ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM/ANTISOCIAL FORCE(s) POLICY

HAKUNA MATATA WALLET LIMITED

TABLE OF CONTENTS

ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM POLICY

1. Preliminary

2. Customer Acceptance Policy and Risk Profiling

3. Non-Government Organizations/Foundations

4. Client Accounts

5. Correspondent Banking

6. Remittances / wire transfers

7. Money Changers

8. Record Keeping

9. Reporting Mechanisms

1. PRELIMINARY

1.1 SCOPE As a Global Policy, this applies to:

a. HAKUNA MATATA WALLET LIMITED, and all of its country offices, regional offices, liaison offices, and any other offices operating under the name of the HAKUNA MATATA WALLET LIMITED.

b. All National Organizations that have signed a Members’ Agreement and License Agreement with HAKUNA MATATA WALLET LIMITED; and

c. All other entities that agree to be bound by the Global Policies. (Together, “HAKUNA MATATA WALLET LIMITED International Entities”, or may be referred to as “we” or “us” in this document).

All of the HAKUNA MATATA WALLET LIMITED International Entities shall enact their own procedures which must be in line with global procedures, regulations, or other regulatory documents that enable compliance by its employees, volunteers, interns, Directors (and/or, when applicable, contractors and other partners) with this Global Policy. Where required by law or local practices, HAKUNA MATATA WALLET LIMITED offices and Organizations may enhance the standards and requirements set out in this policy.

1.2 PURPOSE The purpose of this policy is to strengthen and support HAKUNA MATATA WALLET LIMITED International to enable it to realize its full potential in acquiring raising and importantly to ensure the integrity, survival and growth of HAKUNA MATATA WALLET LIMITED to achieve HM WALLET’s vision to help ‘Make More Possible’ throughout the world. Through this policy HM WALLET seeks to address the challenges of a changing global financial environment and meet its obligation to promote transparency and integrity and to recognize that public confidence in the Finance’s management is paramount. The policy aims to establish best practices in an Anti-Money Laundering (AML) Policy. The policy sets out HM WALLET’s basic goal and purpose so as to permit examination of funds disbursements accordingly and maintain information on the purpose and objectives of HM WALLET’s activities.

1.3 MONEY LAUNDERING (DEFINITION)

Pursuant to the Law on Anti-Money Laundering and Combating the Financing of Terrorism

"Money laundering" shall mean;

● The conversion or transfer of property, knowing that such property is the proceeds of offence, for the purpose of concealing or disguising the illicit origin of the property or of helping any person who is involved in the commission of the predicate offence to evade the legal consequences of his or her action;

● The concealment or disguise of the true nature, source, location, disposition, movement or ownership of or rights with respect to property, knowing that such property is the proceeds of offence;

● The acquisition, possession or use of property, knowing, at the time of receipt, that such property is the proceeds of offence;

● Participation in, and attempts to commit it and aiding and abetting, any of the acts defined in accordance with this article;

"Financing of terrorism" shall mean

"Financing of terrorism" shall mean the willful provision or collection of funds, directly or indirectly, through 'Whatever means, with the intention that such funds be used or in the knowledge that they are or may be used, in full or in part, for the purpose of supporting terrorism, terrorist acts or terrorist organizations. Money laundering is the term used for a number of offences involving the proceeds of crime or terrorist funds. It includes possessing, or in any way dealing with, or concealing, the proceeds of any crime.

The process of money laundering has three stages:

1. placement- through which the funds (often in cash) enter the financial systems;

2. layering- by which the funds pass through a complex sequence of transactions designed to make it impossible for investigators to follow a trail of evidence back to the origin of the funds; and

3. integration- the point at which the funds emerge from the process back into the legitimate economy in a way that they are unrecognizable as the proceeds of crime.

1.4 ANTI-TERRORISM CONSIDERATIONS

Terrorism/Antisocial force(s), in common with other criminal acts, infringes the fundamental rights of the innocent and the powerless and diverts money and attention from the real needs of the communities we are committed to ‘Making More Possible’ in. We do not engage with terrorist/Antisocial force(s) organizations or give money to partners who carry out, or fund, or advocate terrorist activity. We are fully committed to ensuring all our business processes minimize the risk of funds being diverted for terrorist or any other criminal purposes. We work within the law to ensure that our work and that of our partners is free from interference and that resources are used for the purposes intended.

2. CUSTOMER ACCEPTANCE POLICY AND RISK PROFILING

2.1 Customer Acceptance Policy

HM WALLET has customer acceptance policies and procedures as well as some reasonable measures, including risk profiling, in their initial points of contact with potential customers to address different risks posed by each type of customer.

Following the initial acceptance of the customer, HM WALLET continuously monitors the customer's account activity pattern to ensure it is in line with the customer profile. Unjustified and unreasonable differences will cause HM WALLET to reassess the customer as of higher risk.

HM WALLET is wary and ensures that they do not fall complacent and completely rely on the customer due diligence conducted by the intermediaries or other third parties they use. The ultimate responsibility of customer due diligence always remains with HM WALLET.

2.2 Individual Customer Assessment

In establishing a business relationship with an individual customer, We obtain from the individual customer at least the full name, date of birth, identity card/passport number/identity document reference number, occupation/business, address and nationality and Tax Compliance Personal Identification Number.

2.3 HM WALLET requires the individual to furnish the original and make copies of one or more of the following documents to finalize the acceptance process:

• National identity card;

• Taxation Personal Identification Number issued by the National Government of the country of operation.

2.4 Customer Due Diligence

HM WALLET conducts customer due diligence and obtains satisfactory evidence and properly establishes in its records the identity and legal existence of persons applying to do business with them. Such evidence must be substantiated by verifiable documents in 2.3 above.

Unwillingness of the customer to provide the information requested and to cooperate with HM WALLET’s customer due diligence process may itself be a cause for suspicion. Such a situation warrants a suspicious transaction report to be submitted to the Financial Intelligence Unit of the Country of Operations.

2.5 The customer due diligence will be conducted, when:

● establishing business relationship with the customer such as opening an account or engaging in any other business dealings;

● carrying out an occasional or one-off transaction, that involves a sum in excess of USD 1,000 (or 150,000 KES or foreign currency equivalent).

● HM WALLET has any suspicion of money laundering or financing of terrorism; or

● HM WALLET has any doubts about the veracity or adequacy of previously obtained information.

2.6 The customer due diligence undertaken by HM WALLET at least comprises the following:

● identify the customer and verify the identity of the customer using reliable, independent source documents, data or information referred to in articles 2.3;

● determine if the customer conducting business is acting on behalf of another person or beneficial owner;

● obtain information on the purpose and intended nature of the business relationship; and

● conduct ongoing due diligence and scrutiny, to ensure the information provided is updated and relevant and ensure that the transactions being conducted are consistent with HM WALLET's knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.

2.7 Enhanced Due Diligence

HM WALLET shall conduct enhanced customer due diligence for all categories of higher risk customers as deemed by HM WALLET, to ensure that we are not abused by money launderers and financiers of terrorism.

2.8 Enhanced due diligence will include at least:

● more detailed information from the customer, in particular, on the purpose of the business relationship and source of funds;

● independent research and sourcing of additional information about the customer; and

● approval by senior management

3. NON-GOVERNMENT ORGANIZATIONS/FOUNDATIONS

HM WALLET requires a Non-Governmental Organization or foundation establishing business relationships to furnish the constitution documents or other similar documents to ensure that it is properly constituted and registered.

The identity of all account signatories shall be verified according to customer due diligence for individual customers. When signatories change, care will be taken to ensure that the identity of all current signatories has been verified.

HM WALLET takes steps to understand who is in control and makes decisions regarding the Non-Governmental Organization/Foundation, and the use of the funds.

4. CLIENT ACCOUNTS

HM WALLET will satisfy itself about transactions of accounts passing through lawyers and clients' individual accountants that give cause for concern, and will report those transactions to the Financial Intelligence Unit, once suspicion is aroused.

5. SHELL COMPANIES

HM WALLET will not open an account for or conduct business with a shell company, which do not conduct any commercial activities or have any form of commercial presence whichever country but are legal entities through which financial transactions may be conducted.

6. CORRESPONDENT BANKING

HM WALLET shall take the necessary measure to ensure that they are not exposed to the threat of money laundering and financing of terrorism through correspondent accounts they have with any other Financial Institutions.

6.1 HM WALLET entering a correspondent relationship will gather and assess at least the following information on the correspondent;

● board of directors and management;

● business activities and products;

● subjected legislations, regulation and supervision

● AML / CFT measures and controls; and

● annual financial and operational reports.

HM WALLET shall establish or continue a correspondent banking relationship with the correspondent only if it is satisfied with the assessment of the information gathered.

HM WALLET shall also document the responsibilities of the respective parties in relation to the correspondent banking relationship.

The decision and approval to establish or continue a correspondent banking relationship shall be made at the Senior Management level.

HM WALLET shall ensure that such correspondent banking relationships do not include correspondent banks and financial institutions that have no physical presence and which are unaffiliated with a regulated financial group.

HM WALLET shall exercise enhanced due diligence with respect to correspondent banks and financial institutions which allow direct use of the correspondent accounts by their customers to transact business on their own behalf such as payable-through accounts.

HM WALLET shall implement customer due diligence for such customers as required for intermediaries introducing business.

HM WALLET shall pay special attention to correspondent relationships with correspondent banks and financial institutions from countries which have insufficiently implemented the internationally accepted AML / CFT measures. Enhanced due diligence is needed to assess the money laundering and financing of terrorism risks.

7. REMITTANCE/WIRE TRANSFER

HM WALLET conducting or participating in an outgoing remittance/wire transfer transaction shall include with it the necessary originator's name, address, account number, identification number or customer reference number and the details of the transaction.

HM WALLET facilitating or acting as intermediary to a remittance/wire transfer transaction shall ensure such originators' information is still retained with the remittance/wire transfer message.

HM WALLET receiving a remittance/wire transfer message with incomplete originators information shall conduct enhanced due diligence and may consider it as a factor of suspicion. It would be deemed unnecessary to include all the above information in the message accompanying a remittance / wire transfer transaction of less than USD 1,000 (150,000KES or its equivalent in any other currencies).

HM WALLET shall pay attention to wire transfers by higher risk customers and consider such factors as the name of the beneficiary, the destination and amount of the remittance/wire transfer. The customer will be asked to provide further explanation of the nature of any remittance/wire transfer which is inconsistent with the customers usual business/activity.

8. MONEY CHANGERS

HM WALLET shall pay special attention to and ensure that the moneychangers who maintain accounts with them are licensed and only conduct legitimate currency exchange transactions. HM WALLET will ensure that the nature and volume of transactions in the moneychangers account reflect the nature of their business.

If HM WALLET identifies any discrepancies in the activities of the moneychangers account, they will submit a suspicious transaction report to the Financial Intelligence Unit.

9. RECORD KEEPING

9.1 Records

HM WALLET will keep all records, documents and copies of documents involved in all forms of transactions for at least 5 years after the date of the transaction. All identification data, files, records, documents, business Correspondence and copies of documents obtained on a customer must be maintained for at least 5 years after the accounts have been closed or the business relations with the customer have ended.

Where the records are subjected to an on-going investigation or suspicious transaction report submitted, they shall be retained beyond the stipulated retention period until it is confirmed by the relevant authority that such records are no longer needed.

HM WALLET shall retain the relevant document as originals or copies, on microfilm or in electronic form, provided that such forms are secured and retrievable upon request and provided in an accurate and timely manner

HM WALLET shall conduct on-going due diligence for all customer relationships, using a risk-based approach. The risk-based approach to on-going customer due diligence will ensure that the risk profile of the customer is up-to-date.

HM WALLET shall pay special attention to all complex, unusual large transactions, or unusual patterns of transactions, to determine whether the transactions have an apparent or visible or lawful purpose.

9.2 Existing Accounts

HM WALLET shall take necessary measures to ensure that the records of existing customers remain up-to-date and relevant. Further evidence of the identity of existing customers shall, where necessary, be obtained to ensure compliance with customer due diligence standards set by the present document. HM WALLET shall conduct regular reviews on existing records of customers.

These reviews will at least, be conducted when:

• a significant transaction is to take place;

• there is a material change in the way the account is operated;

• the customer's particulars change substantially; or

• information held on the customer is insufficient.

In the event that the circumstances above do not arise, HM WALLET shall, based on risk assessment, obtain additional information in line with their current standards from those existing customers that are of higher risk.

9.3 Audit Trail

HM WALLET must ensure that the retained documents and records are able to create an audit trail on individual transactions that would enable the supervisory and enforcement agencies to trace funds.

The records kept must enable HM WALLET to establish the history and nature of and reconstruct each transaction. The records shall include at least:

• the origin of funds, such as method of receipt and or name of originator of wire and transfer;

• the identity of the person undertaking the transaction if not an account holder;

• the type of transaction; and

• the instruction and the destination of fund transfers.

9.4 Management Information System and Special Attention

HM WALLET shall put in place an adequate management information system for identifying and detecting transactions that we suspect or have reasonable grounds to suspect related to proceeds from an unlawful activity or the customer is involved in money laundering or financing of terrorism.

The management information systems provides  HM WALLET timely information on a regular basis to enable them to detect suspicious activity.

HM WALLET shall conduct on-going due diligence with regards to business relationships and transactions with individuals, business, company and financial institutions from countries which have insufficiently implemented the internationally accepted AML / CFT measures. Such business relationships and transactions will require HM WALLET to make further detailed inquiries, about their background and purpose, to establish the findings in writing, and to make them available to the competent authorities.

9.5 Suspicious Transaction Reporting

HM WALLET is required to establish a reporting system and to promptly submit suspicious transaction reports to the Financial Intelligence Unit when any of its employees suspects or has reasonable grounds to suspect that the transaction involves proceeds of an offence or are related to money laundering or financing of terrorism or they have any other grounds of suspicion about a customer transaction.

Some examples of suspicious transactions are listed in Clause 1.3. These examples are not exhaustive and only provide examples of basic ways in which money may be laundered or used for the financing of terrorism. HM WALLET has established our own internal guidelines on suspicious transaction reporting incorporating the relevant provisions in the Law on Anti-Money Laundering and Combating the Financing of Terrorism and the relevant provisions in the present Document including a list of suspicious transactions indicators.

Other suspicious activities that HM WALLET considers are:

● Entering partnership arrangements with organizations that may be fronts for criminal activities.

● Use of an alternative banking system to move funds to areas of operation.

● Use of conduits for funding (money held for the organization in a conduits name).

● Payment of facilitation charges in an area of operation where these amount to a private benefit rather than a lawful tax or duty.

● Suppliers may be set up to provide such money laundering facilities, so we must ensure that due tender and procurement process is followed and suppliers are confirmed as bona fide.

● Operating trading outlets with donated goods with insufficient internal controls. (No purchase invoices to match any sudden increase in cash income.)

● Operation of trading subsidiaries with insufficient internal controls (can be used to receive loans and repay loans to confuse the audit trail).

● Interest-free loans

● Requests to/or use HM WALLET as a conduit and pass money through it.

HM WALLET shall also submit a Suspicious transaction report when a new or existing customer fails to complete the customer's due diligence without reasonable excuse, regardless of whether HM WALLET accepts, rejects, continues or terminates the business relationship with such a customer.