Subsi AML

ANTI-MONEY LAUNDERING POLICY AND PROCEDURE

1. INTRODUCTION

1.1. Purpose The purpose of this Anti-Money Laundering (AML) policy is to outline the measures and procedures adopted by Subsi Stores Limited to prevent and detect money laundering and terrorist financing activities in compliance with the laws and regulations of Nigeria. 2. LEGAL AND REGULATORY FRAMEWORK

2.1 Compliance Subsi Stores Limited is committed to complying with all relevant anti-money laundering laws and regulations in Nigeria. This includes but is not limited to the Money Laundering (Prohibition) Act 2011, the Terrorism (Prevention) Act, and any other applicable regulations issued by regulatory authorities.

3. RISK ASSESSMENT

3.1. Risk Identification Subsi Stores Limited will conduct a risk assessment to identify and evaluate the money laundering and terrorist financing risks associated with its business activities in Nigeria.

3.2 Customer Risk Assessment Subsi Stores Limited will assess the risk associated with each customer, taking into consideration factors such as the nature of the business relationship, customer location, and transaction patterns, by Nigerian regulations.

4. CUSTOMER DUE DILIGENCE (CDD)

4.1.Customer Identification Subsi Stores Limited will implement procedures to verify and unveil the identity of customers, including individuals, entities, and beneficial owners, as required by the Money Laundering (Prohibition) Act 2011.

4.2 Enhanced Due Diligence (EDD) Enhanced due diligence measures will be applied to customers and transactions that present a higher risk of money laundering or terrorist financing, as mandated by Nigerian regulations.

5. REPORTING AND RECORD KEEPING

5.1 . Suspicious Activity Reporting Subsi Stores Limited will establish procedures for employees to report any suspicion of money laundering or terrorist financing promptly to the Nigerian Financial Intelligence Unit (NFIU) as required by law.

5.2 Record Keeping Subsi Stores Limited will maintain records of customer identification, transactions, and other relevant documentation by the record-keeping requirements of the Money Laundering (Prohibition) Act 2011.

6. TRAINING AND AWARENESS

6.1 Employee Training Subsi Stores Limited will provide training to employees on AML policies, procedures, and relevant Nigerian laws and regulations, including updates as required.

6.2 Awareness Program Subsi Stores Limited will implement an ongoing awareness program to ensure that employees are informed about the latest developments in AML regulations in Nigeria.

7. MONITORING AND COMPLIANCE

7.1 Monitoring Transactions Subsi Stores Limited will implement systems and procedures to monitor transactions for unusual or suspicious activities as required by Nigerian regulations.

7.2 Compliance Review Regular reviews of the AML program will be conducted to ensure ongoing compliance with the Money Laundering (Prohibition) Act 2011 and other applicable regulations in Nigeria.

8. COMMUNICATION AND REPORTING

8.1 Internal Communication Subsi Stores Limited will establish clear lines of communication for reporting AML-related concerns within the organization.

8.2 Reporting to Regulatory Authorities Subsi Stores Limited will promptly report any suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) as required by the Money Laundering (Prohibition) Act 2011.

9. REVIEW AND UPDATES

9.1 This AML policy will be reviewed periodically and updated as necessary to reflect changes in Nigerian regulations, business activities, and risk assessments.

10. ENFORCEMENT AND PENALTIES

10.1 Violations of this AML policy may result in disciplinary action, including termination of employment, and may be subject to legal action as provided by Nigerian law.

11. CONTACT INFORMATION

11.1 Contact Company Secretary Management@subsi.com.ng;

Date of Last Update: 27/11/2023