Glossary

Policy Statement

Dhamana Guarantee Company (the “Company”) shall comply with applicable local and global legislation, countering the financing of terrorism (“CFT”), and anti-money laundering (“AML”), consistent with the Financial Action Task Force (“FATF”) recommendation in its “International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation.

The Company has zero-tolerance of actions prohibited by such legislation. To this end, the Company will not provide support or resources to any individual or entity that it knows, or has reason to believe advocates, plans, sponsors, engages or has engaged in terrorism, weapons proliferation, human rights violations or narcotics trafficking.

Principles

The Company’s approach to mitigating the risk of money laundering, terrorism financing and sanctions breaches is embedded in the following, the Company will: -

a) Embed robust procedures, including maintaining adequate financial records to support expenditure.

b) Conduct risk assessments which will form part of programme planning and adopt appropriate mitigation measures escalating risks where necessary.

c) Conduct due diligence and screening of persons/corporates to whom it engages.

d) Report concerns accordingly in line with regulatory requirements.

Proscriptions

The Company shall not maintain a business relationship with third parties:

a) Where such a relationship is prohibited under the CTF or AML law or regulation in Kenya, Uganda, Tanzania and Rwanda or by an inter-governmental entity such as the UN.

b) Where the third party’s business activities are known or suspected to be illegal based on the applicable laws and regulations.

c) Where the third party is designated or proscribed or believed to be engaged or associated in activities that support terrorism or in money laundering activities.

d) DGC reserves the right to terminate a relationship where a third-party refuses to provide necessary information to enable the company to conduct appropriate due diligence or screening in line with business operations.

e) As a policy, the Company shall not undertake business with:

• Anonymous individuals or institutions;

• Individuals or entities subject to UN or local country sanctions;

• Shell companies;

• Companies whose beneficial ownership is not known or not clear; or

• Unauthorized money changers / prize bond dealers.

Due Diligence, Screening and Politically Exposed Persons (PEP)

Reasonable risk-based due diligence will be conducted before entering contractual relationships with third parties. As part of the due diligence, the Company will also obtain necessary details from the Suppliers and Recipients to ensure that the Company has adequate information on the identity of whom they are dealing with and where necessary, the beneficial owner. Such information will include registration certificates registered addresses, directors or owners.

The Company will screen its Recipients, and Service Providers against sanctions list. The objective of this screening is to reduce the risk of dealing with a sanctioned or proscribed persons or entities. A risk-based approach will be applied in determining the extent of the screening. The Company will avoid engagements with contractors, or third parties found in sanctions list. The Company will immediately take action to terminate any engagements with a Recipient and/or a Service Provider that has been added to the sanctions list.

Politically exposed persons (PEPs) are natural persons who are have been entrusted with a prominent public function. Due to their position and influence, it is recognized /perceived that PEPs bring higher risks that potentially can be abused for the purpose of committing money laundering offences and related predicate offences, including corruption and bribery, as well as conducting activity related to terrorist financing. The Company is especially careful when communicating with public officials or providing assistance to public officials. The Company shall conduct a detailed due diligence at the outset of any relationship with a PEP and on an ongoing basis where it is known or suspected that the business relationship is with a ‘politically exposed person’.

Reporting

Any suspicious activity identified by the Personnel, Service Providers and/or Recipients must be reported to the designated reporting channel i.e., transparency@dhamana.com.

The Legal & Compliance manager is the Company’s designated Anti-Money Laundering Reporting Officer (AMLRO)

KYC Policy

Prior to entering into any agreement with an individual or entity including Recipients and Service Providers, it is important that thorough knowledge is obtained of who such individuals and entities are, their source of funds, business models, connections and intentions, as well as the verification of their identity. The key objective here is to ensure that only appropriate individuals and companies provide services to and are customers of the Company

In the context of compliance with client due diligence (CDD) or Know Your Customer (KYC) requirements, identification means establishing that the customer is who and what they claim to be and verifying their identity by checking the quality of the identification documents provided to confirm the Recipients’ and Service Providers’ identities.

In order for the Company to identify and verify their Recipients and Service Providers, all persons and entities must provide the following information:

• Full Name of the individual/s or entity

• Address

• Registration details (corporate bodies) including certificate of incorporation, articles, directors and shareholder registers. KYC should also be conducted on directors and shareholders.

• Date and country of birth for individuals

• Certified proof of identity and proof of address for individuals