closed by CO on daily basis. Where there is a true match or suspicion, the CO raise the matter with the CEO with his proposal to comply with sanctions obligations including freeze without delay and without prior notice, the funds or other assets of designated persons and entities and reporting to the Commission.

The Company will document and record all the actions that have been taken to comply with the sanctions regime, and the rationale for each such action. The Company will keep track of all the applicable sanctions, and where the sanction lists are updated, shall ensure that existing customers are not listed. The Company will also educate its customers that in case of wrongful or inadvertent freezing, they may apply in writing for de-listing to Federal Government through relevant Ministry or to the UN’s Ombudsman, as the case may be.

INTERNAL CONTROLS (AUDIT FUNCTION, OUTSOURCING, EMPLOYEE SCREENING AND TRAINING)

The Company will put in place systems and controls that are comprehensive and proportionate to the nature, scale and complexity of its activities and the ML/TF risks they identified. The Company will establish and maintain internal controls in relation to:

1. anindependent internal audit function to test the AML/CFT systems, policies and procedures;
2. outsourcingarrangements;
3. employeescreening procedures to ensure high standards when hiring employees; and
4. anappropriate employee training program.

INTERNAL AUDIT FUNCTION:

The Company will, on a regular basis, conduct an AML/CFT audit to independently evaluate the effectiveness of compliance with AML/CFT policies and procedures. The frequency of the audit will be determined through annual risk assessment exercise and will commensurate with the Company nature, size, complexity, and risks identified during the risk assessments. The scope of AML/CFT audits will cover assessment of the AML/CFT systems which include:

1. testingthe overall integrity and effectiveness of the AML/CFT systems and controls;
2. assessingthe adequacy of internal policies and procedures in addressing identified risks, including; (a) CDD measures; Record keeping and retention;
3. Thirdparty reliance; and
4. Transactionmonitoring;
5. assessingcompliance with the relevant laws and regulations;
6. testing transactions in all areas of the Company, with emphasis on high–risk areas, products and services; (5) assessing employees ‘knowledge of the laws, regulations, guidance, and policies & procedures and their effectiveness in implementing policies and procedures;
7. assessingthe adequacy, accuracy and completeness of training programs;
8. assessingthe effectiveness of compliance oversight and quality control including parameters for automatic alerts (if any), and
9. Assessing theadequacy of the Company’s process of identifying suspicious activity including screening sanctions lists.

OUTSOURCING

The Company will maintain policies and procedures in relation to outsourcing where it intends to outsource some of its functions. The Company will conduct the due diligence on the proposed service provider to whom it intends to outsource as appropriate and also ensure that the outsourced service provider (―OSP‖) is fit and proper to perform the activity that is being outsourced.

Where the Company decides to enter into an outsourcing arrangement, the Company will ensure that the outsourcing agreement clearly sets out the obligations of both parties. The Company while entering into an outsourcing arrangement will develop a contingency plan and a strategy to exit the arrangement in the event that the OSP fails to perform the outsourced activity as agreed.

The AFRIONE will report regularly to the Company within the timeframes as agreed upon with the Company. The Company will have access to all the information or documents relevant to the outsourced activity maintained by the OSP. The Company as a matter of policy will not enter into outsourcing arrangements where access to data without delay is likely to be impeded by confidentiality, secrecy, privacy, or data protection restrictions.

Further, the Company will ensure that the outsourcing agreement require OSPs to file a STR with the FIC in case of suspicions arising in the course of performing the outsourced activity.

EMPLOYEE SCREENING

The Company’s policy and procedures with regards to screening prospective and existing employees to ensure abidance with high ethical and professional standards are defined in these sections. The extent of employee screening will be proportionate to the particular risks associated with the individual positions.

Employee screening will be conducted at the time of recruitment and periodically thereafter, i.e., at least annually and where a suspicion has arisen as to the conduct of the employee.

The Company will ensure that their employees are competent and proper for the discharge of the responsibilities allocated to them. While determining whether an employee is fit and proper, the Company will:

1. referencesprovided by the prospective employee at the time of recruitment;
2. Verifythe employee’s employment history, professional membership and qualifications from his resume and original copies of education documents.
3. Verifydetails of any regulatory actions or actions taken by a professional body;
4. Verifydetails of any criminal convictions; if possible and
5. Verifywhether the employee has any connections with the sanctioned countries or parties.

EMPLOYEE TRAINING

The Company will ensure that all staff, receive training on ML/TF prevention on a regular basis, ensure all staff fully understands the procedures and their importance, and ensure that they fully understand that they will be committing criminal offences if they contravene the provisions of the legislation.

Training to staff will be provided at least annually, or more frequently where there are changes to the applicable legal or regulatory requirements or where there are significant changes to the Company’s business operations or customer base.

The Company will provide their staff training in the recognition and treatment of suspicious activities. Training will also be provided on the results of the Company’s risk assessments. Additionally, this training will be structured to ensure compliance with all of the requirements of the applicable legislations pertaining to AML/CFT.

Training material will be designed to ensure staff is aware on the AML/CFT legislation and regulatory requirements, systems and policies. Additionally, focus will be given on the consequences should they fail to report information in accordance with internal procedures and legislation. One of the key focus of these training program will be active coordination with customers and CO whereby all staff will be encouraged to provide a prompt and adequate report of any suspicious activities to the CO for inward reporting to FIC

To make staff more accountable towards AML/CFT requirements, Company will obtain an undertaking from its staff members (both new and existing) confirming that they have attended the training on AML/CFT matters, read the Company’s AML/CFT manuals, policies and procedures, and understand the AML/CFT obligations under the relevant legislation.

The Company is cognizant of the fact that all information regarding a potential or existing customer is not available on systems or on public domain immediately and human interaction plays an important role in identifying such information. Staff members who deal with the public such as traders are the first point of contact with potential money launderers, and their efforts are vital to an organization's effectiveness in combating ML/TF. Staff responsible for opening new accounts or dealing with new customers should be aware of the need to verify the customer's identity, for new and existing customers. Training will be given on the factors which may give rise to suspicions about a customer's activities, and actions to be taken when a transaction is considered to be suspicious.

Staff involved in the processing of transactions will receive relevant training in the verification procedures, and in the recognition of abnormal settlement, payment or delivery instructions. The training curriculum will contain information on types of suspicious activities which may need reporting to the relevant authorities regardless of whether the transaction was completed. Staff will also be made aware of the correct procedure(s) to be following in such circumstances.

The Company expects all staff to be vigilant in circumstances where a known, existing customer opens a new and different type of account, or makes a new investment e.g. a customer with a personal account opening a business account. In such cases whilst the Company may have previously obtained satisfactory identification evidence for the customer, the Company will take steps to learn as much as possible about the customer's new activities.

Although Directors and Senior Managers may not be involved in the handling of ML/TF transactions, it is important that they understand the statutory duties placed upon them, their staff and the Company itself given that these individuals are involved in approving AML/CFT policies and procedures. Hence the supervisors, managers and senior management (including the Board) will receive a higher level of training covering all aspects of AML/CFT procedures, including the offences and penalties arising from the relevant primary legislation for non-reporting or for assisting money launderers, and the requirements for verification of identity and retention of records.

The CO will himself receive in-depth training on all aspects of the primary legislation, the Regulations, regulatory guidance and relevant internal policies. It will include appropriate initial and ongoing training on the investigation, determination and reporting of suspicious activities, on the feedback arrangements and on new trends of criminal activity.

PROCEDURE FOR ENHANCE DUE DILIGENCE:

To address the assessed ML/TF risk following controls are implemented and methods are used for high risk clients;

1. KYC/CDDprocess is performed for each client which includes the following;

Ø  Approval from senior management for enhanced due diligence

Ø  Biometric/face verification of the customer.

Ø  Verification of customer’s identity

Ø  Validation of identity documents (Soft/Hard Copy)

Ø  Full name as per identity document;

Ø  Father/Spouse Name as per identity document;

Ø  Mother Maiden Name;

Ø  Identity document number along with date of issuance and expiry;

Ø  Existing residential address (if different from CNIC);

Ø  Contact telephone number(s) and e-mail (as applicable);

Ø  Nationality-Resident/Non-Resident Status

Ø  FATCA/CRS Declaration wherever required;

Ø  Date of birth, place of birth;

Ø  Incorporation or registration number (as applicable);

Ø  Date of incorporation or registration of Legal Person/ Arrangement;

Ø  Registered or business address (as necessary);

Ø  Nature of business, geographies involved and expected type of counter-parties (as applicable);

Ø  Type of account/financial transaction/financial service;

Ø  Profession / Source of Earnings/ Income: Salary, Business, investment income;

Ø  Purpose and intended nature of business relationship;

Ø  Expected monthly turnover (amount and No. of transactions); and

Ø  Normal or expected modes of transactions/ Delivery Channels.

Ø  Verification of customer’s mailing and permanent addresses

Ø  Verification of customer’s source of income with supporting documents

Ø  Identification of beneficial owner

1. i)In case of a salaried person, in addition to customer domicile of South African citizen or passport along with a copyof his salary slip or service card or certificate or letter on letter head of the employer will be 
2. ii)For Customer registration number[CRN] which expire during the course of the customer’s relationship, regulated person shall design/ update their systems which can generate alerts about the expiry of CRN at least 01 months before actual date of expiry and shall continue to take reasonable measures to immediately obtain copies of renewed CRN.

iii)    The condition of obtaining Board Resolution is not necessary for foreign companies/entities belonging to countries where said requirements are not enforced under their laws/regulations. However, such foreign companies will have to furnish Power of Attorney from the competent authority for establishing Business Relationship to the satisfaction of the regulated person.

1. iv)The condition of obtaining photocopies of identity documents of directors of Limited Companies/Corporationsis relaxed in case of Government/Semi Government entities, where regulated person should obtain photocopies of identity documents of only those directors and persons who are authorized to establish and maintain Business Relationship. However, regulated person shall validate identity information including CRN numbers of other directors from certified copies of article of Association, Article of Memorandum and pattern of shareholding.
2. v)Government entities accounts shall not be opened in the personal names of a government official. Any account which is to be operated by an officer of the Federal or Provincial or Local Government in his/her official capacity, shall be opened only on production of a special resolution or authority from the concerned administrative department or ministry duly endorsed by the Ministry of Finance or Finance Department/Division of the concerned Government.

Explanation: - For the purposes of this regulation the expression ―Government entities‖ includes a legal person owned or controlled by a Provincial or Federal Government under Federal, Provincial or local law.

Screening of customers through UN sanctions committee’s website, National Counter Terrorism Authority’s website and different SROs issued by the Federal Government.

Ongoing monitoring of the clients which includes monitoring of their trading activities and their receipts and payments, etc. Enhanced Due Diligence (EDD) process in which more documentary evidences are obtained from the customers to verify their source of income, etc.

CONTACT INFORMATION 

Any questions or suggestions about this Privacy Policy should be addressed via email to: “afrione@afrionebank.africa

This notice is reviewed intermittently and may be updated at any time. We are regulated by the Information Commissioner’s Office You can contact them for advice and support.

Thank you

Compliance Department.

2 Baanbreker Avenue, Helderkruin, Roodepoort South Africa

AFRIONE INVEST – EVERYONE IS BANKABLE

AGREEMENT FOR CAMPAIGN CREATION ON AFRIONE INVEST CROWDFUNDING PLATFORM

This Agreement is made and entered into on the date of submission of a crowdfunding campaign application (the "Effective Date") between AfriOne Invest (referred to as "AfriOne") and the campaign creator (the "Applicant"). By signing and agreeing to this document, the Applicant agrees to abide by the terms and conditions outlined below regarding their campaign and its relationship with AfriOne's key initiatives.

1. PREAMBLE:

AfriOne Invest is committed to fostering a culture of giving back, where businesses and individuals seeking funding through our platform also contribute to sustainable initiatives that benefit communities and drive African growth and development. To create a healthy and reciprocal ecosystem, all applicants are required to support any of the following initiatives in order to have their campaigns approved:

• The AfriOne Foundation
• The AfriOne Innovation Hub
• Return and Reintegration Support

This contribution represents a symbolic investment in the future of Africa, acknowledging that business is a shared responsibility and must contribute to the greater good.

2. MANDATORY CONTRIBUTION:

The Applicant agrees to donate a non-refundable fee of R250 or more to one of the following AfriOne initiatives as part of the campaign approval process:

• AfriOne Innovation Hub: Supporting entrepreneurs, innovators, and startups with access to resources, mentorship, and workspace to drive innovation and technological advancement in Africa.
• The AfriOne Foundation: Focusing on education, health, and community development, providing support to vulnerable communities and ensuring access to vital services and empowerment opportunities.
• Return and Reintegration Support: Assisting Africans returning from the diaspora to reintegrate successfully into their communities by providing resources, skills, and financial assistance to foster sustainable growth and stability.

3. WHY, PURPOSE AND BENEFIT OF CONTRIBUTION:

At AfriOne Invest, we believe in shared responsibility and the power of community-driven success. While you seek funding for your business or project, it is vital to also contribute to the greater ecosystem that nurtures the very success you aim to achieve. By donating to these initiatives, you are investing in Africa's future—just as others will invest in your vision. We value reciprocity and believe that the best way to build a thriving continent is by giving back as you receive.

As an applicant seeking funding on AfriOne Invest, it is essential to recognize that the crowdfunding ecosystem operates on a foundation of reciprocity.  The contribution of a minimum of R250 or more is a gesture of goodwill and support for the system from which you seek to benefit. We are committed to supporting entrepreneurs, innovators, and communities across Africa through the AfriOne Invest platform. However, we believe that to receive support from a community, it is equally important to contribute back to that same community. Here’s why:

• Fostering Collective Growth: When you support initiatives such as the AfriOne Innovation Hub, The AfriOne Foundation, or Return and Reintegration Support, you are contributing to a system that exists to uplift others—just as you seek to be uplifted. This creates a cycle of giving and receiving, benefitting all members of our community.
• Empowering the AfriOne Ecosystem: Your contribution will help drive innovation, support charitable work, and assist those reintegrating into society. By investing in these initiatives, we strengthen our collective resources, improve opportunities for everyone, and ensure the long-term sustainability of our platform.
• Shared Responsibility and Commitment: As a businessperson seeking funding, it’s important to acknowledge the value of giving into the same system from which you seek support. By contributing, you demonstrate a commitment to the AfriOne community and its goals, aligning with our principles of unity, innovation, and shared responsibility.
• Empower Communities: Contributing to these initiatives helps to create a sustainable support system that nurtures innovation, supports vulnerable communities, and enables the return of skills and talent to Africa.
• Strengthen Your Campaign: By supporting these causes, you are aligning your campaign with the values of community building, corporate responsibility, and sustainable development, which can attract more backers and provide credibility to your efforts.
• Create Mutual Benefit: As a businessperson, investing in initiatives that uplift others also enhances the environment from which you seek support. By giving to a system that supports you, you help to foster a community-driven economy that benefits everyone involved.

4. NON-REFUNDABLE FEE:

The initiation fee of R250 or more is non-refundable, regardless of whether the campaign reaches its funding goal or not. This fee serves as an acknowledgment that all business efforts, including crowdfunding, require investment and commitment, not only to the individual but to the broader ecosystem that supports the growth and development of Africa.

5. CONSEQUENCES OF NON-COMPLIANCE:

Campaigns that do not comply with the donation requirement will “not be approved”. AfriOne Invest reserves the right to reject any campaign that does not support one of the three listed initiatives. Campaign approval is contingent upon the Applicant making the required donation.

6. PROCESS FOR DONATION:

- The Applicant will select one of the three initiatives listed above during the campaign submission process.

- The donation will be processed at the time of campaign application.

- A receipt will be issued confirming the donation and compliance with this agreement.

7. ACKNOWLEDGMENT:

By signing up as a campaign creator, you have already this agreement, the Applicant acknowledges the importance of supporting initiatives that align with the values of AfriOne Invest and the greater African community. The Applicant understands that the non-refundable donation is a mandatory part of the campaign approval process and agrees to make the required contribution in order to proceed with the campaign.

8. GOVERNING LAW:

This Agreement shall be governed by and construed in accordance with the laws of South Africa. Any disputes arising from or related to this Agreement shall be resolved in the courts of South Africa.

Thank you for your understanding and support. Together, we can create a brighter and more sustainable future for all.