1- Preamble

As per the RBI Master Direction - Know Your Customer (KYC) Direction, 2016 updated from time to time wherein Non-Banking Finance Companies (NBFCs) are advised to follow certain customer identification procedures while undertaking a transaction either by establishing an account-based relationship or otherwise and monitor their transactions.NBFCs are required to put in place a comprehensive policy framework, duly approved by the Board of Directors or competent authority authorized by the Board of Directors, in this regard. This policy document has been prepared in line with the RBI guidelines.

Know Your Customer' Standards
The Company has framed its KYC policy incorporating the following four key elements:

1. Customer Acceptance Policy
2. Customer Identification Procedures
3. Monitoring of Transactions; and
4. Risk Management

For the purpose of the KYC policy, a ‘Customer' is defined as:

For the purpose of Aurum Capital Projects Limited, KYC policy Customer means a person who is engaged in a financial transaction or activity with the Company and includes a person on whose behalf the person who is engaged in the transaction or activity, is acting. A person has the same meaning assigned in the Prevention of Money- Laundering Act, 2002 and includes:

1. An individual,
2. Hindu undivided family,
3. A company,
4. A firm,
5. An association of persons or a body of individuals, whether incorporated or not,
6. Every artificial juridical person, not falling within any one of the above persons (1 to 5), and

Any agency, office or branch owned or controlled by any of the above persons (1 to 6).

I. Customer Acceptance Policy (CAP)

The guidelines for Customer Acceptance Policy (CAP) for the Company are as follows.

No account may be opened in an anonymous or fictitious/ benami name(s).
The Company shall classify customers into various risk categories and based on risk perception decide on the acceptance criteria for each customer category.
Accept customers only after verifying their identity as laid down in the customer identification procedures.
While carrying out due diligence the Company will ensure that the procedures adopted will not result in the denial of services to genuine customers.
For the purpose of risk categorization of customers, the Company shall obtain the relevant information from the customer at the time of account opening.

II. Customer Identification Procedures (“CIP”)

Customer identification means identifying the customer and verifying its identity by using reliable, independent source documents, data or information. The company shall obtain sufficient information necessary to verify the identity of each new customer along with brief details of its promoters and management, whether regular or occasional and the purpose of the intended nature of the business relationship. The requirement as mentioned herein may be moderated according to the risk perception; for example, in the case of a public listed company it will not be necessary to identify all the shareholders.

III. Monitoring and reporting of Transactions:

Monitoring of transactions will be conducted taking into consideration the risk profile of the account.The company shall make endeavors to understand the normal and reasonable activity of the customer so that the transactions that fall outside the regular/pattern of activity can be identified, Special attention will be paid to all complex, unusually large transactions and all unusual patterns, which have no apparent economic or visible lawful purpose. Background of the customer, country of origin, sources of funds, the type of transactions involved and other risk factors shall determine the extent of monitoring.

The company shall explore the possibility of validating the new accounts opening application with various watch lists available in the public domain, including the RBI watch list. After due diligence, any transactions of a suspicious nature will be duly reported by a principal officer to Director, Financial Intelligence Unit- India (FIU-IND). To ensure monitoring and reporting of all transactions and sharing of information as required under the law for KYC, the Board may nominate any Director or authorized any other officer(s) to be designated as company’s Principal Officer with respect to KYC/ AML/ CFT.

IV. RISK MANAGEMENT

The Board of Directors of the Company ensures that an effective KYC program is put in place by establishing appropriate procedures and ensuring their effective implementation. It will cover proper management oversight, systems and controls, segregation of duties, training and other related matters. Responsibility would be explicitly allocated within the Company for ensuring that the Company’s policies and procedures are implemented effectively. The Company may, in consultation with its board, devise procedures for creating Risk Profiles of its existing and new customers and apply various Anti Money Laundering measures keeping in view the risks involved in a transaction, account or business relationship. The Company’s internal audit and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures. As a general rule, the compliance function provides an independent evaluation of the Company’s own policies and procedures, including legal and regulatory requirements. Concurrent/ internal auditors should specifically check and verify the application of KYC procedures and comment on the lapses observed in this regard. The compliance in this regard may be put up before the Audit Committee of the Board on quarterly intervals. The Company has an ongoing employee training program so that the members of the staff are adequately trained in KYC procedures. Training requirements will have different focuses for frontline staff, compliance staff and staff dealing with new customers. It is crucial that all those concerned fully understand the rationale behind the KYC policies and implement them consistently.

V. Customer Education:

Implementation of KYC procedures requires the Company to demand certain information from customers which may be of a personal nature or which have hitherto never been called for. This can sometimes lead to a lot of questioning by the customer as to the motive and purpose of collecting such information. The Company will prepare specific literature/ pamphlets etc. so as to educate the customer on the objectives of the KYC program. The front desk staff needs to be specially trained to handle such situations while dealing with customers.

VI. Introduction of New Technologies

The Company will pay special attention to any money laundering threats that may arise from new or developing technologies including internet transactions that might favor anonymity, and take measures, if needed, to prevent their use in money laundering schemes.

VII. Employees Training/Hiring of Employees:

The company shall have a suitable training program for employees so that the team members are adequately trained in KYC/ AML/ CFT procedures. Training requirements shall have different focuses for staff dealing with the KYC matters.

VIII. Appointment of Principal Officer

To ensure the monitoring and reporting of all transactions and sharing of information as required under Rule 7 of the Prevention of Money Laundering (Maintenance of Records etc.) 2005.
Principal Officer for KYC will act independently and report directly to the concerned Director/MD/CMD or to the Board of Directors.
Principal Officer shall be located at the head office of the company.
Principal Officer shall be responsible for monitoring and reporting of all transactions and sharing of information as required under the law.
He/ She will maintain close liaison with enforcement agencies, The company and any other institution which are involved in the fight against money laundering and combating financing of terrorism.
Further, the role and responsibilities of the Principal Officer shall include overseeing and ensuring overall compliance with regulatory guidelines on KYC/AML/CFT issued from time to time and obligations under the Prevention of Money Laundering Act, 2002, rules and regulations made there under, as amended form time to time.
The Principal Officer will also be responsible for timely submission of CTR, STR to FIU-IND.
With a view to enabling the Principal Officer to discharge his responsibilities effectively, the Principal Officer and other appropriate staff shall have timely access to customer identification data and other CDD information, transaction records and other relevant information.

IX. Maintenance of records of transactions

The company has a system of maintaining proper record of transactions prescribed under Rule 3, of the Prevention of Money-Laundering and value of transactions, the procedure and manner of maintaining and verification and maintenance of records of the identity of the clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005, as mentioned below:

All cash transactions of the value of more than rupees ten lakhs or its equivalent in foreign currency;
All series of cash transactions integrally connected to each other which have been valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the aggregate value of such transactions exceeds rupees ten lakh;
All cash transactions were forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security has taken place;
All suspicious transactions whether or not made in cash and by way of as mentioned in the Rules.

X. Information to be preserved

As per the NBFC guidelines, The company is required to maintain the following information in respect of transactions referred in Rule 3:

The nature of the transactions;
The amount of the transaction and the currency in which it was denominated;
he date on which the transaction was conducted; and
The parties to the transaction.

XI. Maintenance and Preservation of records

The companyhas a system for proper maintenance and preservation of account information in a manner that allows data to be retrieved easily and quickly whenever required or when requested by the competent authorities. The companywill maintain for at least ten years from the date of cessation of transaction between the companyand the client, all necessary records of transactions, both domestic or international, which will permit reconstruction of individual transactions (including the amounts and types of currency involved if any) so as to provide, if necessary, evidence for prosecution of persons involved in criminal activity.The company will also ensure that records pertaining to the identification of the customer and his / her address (e.g. copies of documents like passports, identity cards, driving licenses, PAN, utility bills etc.) obtained while opening the account and during the course of business relationship, are properly preserved for at least ten years after the business relationship is ended. The identification records and transaction data will be made available to the competent authorities upon request.

XII. Updating of the KYC Policy of the Company

The Board of the companywill be authorized to amend/modify the KYC/ AML/ CFT Policy or such other related guidance notes of Company, to be in line with RBI or such other statutory authority’s requirements/updates/ amendments from time to time.

XIII. Reporting to Financial Intelligence Unit-India

In terms of PMLA Rules, the companyshall be required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU- IND) in respect of transactions referred to in Rule 3 at the following address:

Director, FIU-IND
Financial Intelligence Unit-India
6th Floor, Hotel Samrat
Chanakyapuri
New Delhi – 110 021
Website – http://fiuindia.gov.in

The company will ensure that the provisions of the PMLA Rules and the Foreign Contribution and Regulation Act, 1976, wherever applicable, are adhered to strictly. The company shall strictly comply with all formalities including timely submission of all applicable reports and returns in the prescribed format with regards to cash and suspicious transaction qualifying under the PML Rules directly to FIU-IND through the designated Principal Officer(s) of the Company. However, as has been earlier advised, there is no need for submission of any NIL report in respect to the above. Further, the company and its employees shall maintain strict confidentiality of the fact of furnishing/reporting details of suspicious transactions.

MANDATORY DOCUMENTS REQUIRED FOR STARTING A RELATIONSHIP

A) Individuals:

Copy of Photo pan card.
Photograph
Address proof as mentioned in KYC documents requirements.
Copy of last ITR filed with Income Tax.
Three months bank statement.
Net worth particulars of the borrower & guarantors;

B) Private and Public Limited Companies:

Certificate of Incorporation.
Certificate of commencement of business in case company incorporated under the Provisions of the Companies Act, 2013.
Certified True copy (certified by Company Secretary or Director or authorised signatory) of the Memorandum and Articles of Association.
List of directors (certified by Company Secretary or Director or authorised signatory).
List of shareholders (certified by Company Secretary or Director or authorised signatory).
List of directors and shareholders certified by CA/CS/authorised signatory for mortgagors/Guarantors/Pledger, if applicable.
Latest audited financials of the company.
Certified copy of PAN card of borrower and guarantor.
Three months bank statement of borrower.
Net worth particulars of the borrower & guarantors;
Board resolution of guarantor company; (if applicable), if third company provides the Corporate Guarantee.

C) Partnership Firms:

Registration certificate, if registered.
Copy of PAN card of firm & partners.
Photographs of partners.
Certified copy of partnership deed.
Power of Attorney granted to a partner or an employee of the firm to transact business on its behalf.
List of partners along with Address.
Last 3 month bank statement.
Photograph of partners.

D) Trust & Foundations:

The company shall not extend any loan to Trust/Society/Foundation or ant form of NPO’s.

XIV. Designated Director:

The Board of directors have appointed the following person as the “Designated Director” for the above purpose.

• Ms. Ritika Gupta

Whole Time Director
2nd Floor YMCA Complex,13 Rana Pratap Marg, Lucknow-226001
Contact Details: 0522 – 2209401/02
Email Id: ritika.shailesh@gmail.com

XV. Principal Officer:

The Board of directors have appointed the following person as the “Principal Officer” for the above purpose.

• CS Geetanjali

Company Secretary cum Compliance officer 2nd Floor YMCA Complex, 13 Rana Pratap Marg, Lucknow-226001
Contact Details: 0522 – 2209401/02
Email Id:admin@aurumcapitalprojects.com