A proud member of the (NYMEX), (COMEX), CME Group, (CBOT), (LBMA), (DGCX), (DGAG), (DGJG)

OUR POLICY

CONTENT

1. KALOTI JEWELLERY INTERNATIONAL'S COMMITMENT
2. POLICY CUSTODIAN
3. PURPOSE AND RATIONALE
4. POLICY STATUS AND SCOPE
5. PORCEDURES AND CONTROLS (GENERAL)
6. PERIODICAL REVIEW
7. IDENTIFICATION (ID), VERIFICATION (VR) AND KNOW -YOUR - CUSTOMER (KYC)
8. KYC INFORMATION UPDATING
9. AUTOMATED ACTIVITY MONITORING
10. REPORTING OF SUSPICIOUS ACTIVTIES
11. TRAINING AND AWARENESS
12. RECORD KEEPING
13. MANAGEMENT AND STAFF RESPONSIBILITES
14. OECD's MISSION
15. REFERENCES

APPENDICES

APPENDIX A – CORPORATE KYC CHECKLIST
APPENDIX B – INDIVIDUAL CLIENTS KYC CHECKLIST
APPENDIX C – CORPORATE KYC UPDATING CHECKLIST
APPENDIX D – INDIVIDUAL CLIENTS KYC UPDATING CHECKLIST
APPENDIX E – PRATICAL ISSUE CONCERNING TRAINING AND AWARENESS
APPENDIX F – PRACTICAL ISSUE CONCERNING RECORD KEEPING

Glossary of Terms Used in the Policy

AML	Anti-Money Laundering
KJI	Kaloti Jewellery International
OECD	Organization for Economic Co-operation and Development
CDD	Customer Due Diligence
CFT	Combating the Financing of Terrorism
CIBO	Client Identification and Beneficial Ownership
DFSA	Dubai Financial Services Authority
DMCC	Dubai Multi Commodities Centre
FT	Financing of Terrorism
ID	Identification
KYC	Know Your Customer
ML	Money Laundering
VR	Verification

1. KALOTI JEWELLERY'S COMMITMENT.

1.1

1.2

1.3

1.4

1.5

KJI will follow DMCC guidelines for combating Money Laundering and the Financing of Terrorism by implementing internal measures as may be deemed necessary.

KJI will have agreements with suppliers to follow policies on responsible sourcing of minerals from conflict affected & high risk areas to refrain from any action with contributes to financing of conflict

KJI will comply with relevant UN Sanctions resolutions regarding contribute to any forms of inhuman treatment, forms of forced child labor & widespread sexual violence.

KJI will not tolerate with direct or indirect support to non state armed groups & their affliates, in every step of mineral process including trade with illegality control mine sites & illegally tax or report.

KJI will not offer, promise, give or demand any bribes and fraudulent misrepresentation of the origing of minerals, taxes, fees and royalties paid to government for mineral process.

2. POLICY CUSTODIAN

2.1	KJI Management Team shall be ultimately responsible for the implementation and enforcement of the policy
2.2	KJI Management Team will be seeking the support of the Compliance and Inspection department of DMCC to provide the expertise and assistance regarding the implementation and enforcement of the policy.
2.3	KJI Management Team willl be implementing and following OECD due diligence guidance for rsponsible supply chains of minerals from conflict-affected and high-risk areas.

3. PURPOSE AND RATIONALE

3.1	This policy sets out provisions, procedures and controls as enacted by KJI concerning Anti-Money Laundering ('AML') and Combating the Financing of Terrorism ('CFT').
3.2	The Rationale behind the Policy is unequivocally clear, KJI will only accept those Clients; • Whose sources of funds can be reasonably established as legitimate; and • Who do not pose any risk (actual or potential) to KJI's reputation.
3.3	In light of the foregoing, KJI will not tolerate any involvement in illegal activities by its staff, clients or subsidiaries.

4. POLICY STATUS AND SCOPE

4.1	The provisions, procedures and controls detailed below shall apply to: • KJI staff; and • KJI's clients and affiliates; and • KJI's subsidiary companies and divisions.
4.2	Breach of the Policy by KJI staff, clients, affiliates or subsidiary shall constitute a disciplinary offence and KJI reserves the right to take any additional action as it, in its sole discretion, deems fit in securing the diligent and proper implementation and enforcement of this policy.

5. PROCEDURES AND CONTROLS (General)

5.1	This Policy contains as an integral part to it, certain procedural checks and balances so as to ensure the vigilant and effective operation of the Policy.
5.2	The Procedures & Controls are as follows • Identification, verification and Know-your-customer (KYC) measures • Updating of KYC information • Automated activity monitoring • Reporting of suspicious activities • Training and Awareness • Record Keeping

6. PERIODICAL REVIEW

6.1	This policy shall be reviewed on regular basis. Any review shall take into account changes provided to KJI by DMCC's Compliance and Inspection Department.

7. IDENTIFICATION (ID), VERIFICATION (VR) and KNOW-YOUR-CUSTOMER(KYC)

7.1	ID, VR, and KYC together form the first key step in the Procedures and Controls and are to be conducted prior to the granting of any KJI clients ('Applicant') approval for opening an account or conducting any business transactions. It enables basic background information about the Applicant, their business, source of funds and their expected level of activity to be obtained and an initial decision undertaken.
7.2	The carrying out of ID, VR and KYC procedures are vital and necessary for opening an account and starting any business transactions.
7.3	Where Applicant is an Individual Person(s) seeking to be KJI clients. The ID, VR and KYC process must, in order to be valid, cover the following details regarding each individual Applicant: • Applicant's full name (as per passport) • Date and place of birth • Nationality • Physical address (residential and business/ home country and UAE (If Applicable) • Contact details • Understanding previous personal/ business activities/occupation (type and volume) • Anticipated type and volume of company's activities • Source of funds (Declaration). • Bank reference and introductory letter • Declaration re: Beneficial Ownership
7.4	Where Applicant is a Company seeking to be a KJI client. The ID, VR, and KYC process must, in order to be valid, cover the following details regarding the Applicant Company: • Incorporated name • Shareholders • Beneficial owners • Signatories • Country of origin/UAE physical address (If Applicable) • Contact details • Previous business activities (type and volumes) • Anticipated type and volume activities • Source of funds (Declaration) • Bank Reference or Trade Reference
7.5	KYC process
	7.5.1	KYC is to be carried out via the use of (2) checklists: • Corporate KYC checklist (please refer to Appendix A) • Individual and/or Shareholders/Managers KYC Checklist (please refer to Appendix B)
	7.5.2	When Conduction the KYC process, ID, VR, and KYC must be carried by KJI itself. KJI might seek DMCC's Cooperation to carry out of Applicant screening and relative risk assessments.

8. KYC INFORMATION UPDATING

8.1	Reasonable steps must be taken to ensure that ID, VR and KYC information is updated as and when required. KYC information will be updated regularly.
8.2	KYC updating is carried out via the use of those KYC updating checklists as attached in Appendices C and D.

9. AUTOMATED ACTIVITY MONITORING

9.1	KJI will monitor the activities of its Clients on regular basis, to ensure that their operations are conducted in accordance with DMCC regulations.

10. REPORTING OF SUSPICIOUS ACTIVITIES

10.1

Procedures for AML place a clear obligation on all KJI Management and staff to report any suspicious activities or information which may point to transactions and instructions being related to illegal activities. As money laundering and the financing of terrorism methods and techniques are always evolving, the Compliance department, with coordination with DMCC, will inform staff as what are to be considered as red flags for suspicious activities in both money laundering and financing of terrorism.

10.2

As such it is the duty of KJI management to report any suspicious activity or information to the DMCC Compliance and Inspection Department or Local Authorities. In doing so, it is important to provide the following:

• The reason for the suspicion is fully explained; and
• No mention of the suspicion is made to the Client or Third party the subject of suspicion; and
• And additional information as may be requested by the Compliance and Inspection Department of DMCC and the Local Authorities will be provided.

11. TRAINING AND AWARNESS.

11.1	Training shall be carried out on regular basis for all concerned staff within KJI, so to ensure they are aware of those AML and CFT regulations, controls and responsibilities which require their compliance and which form the basis for this Policy.
11.2	All new (recently joined) concerned KJI staff must be provided with an initial induction into the policy, AML and CFT and the need for the reporting of suspicious transactions. Such induction may be carried out as part of the normal induction procedures.

12. Record Keeping

12.1	KYC Documentation • All Clients' documentation and/or correspondence regarding KJI contract; • All Clients' documentation and/or correspondence regarding KJI account opening; • Refused account opening applications; • All documentation concerning a suspicious activity concerning a client together with any response/follow up; and • Records of AML/CFT training sessions attended by KJI staff, their dates, content and attendees.
12.2	Retention Period All documentation required under this Policy should be retained for a period of at least 2 years from the date of termination of the Clients contract.
12.3	12.3 Investigations Where a client is the subject of an investigation of any kind then all documentation relating to the investigation must be retained for such time until the authority conducting the investigation informs KJI otherwise in writing.

13. KJI MANAGMENT and STAFF RESPONSIBILITY.

13.1

Scope of Responsibility

In carrying out the proper discharge of their duties under the Policy, both KJI Staff and Management alike will be expected to:

• Undertake their due diligence role,
• Ensure their and their team's awareness of and compliance with ID,VR and KYC, record keeping and reporting; and
• Undergo such ongoing AML/CFT training as KJI deems necessary from time to time.

14. OCED's MISSION

	The mission of OECD is to provide guidance that will improve the economic and social well-being of people around the world by understanding what drives economic, social and environment change.
	KJI Management Team feels proud by implementing and following OECD due diligence guidance for responsbile supply chains of minerals from conflict-affected and high-risk areas.

15. REFERENCES

In this Policy reference has been made to follow DMCC's Compliance and Inspections department's procedures regarding KYC, AML and CFT as well as OECD due diligence guidance for responsible supply chains and minerals from conflict-affected and high-risk areas.

Appendix A - Corporate KYC Checklist

The following information/documents must be collected and retained:
A1	A1 Proof of legal existence of Applicant Company:
	• Trade License (if relevant in country of incorporation); and • Certificate of Incorporation; and • Memorandum and Articles of Association; and
A2	Proof of Applicant company's physical address in country of origin and physical address within the UAE (when applicable):
	• Original utility bill; or • Copy of lease/purchase agreement; or • Original statement from a financial institution, or • Letter from public authority or external auditor
A3	Contact details of Applicant Company:
	• Office telephone number(s); and • Office fax number(s); and • Office email address; and • Website address
A4	Proof of Identity of all controlling individuals/shareholders of the Applicant Company
A5	Contact details of the individuals/Shareholders:
	• Telephone number(s); • Fax number(s); and • email address.
A6	Declaration by authorized signatories of the Applicant Company that the beneficial owners mentioned is the sole beneficial owners of the Applicant Company.
A7	Identities and addresses of all signatories of Applicant Company
A8	Understanding the relationship that exists between the principals of the applicant company and the powers of attorney/third party mandate holders
A9	Names and address of all partners in partnerships
A10	Details of Applicant Company's line of business including:
	• Main products; • Main activities geographical areas; and • Volume of activities
A11	Indication of the anticipated volume and type of activity to be conducted by the Applicant Company
A12	Understanding the source of funds originating from the Applicant Company (Signed Declaration for legal source of funds, metals and equity)
A13	Bank reference whereby Applicant Company has been known to the issuing bank for a good period of time (1-2) years or Trade Reference (If the above are not available) KJI management to conduct a reputational market presence survey approved and signed by the Managing Director
A14	External Auditors name and address (if available)

Appendix B - Individual Client KYC Checklist

The following information/documents must be collected and retained:
B1	Valid, original ID card or passport clearly showing:
	• Legal name (Change of Name Deed in the case of change of name); • Date and place of birth; and • Nationality
B2	Proof of Individual Applicant's physical address:
	• Original utility bill; or • Copy of lease / purchase agreement; or • Bank Statement highlighting address
B3	Contact details of the Individual Applicant:
	• Telephone number(s); • Fax number(s); and • email address.
B4	Verification of contact details
B5	Understanding of Individual Applicant's expertise and previous business activities
B6	Indication of the anticipated volume and type of activity to be conducted by the Individual Applicant.
B7	Understanding the source of funds (income, assets, net worth, etc) of each individual Applicant. (Signed Declaration of legal source of funds, metals and equity)
B8	Bank reference whereby Individual Applicant has been known to the issuing bank for a good period of time (1-2) years or Trade Reference (If the above are not available) KJI management to conduct a reputational market presence survey approved and signed by the Managing Director

Appendix C - Corporate KYC Updating Checklist (For Internal Use)

The following information/documents must be collected and retained:
C1	Same year proof of physical address of Corporate Client in the form of:
	• Utility bill; or • Copy of lease/purchase agreement
C2	Recent contact details of Corporate Client:
	• Office telephone number(s); • Office fax number(s); • Office email address; and • Website address
C3	Description of Corporate Client's activities (types and volume) for the last two years
C4	External auditors name and address (If Available)

Appendix D - Individual Client KYC Updating Checklist (For Internal Use)

The following information/documents must be collected and retained:
D1	Valid ID card or passport clearly showing:
	• Legal name (Change of Name Deed in the case of change of name); • Date and place of birth; and Nationality
D2	Same year proof of physical address of individual:
	• Original utility bill; or • Copy of lease agreement; or • Copy of deed agreement
D3	Latest contact details of the individual:
	• Telephone number(s); • Fax number(s); and • Email address
D4	Description of Individual Client's activities (types and volume) for the last two years

Appendix E - Practical Issues Concerning Training and Awareness (Section 12)

The following information/documents must be collected and retained:
E1	Any training provided must include:
	• An introduction into what is money laundering/financing of terrorism; • Developing the ability to recognize suspicious activities or 'early warning' signs (particularly regarding commodities trading); • The requirements of local and international regulatory legislation and their ramifications; and • The Policy
E2	Training and awareness can be raised through the following tools:
	• Handbooks • Awareness messages • Courses (internal and external) • Induction programs

Appendix F - Practical Issues Concerning Record Keeping

The following information/documents must be collected and retained:
F1	Storage Location
	If it is not possible or practicable (for example due to space constraints) to store KYC Documentation on site, then a suitable external location may be utilized. Suitable external locations may be: • A secure area (e.g. warehouse, office) owned and/or operated by KJI; or • A secure area owned and/or operated by a reputable third party provider. Regardless as to whether KYC Documentation is stored on or off-site, the documents themselves must be stored in a secure, fireproof location such as a safe from a reputed manufacturer.
F2	Use of Other Storage Media
	As an additional safeguard, the Company may elect to scan images of original documents onto CD-Rom format. CD-Rom's should be stored in a secure environment suitable for the long term storage of electronic/digital media.
F3	Data Retrieval/Accessibility
	The robustness of the security offered by any given storage option should not compromise the efficacy of data retrieval. Storage locations which prevent a reasonably fast retrieval of data should be disregarded in favor of suitable alternatives. The requirement for swift data retrieval is particularly important when dealing with third party conducted investigations where KJI may be requested to source and forward on data within a stipulated time period.
	As such, stored KYC Documentation should be indexed by reference to:- • Member name; • Date stored; • Data type (e.g. registration, license, correspondence, report); and • details of the individual responsible for filing the KYC documentation in storage.


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