Key areas that the KYC/CDD policy. Sr. no Point Ref # PSX Guidelines Clause Broker Policy 1 CUSTOMER INDENTFICIATION

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1 Key areas that the KYC/CDD policy Sr. no Point Ref # PSX Guidelines Clause Broker Policy 1 CUSTOMER INDENTFICIATION 3.1 It is a basic tenet of any business to know who its customers are. This helps you to protect yourself from being used by unscrupulous and/or criminal elements. In this regard, brokers have to take all reasonable care to establish the true identity of customers. A minimum set of documents that need to be obtained from customers/potential customers at the time of opening their brokerage account has been prescribed by the SECP. To be prudent, brokers are advised to obtain any other document from the account opener if they believe it will help in establishing the true identity of the customer and the real controlling person behind the account. The key point is that brokers must not open anonymous or obviously fictitious accounts. 1.1 That the identities of all persons conducting business with the Brokerage House are properly verified and sufficient information gathered and recorded to permit the "know its customer" and forecast the expected pattern of business. Prospective business where all of the required information cannot be obtained without a justifiable reason is declined. Potential new relationship that do not appear to be legtimate are declined. Transactions offered by equity account holders do not appear legitamate are declined. Established relationships are regularly monitored, to ensure that they fit the customer's profile, especially in respect of large or abnormal transactions. Records are retained to provide an audit trial and adequate evidence to the law enforcement agencies in their investigations. CUTOMER IDENTIFICATION: The need to Verify Identity and Address. Must verify the credentials of every customer when an account is first opened.this applies to all types of accounts( personal customers, sole proprietors, traders, partnerships, private and public companies etc). Cutomer must fill Know Your Cutomer form and complete Account Opening formalities and authorizations. 3.2 It is important to recognize if a customer is acting on behalf of another person. If this is the case, than the identity of that person should be ascertained and relevant documents of that person needs to be obtained also. 1.2 In case of any other third parties, who are permitted by the account holder to operate the account. If the customer gives a mandate to a third party to operate the account, in such cases the identity of both the account holder and third party should be obtained in line with the normal procedures set out for personal customes in line with SECP and Stock Exchange guidelines. 3.3 For non-individual customers (e.g. companies, pension funds, government & 3.4 owned entities, non-profit organizations, foreign companies/ organizations) additional care has to be taken to establish the ownership and control structure of such an organization and who (i.e. person(s)) actually owns the organization and who manages it. Brokers should verify that the person who represents himself as authorized signatory with powers to open and operate the brokerage account is actually authorized by the organization. 1.3 Establishing the identity of anyone who wishes to do business with the Brokerage House is vital. For all applicants is required to be satisfiesd that:the person we are dealing with is who she/he says they are and lives permanently at the address they have given; the sole trader, partnership,company we are dealing with is a legitamate business with a known address and represents legitamate owners. In repect of accounts for Companies, it is necessary to verify the identity of the business entity in addition to the key individuals who will be operating the account as well as those who are investing into the business or controlling it. Further more it is imperative to have appropriate duly attested board resolutions in the case of limited concerns. Page 1 of 11

2 3.5 Brokers have to make sure and be careful that accounts of Institutions/ organizations / corporate bodies are not opened in the name of employee(s)/official(s). Because of sensitive nature of public sector (government) entities and risk of potential conflict of interest, it is critical for brokers and their representatives to ensure that accounts of Govt. Institutions are not opened in the individual name of any employee/official. Any such account, which is to be operated by an officer of a govt. owned entity, is to be operated by an officer of the Federal/Provincial/Local Government in his/her official capacity, shall be opened only on production of a special resolution/authority from the concerned administrative department, duly endorsed by the Ministry of Finance or Finance Department of the concerned Provincial or Local Government. 1.4 For each type of customer, certain documentation must be obtained and sufficient information gathered for us to be certain that; we know our new customer, having verified identity and address and understand the customer's business and the expected levels of transactions; the new customer has understood and accepted the Brokerage House's terms and conditions for the account;we are satisfied that the mandated individuals do have the authority of the account holder(s) and; we are satisfied that the account holder(s) and their business is legitimate and the Brokerage House is not a risk of financial loss or reputation damage. Original identification must be seen, photocopied and retained in the customer's file. Care must be taken to ensure that the copies are clear and legible and that the copies are stamped, signed and dated to show that the originals have been seen. If there any doubt about the legality or acceptability of any document reference must be made to Compliance Head. Accounts must not be opened on the strength of faxed documentation. Only original or certified photocopy documentation is acceptable. All signatures must be witnessed by two individuals. 3.6 When an individual or an organization/institution opens brokerage account & 3.7 with you, it is important to find out and document in broad terms what does the customer intend to do. For example, are there any specific sectors or stocks that the customer does not which to participate in; is the customer intending to invest for short-term only or is the customer intending to invest for longer term; will investment be only in liquid scrips or any scrip; or any other special needs or requirements of the customer. This, along with customer s other information such as age, gender, occupation, knowledge of market, etc. will help you develop a sense of the risk taking capacity and profile of the customer and thus guide the customer in more effective manner. At the same time, it will also help you to understand whether the customer should be classified as a low risk or a high risk customer from the KYC/CDD perspective. For example, a domestic customer working in a company with regular income would be low risk category; on the other hand, a government employee may be in a higher risk category because of the potential for conflict of interest; or a foreign organization having foreign currency sources would be in high risk category requiring more careful identification procedure and close monitoring of account operations. In the above context, brokers have to carefully determine the source of funding especially if the customer is expected to receive/send funds in foreign currency. 1.5 KNOWING THE CUSTOMER'S BUSINESS. It is not sufficient only to identify the customer, it is also necessary to understand the customer's business and the use to be made of the account i.e investment or trading account. Knowing the customer obviously includes knowing who the customer is and where he/she lives or conduct their business, but KYC is also about what the customer does, his/her/their financial circumstances and how the account will be use.directors of Private Companies must confirm whether they are the principal shareholders and, if not, the beneficial owners of the company must be identified. KYC information is needed to establish a pattern of expected activity and can assist the Brokerage House: to recognize unusual transactions and thus protect the Brokerage House from fraud; and to recognize any unusual transaction which might raise suspicion of money laundering. No account should be obtained until a satisfactory understanding of the customer's business has been obtained and documented on the Know your Customer form. Knowing the customer's business in not a öne off" event. Regular contact with the customer must be used to keep such knowledge up to date and appropriate notes must be placed in the customer's file. All information gathered during the monitoring of existing client accounts which updates knowledge of the customer and his/her business must be the subject of a similar not for the file. All cusotmer orders are recorded as per policy and clear instructions of trade must be taken. Not to take any orders in any other form which are not permitted by the SAOF or special instructions. Page 2 of 11

3 3.8 As is already the practice and part of KSE regulations, brokers must follow the regulations that the all receipts/payments above Rs25,000/= are made through cross cheques, bank drafts, payorders or other crossed banking instruments. Where any cash is accepted from a customer in an exceptional circumstance only, it has to be immediately reported to the Exchange with clear reasons as to why the cash receipt was accepted by the broker. 1.6 Concerned Staff must ensure that No receipt/payment would be made/accepted in CASH in excess of Rs.25,000/- from Customer/made to Customer. All receipts/payments above Rs.25,000/- must be in shape of cheque/crossed banking instruments made/issued from the designated Bank account only of the Customer as given by the Customer and/or payment made in the name of Customer contained CNIC No. In case of a urgent transaction of receipt of payment in cash of upto Rs.25,000/- to immediately inform the regulatory authority. In case, if the Customer is Sole Proprietor. Partnership and/or Joint Stock Company the receipt/payment must contained the business name of Sole Proprietor/Partnership/Joint Stock Company. 3.9 In general, physical presence of the account opener/authorized representative is necessary at the time of opening a brokerage account. In the case of nonresident/overseas customers or customers in other cities where the broker does not have a branch/office, more strong identity verification procedures should be applied. These include verification by a reliable third party, reference of an existing customer of the broker, confirmation from another broker with whom the customer had an account etc. Furthermore, it is important when obtaining confirmation from third parties in other jurisdictions, especially foreign, that brokers consider whether that foreign jurisdiction is following the Financial Action Task Force (FATF) recommendations. The list of jurisdictions following FATF recommendations is available. 1.7 It is imperative that all prospective customers for accounts with Amanah Investments Limited must be seen face to face and are verifiable. The appropriate account opening and customer information forms must be completed and any additional interview notes must be obtained and retained on the customer file.the NEED FOR VIGILANCE Whilst it can be assumed that the majority of customers are honest and that their transactions are legitimate, this is not always the case. As with all Brokerage Houses, there will be some prospective customers who approach the Brokerage House with the deliberate intention of using our services to launder criminal funds. It is hoped that the Brokerage House s enhanced procedures for account opening will identify these situations at the outset. However, it is not only prospective customers who may put the Brokerage House at risk. Occasionally, customers may seek deliberately to build up a degree of trust before they use the Brokerage House for other purposes; others may turn to crime because of a change in their personal circumstances. It is possible, therefore, that some existing customers may become deliberately or unintentionally involved in money laundering It is therefore vital that all staff is vigilant and that all unusual transactions for any customers are identified, discretely researched and, where there is a suspicion of money laundering, a report is made to the Compliance Head. The foundation of any monitoring procedure lies in the initial collection of identification and know your customer information and the ongoing updating of that information. Updating arises from regular contact with the customer and the results of Page 3 of 11

4 2 RISK ASSESSMENT 4.1 We have discussed assessment and categorization of customers as low, medium or high risk profile above. This risk assessment by brokers has to be done on the basis of information obtained at the time of brokerage account opening and has to be updated on the basis of information obtained during the relationship and doing business with the customer. It should be based on customer s identity, nature of income, source of funding, location/domicile of customer, etc. SECP has provided the following broad outline of factors that will categorize the customer into HIGH RISK CATEGORY: i. Non-resident customers; ii. Legal persons or arrangements including non-governmental organizations; (NGOs)/ not-for-profit organizations (NPOs) and trusts / charities; iii. Customers belonging to countries where CDD/KYC and antimoney laundering regulations are lax or if funds originate or go to those countries; iv. Customers whose business or activities present a higher risk of money laundering such as cash based business; v. Customers with links to offshore tax havens; vi. High net worth customers with no clearly identifiable source of income; vii. There is reason to believe that the customer has been refused brokerage services by another brokerage house; viii. Non-face-to face / on-line customers; ix. Establishing business relationship or transactions with counterparts from or in countries not sufficiently applying FATF recommendations; and x. Politically Exposed Persons (PEPs) or customers holding public or high profile positions 4.2 Politically Exposed Persons (PEPs ). PEP s also fall under HIGH RISK CATEGORY. These generally include individuals in prominent positions such as senior politicians, senior government, judicial or military officials; senior executives of State Corporations AND their family members and close associates. These individuals present reputational risk and potential conflict of interest and extra caution is required when opening their brokerage account and monitoring their account activity. The above definition is not intended to cover middle ranking / junior officials in above noted categories. However, prudence requires brokers to be careful. 2.1 RISK ASSESSMENT While a Customer applies for Opening of Account, the concerned Staff must ensure and signed the risk disclosure document, which must inter alia contain; 1. Whether the customer is entering into the business relationship as Principal or through representative 2. Nature of Service to be provided to customer, considering their risk profiles 3. All material information to be documented on the customer for determining risk profile 4. Terms and conditions to be signed in which any securities activity etc is involved. 5. Explanation of risk to customer and continuous advising on the various systemic and systematic risks of the market without putting the brokerage house into any responsibility or at risk. Whether the Customer; i. Non-resident ii. Legal persons or arrangement including non-governmental organizations; NGO/not for profit organizations (NPOs), trust /charities iii. Belonging to those Countries where CDD/KYC and antimony laundering are lax. iv. Business or activities present a higher risk of money laundering. 2.2 POLITICALLY EXPOSED PERSONS AND RISK PROFILES Due to obvious reasons, a strict diligence is require for any individual who is politically exposed regardless of his stature within a political organization. Forms for internal use must be fully properly and a decision is made by the management on how to treat this account and the level of risk to be allocated. High due diligence is required for such prospective clients and any suspicious activity is to be reported directly to the Chief Compliance Officer. Such accounts must be approved by senior management and the nominee director of the firm. Page 4 of 11

5 4.3 In general, please note that Brokers should conduct a self assessment for money laundering and terrorist financing risk, identifying and documenting the key risks presented by virtue of its business model, types of customers and geographical placement 2.3 TRANSACTION MONITORING The most important safeguard against money laundering is the ability to detect suspicious transactions and to take further action to prevent recurrence of such transactions. RECOGNISING SUSPICIONS OF MONEY LAUNDERING WHAT IS SUSPICION? As the types of transactions that may be used by a money launderer are almost unlimited, it is difficult to define a suspicious transaction. Suspicion is personal and subjective and falls far short of proof based on firm evidence. However, the suspicion must at least have some foundation and not just be based on mere speculation. A suspicious transaction will often be: any transaction where the amount, duration or other specific feature is inconsistent with the customer's professional or business activities, standard of living or normal movements on the account; and transaction that is not logical from an economic or financial point of view. 4.4 The bottom line is that brokers need to assess the risk of potential money laundering / terrorism financing and the guidelines and this commentary will help in documenting such risk if the broker assesses that it exists. The key to recognizing suspicions is based on having enough knowledge about a customer's normal expected transactions and financial circumstances to be able to recognize the abnormal/unusual, and from the abnormal, what might be suspicious. 2.4 The key to recognizing suspicions is based on having enough knowledge about a customer's normal expected transactions and financial circumstances to be able to recognize the abnormal/unusual, and from the abnormal, what might be suspicious. For example, a customer who is unemployed or working in a junior position but is making frequent large cash deposits may be involved in money laundering frauds. EXAMPLES OF SUSPICIOUS TRANSACTIONS Examples of what might constitute a suspicious transaction, by activity, are listed below. These are by no means exhaustive and only provide examples of some of the most basic ways by which money can be laundered. This should not be applied as a routine instrument in place of Common Sense. Identification of these types of transactions does not automatically establish suspicion, but should prompt enquiry and consideration of the circumstances. Due consideration should be given to the customer s explanation for such transactions but not every explanation can be accepted without scrutinizing the transaction. It is justifiable to suspect a customer who is reluctant to provide necessary information and documents to establish relationship. Dealers should pay more attention to customers who provide minimal or misleading information when opening an account or provide information that is difficult or expensive for the Brokerage House to verify. Transactions Which Do Not Make Economic Sense Page 5 of 11

6 3 ENHANCED DUE 3.1 REPORTING SUSPICIONS DILIGENCE 5.1 Once a customer has been categorized as HIGH RISK, it is necessary for the broker to have Enhanced Due Diligence (EDD) when dealing with such a customer. Policies and procedures should be put in place so that activities and transactions of HIGH RISK customers are monitored and any unusual transactions are reported in a SUSPICIOUS TRANSACTION REPORT (STR). All suspicions must be reported to the Compliance Head. Once a report has been made, all personal legal obligations have been met. All reports submitted are treated in the strictest confidence. The customer is never informed and to do so would be a criminal offence. REPORTING PROCEDURES FOR STAFF AND MANAGEMENT It is important that the reason for the suspicion is explained fully. It is of critical importance that such suspicions must not be discussed with anyone outside the Brokerage House. Care must be taken in discussing a suspicion, even with other colleagues, and if this is considered not to be appropriate, then discussion must only be held with the Compliance Head. It is vital that no mention of such suspicion is made to the customer. Any discussion of this nature would risk a tipping off offence being committed, if the customer became aware that a report had been submitted. All staff must note that once the reporting process has commenced, it must be followed through and completed, even if the original suspicion might appear to have been resolved. 5.2 In the above context, when dealing with high-risk customers, including Politically Exposed Persons (PEP s) either the Exchange member himself (in case of individual members) or nominee director/senior management of the corporate brokerage house, has to approve the opening of brokerage account. In the case of HIGH RISK CATEGORY customers, it is all the more important for brokers to determine the source of wealth and funds invested. It should be noted that this exercise of categorizing customers in LOW, MEDIUM, HIGH RISK category applies to all customers, including existing customers, Thus, once the broker has carried out the above exercise, if an existing customer falls into the HIGH RISK CATEGORY, the above requirements for monitoring and reporting suspicious transactions and senior management approval for continuing with the customer will also apply to such customer (s) The Compliance Head will examine all reports and make additional enquiries as 3.2 POLITICALLY EXPOSED PERSONS AND RISK PROFILES Due to obvious reasons, a strict diligence is require for any individual who is politically exposed regardless of his stature within a political organization. Forms for internal use must be fully properly and a decision is made by the management on how to treat this account and the level of risk to be allocated. High due diligence is required for such prospective clients and any suspicious activity is to be reported directly to the Chief Compliance Officer. Such accounts must be approved by senior management and the nominee director of the firm. 5.3 If the above requirements can not be fulfilled by the broker than they should not open the brokerage account of such person(s) and file a Suspicious Transaction Report (STR). In case an existing customer falls into HIGH RISK CATEGORY and the broker is unable to fulfill the above mentioned requirements, such account should be closed and a Suspicious Transaction 6 Report Similarly, filed. brokerage account should not be opened if the broker is unable to verify the identity of the customer / beneficial owner of the account, or if it is unclear what the purpose and intention of customer is and should file an STR. If there are any such existing accounts they should be closed and a Suspicious Transaction Report (STR) filed. 3.3 Amanah Investments Limited, generally not prefers opening of account of High Risk category customers. 4 Amanah Investments Limited, generally not prefers opening of account of persons and others which falls in High Risk Category. Reporting of Suspicious Circumstances If there are any suspicious circumstances surrounding the opening or operation of any account, the matter must be reported immediately to the Compliance Head. If it is established that the transaction under review is suspicious, Compliance Head after due diligence and necessary checks will report the transaction to regulatory authorities Page 6 of 11

7 4 ON-GOING DUE DILIGENCE 7.1 It is important for brokers and their agents to realize that Customer Due Diligence (CDD) is not a one-time exercise at the time of account opening only. In order to guard against misuse of their good offices against criminal transactions brokers need to be vigilant at all the times, and keep monitoring transactions of their customers to ensure that the transactions executed in any particular account are within the understanding of the Broker in terms of the customer s profile, risk category, historical pattern of the transactions and their historic funding source. For example, if a domestic individual customer orders a transaction that is significantly different from the average historical transaction size, the broker has to became alert and be satisfied that no suspicious reportable activity is taking place. Similarly, if a regular domestic customer, all of a sudden shows foreign sources of funds, this is likely to require further the investigation by the broker. 5.1 REVIEWING AND MONITORING CUSTOMER ACCOUNTS: THE NEED FOR VIGILANCE Whilst it can be assumed that the majority of customers are honest and that their transactions are legitimate, this is not always the case. As with all Brokerage Houses, there will be some prospective customers who approach the Brokerage House with the deliberate intention of using our services to launder criminal funds. It is hoped that the Brokerage House s enhanced procedures for account opening will identify these situations at the outset. However, it is not only prospective customers who may put the Brokerage House at risk. Occasionally, customers may seek deliberately to build up a degree of trust before they use the Brokerage House for other purposes; others may turn to crime because of a change in their personal circumstances. It is possible, therefore, that some existing customers may become deliberately or unintentionally involved in money laundering It is therefore vital that all staff is vigilant and that all unusual transactions for any customers are identified, discretely researched and, where there is a suspicion of money laundering, a report is made to the Compliance Head. The foundation of any monitoring procedure lies in the initial collection of identification and know your customer information and the ongoing updating of that information. Updating arises from regular contact with the customer and the results of regular monitoring procedures. 7.2 In the above context, brokers should keep all customer records updated and have a policy of assessing any change in customer profile on regular basis, which change should be documented and sufficient information should be obtained regarding such change. 5.2 UPDATING KNOWLEDGE OF THE CUSTOMER Staff members need to keep themselves up to date of the customer with particular reference to: documenting the customer's trading habits and patterns of transactions; documenting events or changes that are considered important for a sound knowledge of customers and their activities; noting customers with particularly large sums being credited to / debited from their accounts; providing easy and immediate access to customer and KYC information for the Compliance Head ; and ensuring that the true beneficial owner and source of all funds is known. Any request by the customer must be in writing as per the SAOF A file note must be completed recording every meeting and telephone conversation with the customer and filed in the customer file. Accounts where there is little personal contact with the customer should be subject to Page 7 of 11

8 5 SIMPLIFIED DUE DELIGENCE 8 The purpose of the KYC/CDD guidelines is not to make brokers operations unnecessarily cumbersome, but to help the broker community guard against their services from being used for money laundering by unscrupulous elements. In this regards: 6 guidelines on KYC Policy and CDD Policy of the Amanah Investments Limited ( AIL ), would assist management and staff to fully understand their obligations. This would particularly help AIL front-end staff having direct inter-actions with the customers and others. However, it is acknowledged by all that new regulations and subsequent amendments will require a regular update of procedures and skills to remain in line with best practices followed. AIL expects all management employees to carefully study these guidelines, which will assist them to meet their regulatory obligations, with integrity, concentrated efforts and team work.. The Policies mentioned in these guidelines have minimum requirements under normal circumstances. It is the responsibility of front-end office executives to identify and establish additional controls and strengthen KYC Policies and procedures. These guidelines are of course not the final word, but merely a risk advising guidelines and the essence of these guidelines and policies is the one key word, KYC. 8.1 it is acceptable for Brokers to apply simplified or reduced CDD measures in the following circumstances: a) risk of money laundering or terrorist financing is lower b) information on the identity of the customer and the beneficial owner of a customer is publicly available c) adequate checks and controls exist 6.1 SEMI ANNUAL REVIEW OF ACCOUNTS All dealers are responsible for monitoring the activity on their customers accounts in accordance with their knowledge of the customer s business and the expected activity on those accounts. Line manager should ensure that he undertakes a semi annual review of all accounts average monthly turnover is PKR Rs.5,000,000 or more. During the review, dealers should check that all transactions are in line with expected activity and that new information has been recorded. Attention should be paid to any new sources of income or unexpected use of the account. A file note confirming the date of the review should be placed on the customer s file. Any change in Customers financials status must be updated Page 8 of 11

9 8.2 Accordingly, following customers may be considered for simplified or reduced CDD: Financial institutions which are subject to requirement to combat money laundering and terrorist financing consistent with the FATF Recommendations and are supervised for compliance with those controls Public companies that are subject to regulatory disclosure requirements Government administrations or enterprises 6.2 At the moment Amanah Investments Limited do not prefers account(s) of financial institutions, public companies, Government administrations. 8.3 When opting for simplified or reduced due diligence, the FATF guidelines in this regard must be consulted. Simplified CDD should not be followed when there is an identified risk of money laundering or terrorist financing. 6.3 At the moment Amanah Investments Limited do not prefers account(s) of financial institutions, public companies, Government administrations, therefore, FATF regulations and guidelines kept in abayence. 6 COMPLIANCE FUNCTION 9.1 While the above noted KYC/CDD guidelines are being provided to help brokers and their agents understand the processes involved in KYC/CDD, it is important that a system be developed at the brokers end to implement these guidelines. This will help brokers to monitor customer transactions and report any suspicious activity in a timely manner. In order to achieve this objective two key elements have to be instituted at the brokers end: (i) Compliance Function with suitable human resource (ii) MIS reporting capability 7.1 Reporting of Suspicious Circumstances If there are any suspicious circumstances surrounding the opening or operation of any account, the matter must be reported immediately to the Compliance Head. If it is established that the transaction under review is suspicious, Compliance Head after due diligence and necessary checks will report the transaction to regulatory authorities THE COMPLIANCE HEAD IS RESPONSIBLE FOR: A position is set up for compliance of the various areas of the brokerage business. That compliance officer would have a role for: Ensuring that all segments of the Brokerage House are complying with the stated policy and therefore monitoring operations and development of the policy. Preparing and presenting compliance reports to the Senior Management. Advising Senior Management of any deviations from the policies and procedures that have been noted by Compliance Division during their reviews. Developing and maintaining policy in line with evolving statutory and regulatory obligations Page 9 of 11

10 9.2 In this context, the person responsible for compliance should be designated and he/she should have sufficient skills and experience to effectively perform the compliance function. In case of individual members of the Exchange, they should identify the person who will be responsible for compliance. In the case of corporate members of the Exchange the individual identified to ensure compliance should report to the Board of Directors of the Corporate Brokerage House. 7.2 THE COMPLIANCE HEAD IS RESPONSIBLE FOR: A position is set up for compliance of the various areas of the brokerage business. That compliance officer would have a role for: Ensuring that all segments of the Brokerage House are complying with the stated policy and therefore monitoring operations and development of the policy. Preparing and presenting compliance reports to the Senior Management. Advising Senior Management of any deviations from the policies and procedures that have been noted by Compliance Division during their reviews. Developing and maintaining policy in line with evolving statutory and regulatory obligations 9.3 It is the responsibility of the compliance function to ensure that KYC/CDD guidelines are being complied with as well as with other regulatory requirements. This includes maintaining record of violations / non-compliance indentified which has to be reported to the Board of Directors. Any such record has to be available for inspection by SECP and KSE as and when required. 7 DATA RETENTION 10 All data relating to KYC/CDD guidelines & procedures have to be maintained for a minimum of five years, including identity of the customer(s), account files and correspondence exchanged with the customer(s). 7.3 It is imperative that all concerned staff must ensure the proper implementation of KYC/CDD in letter and spirit. In case, any violation/non-compliance if any, proper record to kept and made available for inspection of SECP and PSX as and when they needed. 8 RECORD KEEPING / DOCUMENT RETENTION Records are to be retained to provide an audit trail and adequate evidence for the law enforcement agencies in their investigations. The minimum retention periods to comply with are: Account opening records and documentary evidence of identity - at least 5 years after the account is closed; Account ledger records - at least 5 years; and Individual transaction records - at least 5 years. In case of violations also by any customer, it is imperative that such records are kept and are highlighted through re determining the risk profile of the customer. RETRIEVAL OF DOCUMENTS Page 10 of 11

11 8 TRAINING 11 There has to be on-going training of brokers, their employees and agents to ensure that they understand their duties under KYC/CDD and are able to perform those duties satisfactorily. 9 TRAINING OF STAFF AND EMPLOYEES A continuous process of encouragement program is being planned by the company to ensure that all relevant staff and employees are updated with the latest compliance requirements, to ensure that a perfect ethical and integral system is run in the company. The staffs are encouraged to continually read new compliance rules and regulations as suggested by the regulators. The company ensures that the compliance team and all members have the sufficient knowledge and experience to determine a clients status and allocate a risk profile. The company would also undergo a strict compliance level, when screening for employees and make a clear profile as to the history of the prospective employee with regards to any violation s and market reputation. 9 SCREENING 12 In order to ensure, for their own safety, that unscrupulous elements do not become employees/agents, brokers should have appropriate screening procedures when hiring and also on an ongoing basis to ensure high standards of staff in terms of honesty, integrity, ethics and professionalism. This is important not just for the sake of brokers own safety and reputation but the reputation of the Capital Market. 10 Amanah Investments Limited only employee's those person who possessed high standard of professionalism and bears high values of honesty, integrity, ethics. Page 11 of 11