Anti-Money Laundering Policy and Procedure

Introduction

• Vhodia  recognizes the importance of preventing money laundering and terrorism financing and is committed to the highest standards of Anti-Money Laundering and Combating Terrorist Financing in Nigeria.

• Vhodia ,  is subject to applicable legislation designed to prevent Money Laundering . This legislation. includes legislation such as: Terrorism Prevention Act 2103, Money Laundering Prohibition Act, 2011 (as amended) and others.To fulfil this commitment, Vhodia  has established internal policies and procedures. This Policyestablishes standards which every employee, contractor and business partner of Vhodia  should observe.

• 1. Scope

• Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins.Criminal proceeds may take any form, including money or money’s worth, securities, tangible property and intangible property. Terrorism Financing is defined as providing, depositing, distributing or collection funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially use, for the committing of terrorist acts. This Policy is aimed to prevent any company or individual from using Vhodia  for money launderingor terrorist financing activities.

• 2. Our Policy

• 2.1. Customer Due Diligence To prevent Money Laundering, Vhodia  will implement processes and procedures in its Line of Businesses (LOBs) to conduct appropriate customer due diligence through the Vhodia ’ s Business Partner Screening Questionnaire , identifying the customer and verifying the customer’ s identity on the basis of

• the following “Know Your Customer” principles:

• • Customer provided documentation (Verification Checking); 

• • Information on the customer obtained from reliable and independent sources (Ownership Checking);

• • Compliance with Vhodia ’ s Business Codes.

Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the designated Vhodia  Chief Compliance department or commercial department.

2.2. Risk-Based Approach 

For Vhodia , the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business that Vhodia ’ s customers carry out or on the country where Vhodia ’ s customers are located. Vhodia  will classify its customers based on a risk level in its applicable line of business processes and procedures. Identifying the potential risk will help to effectively manage these risks, implementing controls to mitigate the identified risk, if any.

 
2.3. High Risk Customers
Vhodia  will not do business with the following segments of customers:
 
• Persons included in any official lists of sanctions , in line with the Vhodia  Sanctions Policy ;
 
• Persons indicating possible involvement in criminal activities , based on available information about them ;
• Persons with businesses in which the legitimacy of activity or source of funds can ’ t be reasonably verified ;
 
• Persons refusing to provide the required information or documentation ; or
• Entities whose shareholder/control structure cannot be determined.

2.4. Record Keeping 
Customer documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken and copies of, or reference to, the documentation of the customer must be kept. 

 
Records should be kept for as long as the relationship endures with the customer and for at least five (5) years after the relationship ends. In countries where this period exceeds the established period of time, the legally established time period will be considered to comply with local law. 

2.5. Designation of Anti- Money Laundering Reporting Officer (AMLO)
Vhodia  will designate an Anti-Money Laundering Officer . The Anti-Money Laundering officer will be responsible for:

• Considering internal reports of money laundering;
 
• Reporting suspicions of money laundering to the responsible authorities; and
• Acting as key liaison with the money laundering authorities.
• Training the business and its employees on money laundering;
 
• Submitting weekly reports to the Special Control Unit Against Money Laundering (SCUML)
 
• Advising on proceed after a report of suspicion on money laundering has been raised; and
• Designing and implementing Anti-Money Laundering processes and procedures.

3. Reporting Suspicious Activity

Vhodia  expects that, if any employee, contractor or business partner becomes aware of any suspicion or knowledge of possible Money Laundering activity, this is reported without undue delay to the AMLO.
 
This can either be done contacting directly the AMLO or his deputy. A report on suspicious activity should contain, at least, the following information, which will be confirmed by the  AMLO: 
• Identity of the person raising the suspicion; 
• Date of the report; 
• Who is suspected of money laundering or terrorist financing activities;
• Other individuals involved otherwise; 
• Deliverance of facts; 
• What is suspected and why; and
• Any possible involvement of Vhodia .
The AMLO may make reasonable enquiries within Vhodia  to confirm these suspicions or obtain additional information to confirm these suspicions. After this assessment, the AMLO will determine  whether or not
it is necessary to file an official report to the responsible money laundering authority. Details of internal reports will be held by the AMLO separately, excluded from customer files, to avoid inadvertent or  inappropriate disclosure.

4. Training

Vhodia  has a high commitment to compliance and all employees and contractors are required to complete mandatory compliance training, including provisions on anti-money laundering, on an annual basis. Job-specific and comprehensive anti-money laundering training should be provided to the relevant employees to  help recognize and deal with transactions which may lead to money laundering or terrorist financing.

5. Policy Review And Audits 

Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by the Vhodia  Internal Audit function. This provides Executive Management and the Board Audit Committee with the necessary assurance and information regarding the operating effectiveness of Julius Berger Nigeria Plc’ s controls and processes relating to this Policy.