Anti-Money Laundering Policy for the Kayndrex Foundation

Introduction

The Kayndrex Foundation is committed to preventing the use of its funds and operations for illegal purposes, including money laundering and financing of terrorism. To this end, the Foundation has established an Anti-Money Laundering (AML) Policy, which sets forth the measures that it will take to comply with applicable laws and regulations and to mitigate the risk of money laundering and other illegal activities.

Scope

This Policy applies to all employees, contractors, agents, volunteers, and other third parties who conduct activities on behalf of the Foundation. It also applies to all transactions and activities conducted by the Foundation, regardless of the type of transaction or activity and the method of execution.

Policy Requirements

Due Diligence

The Foundation will implement due diligence (DD) procedures to identify its stakeholders, verify their identities, and assess the risk of money laundering and financing of terrorism. The DD procedures will include obtaining and verifying stakeholder information, including name, address, identification number, and other relevant information. The Foundation will also evaluate the stakeholder’s transaction patterns and conduct ongoing monitoring of the stakeholder’s activities.

Suspicious Activity Reporting

The Foundation will establish procedures for reporting suspicious activities, which may include money laundering or financing of terrorism. All employees, contractors, agents, volunteers, and other third parties who conduct activities on behalf of the Foundation must be trained to recognise and report suspicious activities. Suspicious activities should be reported promptly to the designated person or department.

Record Keeping

The Foundation will maintain accurate and complete records of all transactions, including the identity of the stakeholder, the nature and amount of the transaction, and the date and time of the transaction. These records must be kept for a minimum of five years from the date of the transaction.

Employee Training

The Foundation will provide ongoing training to all employees, contractors, agents, volunteers, and other third parties who conduct activities on behalf of the Foundation. The training will cover the relevant laws and regulations, the Foundation’s AML Policy, and the procedures for identifying and reporting suspicious activities.

Internal Controls

The Foundation will establish and maintain internal controls to ensure that its AML Policy is effectively implemented and that the risk of money laundering and financing of terrorism is mitigated. The internal controls will include regular audits, risk assessments, and independent testing of the AML controls.

Monitoring and Review

The Foundation will monitor its AML Policy on an ongoing basis and review it periodically to ensure its effectiveness and to ensure that it remains in compliance with applicable laws and regulations. The Foundation will also conduct regular assessments of the risks associated with its operations and will take appropriate measures to mitigate those risks.

The Kayndrex Foundation is committed to preventing the use of its funds and operations for illegal purposes, including money laundering and financing of terrorism. By implementing the measures set forth in this AML Policy, the Foundation will demonstrate its commitment to compliance with applicable laws and regulations and to the protection of its reputation and assets.

Last Updated: [30/01/2023]