KYC (Know Your Customer) Policy

Reddington Financial Advisory Private Limited (“Reddington,” “we,” “our,” or “us”) is committed to maintaining high standards of transparency and integrity in our financial dealings. Our Know Your Customer (KYC) Policy is designed to ensure that we adequately verify the identity of our clients, understand the nature of their activities, and manage the associated risks effectively. This policy helps us comply with legal and regulatory obligations while protecting against fraud, money laundering, and other financial crimes.

1. Purpose

The purpose of this KYC Policy is to:

• Verify the identity of clients and investors to prevent fraud, money laundering, and terrorist financing.
• Understand the financial background and activities of our clients and investors.
• Comply with regulatory requirements and guidelines, including those set forth by the Reserve Bank of India (RBI) and other relevant authorities.
• Mitigate financial, operational, and reputational risks associated with client relationships.

2. Scope

This policy applies to all clients, investors, and counterparties engaging with Reddington, including:

• Individual investors.
• Corporate entities, partnerships, trusts, and other legal structures.
• Any other parties involved in financial transactions with Reddington.

3. KYC Procedures

3.1 Client Identification Process (CIP)

The Client Identification Process involves the collection and verification of the following information for individuals and entities:

3.1.1 Individuals

• Full Name: As per government-issued identification.
• Date of Birth: Verified through official documents such as a passport, Aadhaar card, voter ID, or driver’s license.
• Permanent Address: Verified through utility bills, bank statements, or similar documents.
• Contact Information: Phone number and email address.
• Government-Issued Identification: PAN card, Aadhaar card, passport, voter ID, or similar identification.
• Photograph: Recent passport-size photograph.

3.1.2 Corporate Entities

• Company Name and Registration Number: As per incorporation documents.
• Registered Address and Contact Information: Verified through official documents.
• Directors/Owners/Shareholders: Identification documents and KYC of key individuals (e.g., PAN card, Aadhaar card, passport).
• Memorandum and Articles of Association: Verified to understand the business structure and governance.
• Board Resolution: Authorizing the individual to act on behalf of the entity.
• Ultimate Beneficial Owner (UBO): Identification of individuals who ultimately own or control the entity.

3.1.3 Partnerships/Trusts

• Partnership Deed/Trust Deed: Verified to understand the structure and management of the partnership or trust.
• Identification of Partners/Trustees: KYC documents of all partners or trustees, including PAN card, Aadhaar card, passport, or other valid identification.
• Registered Address and Contact Information: Verified through official documents.
• Ultimate Beneficial Owner (UBO): Identification of individuals who ultimately own or control the partnership or trust.

3.2 Verification of Documents

All documents provided by clients or entities must be verified through:

• In-Person Verification (IPV): Physical verification of documents and identity, where applicable.
• Third-Party Verification: Cross-checking documents against databases or third-party services for authenticity.
• Digital Verification: Use of digital KYC methods, including OTP-based Aadhaar verification, where applicable.

3.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied in cases where higher risks are identified, such as:

• High-Risk Clients: Clients from high-risk jurisdictions, politically exposed persons (PEPs), or those with complex ownership structures.
• Large Transactions: Transactions that exceed a certain threshold or involve significant sums of money.
• Unusual Activity: Clients or transactions that exhibit unusual behavior or patterns.

EDD involves:

• Additional Documentation: Collection of additional documents to verify the source of funds and the nature of the business.
• In-Depth Analysis: Detailed scrutiny of the client’s background, including financial history and business activities.
• Ongoing Monitoring: Continuous monitoring of the client’s activities to detect any suspicious behavior.

3.4 Ongoing Monitoring and Updating

We continuously monitor the activities of our clients and update their KYC information periodically to ensure it remains current and accurate:

• Transaction Monitoring: Regular monitoring of transactions for any suspicious or unusual activity.
• Periodic Reviews: Updating KYC information at regular intervals or when significant changes occur, such as changes in ownership or address.
• Re-KYC: Re-verification of client information as required by regulatory guidelines.

3.5 Risk Categorization

Clients are categorized based on the level of risk they pose:

• Low Risk: Clients with straightforward structures, verified identities, and minimal transactions.
• Medium Risk: Clients with moderate complexity or those engaged in activities that may pose a moderate level of risk.
• High Risk: Clients with complex structures, high transaction volumes, or those from high-risk jurisdictions.

Risk categorization helps us tailor our KYC and monitoring efforts according to the risk level.

4. Compliance with Regulatory Requirements

4.1 Regulatory Framework

Our KYC Policy complies with the regulations and guidelines issued by:

• Reserve Bank of India (RBI): Adhering to RBI’s KYC/AML guidelines.
• Foreign Exchange Management Act (FEMA): Compliance with FEMA for transactions involving foreign clients or entities.
• Prevention of Money Laundering Act (PMLA): Ensuring that our practices are in line with the PMLA to prevent money laundering activities.

4.2 Reporting Obligations

We fulfill our regulatory reporting obligations by:

• Suspicious Transaction Reports (STRs): Reporting any suspicious transactions or activities to the Financial Intelligence Unit (FIU) as required by law.
• Cash Transaction Reports (CTRs): Reporting large cash transactions exceeding regulatory thresholds.
• Record-Keeping: Maintaining records of all KYC documents and transaction details for the period specified by regulatory authorities.

4.3 Regulatory Audits

We conduct regular internal audits and comply with external regulatory audits to ensure adherence to KYC and AML regulations.

5. Roles and Responsibilities

5.1 Board of Directors

The Board of Directors is responsible for:

• Approval: Approving the KYC Policy and any significant updates or changes.
• Oversight: Providing oversight to ensure the KYC Policy is effectively implemented.

5.2 Compliance Officer

The Compliance Officer is responsible for:

• Implementation: Ensuring that the KYC Policy is implemented across the organization.
• Monitoring: Regularly monitoring compliance with KYC requirements and addressing any issues.
• Reporting: Reporting any significant issues or regulatory non-compliance to the Board of Directors.

5.3 Employees

All employees involved in client interactions and financial transactions are responsible for:

• Compliance: Adhering to the KYC Policy in their daily operations.
• Document Collection and Verification: Ensuring that all required documents are collected and verified in accordance with the policy.
• Incident Reporting: Reporting any suspicious activity or potential non-compliance to the Compliance Officer.

6. Data Protection and Confidentiality

6.1 Data Security

We protect client information by:

• Encryption: Encrypting all sensitive data during transmission and storage.
• Access Controls: Restricting access to KYC data to authorized personnel only.
• Secure Storage: Storing physical and digital records securely to prevent unauthorized access.

6.2 Confidentiality

We ensure the confidentiality of client information by:

• Non-Disclosure: Not disclosing client information to unauthorized third parties unless required by law.
• Data Retention: Retaining KYC data for the period required by law and securely disposing of it thereafter.

7. Training and Awareness

7.1 Employee Training

We provide regular training to our employees on:

• KYC Requirements: Understanding the importance of KYC and the specific requirements for client identification and verification.
• AML Practices: Training on Anti-Money Laundering practices and how to identify suspicious activities.
• Regulatory Compliance: Ensuring employees are aware of the latest regulatory changes and how to comply with them.

7.2 Awareness Campaigns

We conduct regular awareness campaigns to:

• Highlight Risks: Educate employees about the risks of non-compliance with KYC regulations.
• Promote Best Practices: Encourage adherence to best practices in client identification, document verification, and transaction monitoring.

8. Policy Review and Updates

This KYC Policy is reviewed and updated annually or more frequently as required by changes in regulatory requirements or business practices. All updates are approved by the Board of Directors and communicated to all relevant stakeholders.

9. Non-Compliance and Penalties

Non-compliance with the KYC Policy can result in:

• Disciplinary Action: Employees who fail to comply with the policy may face disciplinary action, including termination of employment.
• Legal Consequences: Non-compliance with regulatory requirements can result

10. Closing Note

Reddington Financial Advisory Private Limited remains committed to fostering a secure and compliant financial environment through stringent adherence to KYC principles. We recognize the importance of building trust with our clients and stakeholders by ensuring that all financial transactions are conducted transparently and securely. Adhering to this policy not only helps us meet regulatory requirements but also strengthens our ability to manage risks effectively, protect our reputation, and uphold the integrity of our financial services. We appreciate the cooperation of our clients and partners in complying with these procedures, as they are vital to the success and sustainability of our operations.