Anti-Money Laundering Policy and Procedure

Introduction

Evea Limited (“EVEA”) 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.

To fulfill this commitment, EVEA has established internal policies and procedures. This Policy establishes standards that every employee, contractor, and business partner of EVEA 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 collecting funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially used, for the committing of terrorist acts.

This Policy is aimed at preventing any company or individual from using EVEA for money laundering or terrorist financing activities.

2.Our Policy

2.1Customer Due Diligence

To prevent Money Laundering, EVEA will implement processes and procedures in its Lines of Business (LOBs) to conduct appropriate customer due diligence through EVEA’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 EVEA’s Business Codes.

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

2.2Risk-Based Approach

For EVEA, the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business that EVEA’s customers carry out or on the country where EVEA’s customers are located.

EVEA 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.

2.3High-Risk Customers

EVEA will not do business with the following segments of customers:

• Persons and/or businesses included in any official lists of sanctions, in line with the EVEA Sanctions Policy.
• Persons and/or businesses 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.
• Entities whose shareholder/control structure cannot be determined.

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

2.4Record Keeping

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

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

2.5Designation of Anti-Money Laundering Reporting Officer (AMLO)

EVEA 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.
• 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 how to proceed after a report of suspected money laundering has been raised.
• Designing and implementing Anti-Money Laundering processes and procedures.

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

3.Reporting Suspicious Activity

EVEA 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 be done by contacting the AMLO or their deputy directly.

A report on the 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 otherwise involved.
• A statement of the facts.
• What is suspected and why.
• Any possible involvement of EVEA.

The AMLO may make reasonable enquiries within EVEA to confirm these suspicions or obtain additional information. 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

EVEA 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 them 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 EVEA Internal Audit function. This provides Executive Management and the Board Audit Committee with the necessary assurance and information regarding the operating effectiveness of EVEA’s controls and processes relating to this Policy.