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At Capgemini Finance Service Ltd, we specialize in creating comprehensive KYC and CIP policies tailored to meet regulatory standards and enhance customer trust.

Know Your Customer (KYC) & Customer Identification Program (CIP) Policy

1. Introduction

Capgemini Finance Service Ltd ("the Company") provides financial advisory services and is committed to maintaining the integrity and legitimacy of its business activities. While the Company does not operate under Financial Conduct Authority (FCA) regulations, it voluntarily adopts Know Your Customer (KYC) and Customer Identification Program (CIP) procedures to ensure responsible client engagement. This policy helps the Company avoid any associations with illicit activities such as money laundering or fraud and align with the expectations of banking partners.

2. Purpose

The primary purpose of this policy is to:

• Establish clear procedures for identifying and verifying customers.

• Implement due diligence measures for onboarding new clients.

• Manage and mitigate potential client risks through a Risk-Based Approach (RBA).

• Ensure compliance with general business integrity standards while acknowledging that Capgemini Finance Service Ltd is not an FCA-regulated entity.

3. Scope

This policy applies to:

• Individual Clients: Engaging with the Company for financial advisory services.

• Corporate Clients: Businesses seeking consultancy or intermediary services.

It covers all advisory activities but does not extend to services involving financial transactions or the handling of client funds.

4. Client Identification Program (CIP)

4.1 Information Collection

To verify the identity of clients, Capgemini Finance Service Ltd collects the following information:

For Individual Clients:

• Full legal name.

• Residential address.

• Date of birth.

• Nationality.

• Government-issued photo identification (e.g., passport, driving license).

• Proof of address (e.g., utility bill, bank statement).

For Corporate Clients:

• Full registered name of the company.

• Company registration number and incorporation documents.

• Registered office address.

• Details of directors and beneficial owners.

• Nature of the business and business activities.

4.2 Verification Procedures

The Company verifies the accuracy of the information provided through reliable, independent sources:

• For Individuals: Verification is conducted through government-issued IDs and proof of address documents.

• For Corporate Clients: The Company verifies incorporation documents and cross-checks the identities of directors and beneficial owners.

4.3 Simplified Customer Due Diligence

In cases where the risk of money laundering or fraud is deemed low, the Company applies simplified due diligence to streamline the onboarding process while still collecting basic identification information.

5. Risk-Based Approach (RBA)

Capgemini Finance Service Ltd follows a Risk-Based Approach (RBA) to client due diligence, which allows the Company to focus resources on higher-risk clients and mitigate the risk of financial crime.

5.1 Risk Assessment Factors

The Company assesses the following risk factors:

• Geographical Risk: Clients from jurisdictions with weak AML controls or those identified by the Financial Action Task Force (FATF) as high-risk are subject to enhanced due diligence (EDD).

• Client Risk: Clients who are politically exposed persons (PEPs), have complex corporate structures, or are involved in high-value transactions may undergo additional scrutiny.

• Service Risk: Clients seeking high-value consultancy or advisory services may present a higher financial crime risk.

5.2 Enhanced Due Diligence (EDD)

For higher-risk clients, Capgemini Finance Service Ltd performs Enhanced Due Diligence (EDD) measures, which include:

• Obtaining additional identification documents.

• Conducting in-depth background checks on clients and their businesses.

• Gathering information about the source of wealth and funds.

• Obtaining approval from senior management for onboarding high-risk clients.

6. Ongoing Monitoring

Although the Company does not engage in financial transactions or manage client funds, it will monitor client activities to ensure that the advisory services align with clients' expected business behaviour.

6.1 Transaction Monitoring

Any unusual activity related to client requests (e.g., requests for advice involving potentially illegal activities or attempts to bypass due diligence checks) will be flagged and reviewed by the Compliance Officer.

6.2 Periodic Reviews

Client information is reviewed periodically to ensure that records remain up-to-date and that client profile changes (e.g., business expansion, high-risk behaviour) are appropriately recorded.

7. Data Security and Confidentiality

Capgemini Finance Service Ltd ensures that all client data collected through the KYC process is protected under GDPR and other applicable data protection laws. All client information is stored securely, and access is restricted to authorized personnel only.

8. Record Keeping

The Company retains records of all customer identification, risk assessments, and related documentation for at least 5 years after the end of the business relationship. This ensures that the Company maintains an audit trail and can demonstrate compliance with its voluntary KYC/CIP obligations.

9. Employee Training

Capgemini Finance Service Ltd trains all employees in client-facing roles, particularly those responsible for client onboarding and advisory services. The training focuses on identifying suspicious behaviour, reporting red flags, and complying with the Company’s KYC/CIP policy.

10. Voluntary Compliance with Best Practices

While Capgemini Finance Service Ltd is not subject to FCA regulation, the Company voluntarily adheres to certain elements of AML and KYC regulations to ensure that its services are not used for illegal purposes. By adopting this policy, Capgemini Finance Service Ltd maintains its commitment to business integrity and avoids association with financial crimes.

11. Policy Review

This KYC/CIP policy will be reviewed annually or as necessary to ensure that it remains current with the Company’s operations and aligned with general business best practices. Any updates required by industry standards or client engagement changes will be incorporated promptly.