IGCJD will use its best endeavors and correspond with its ability to influence promoting responsible business practices among its significant business partners.
KNOW YOUR CUSTOMER/VENDOR (KYC): IDENTIFICATION AND VERIFICATION
IGCJD will identify and verify the identity of all their customers, suppliers, and business partners using reliable, independent source documents, data, and information.
All customers, suppliers, and business partners are required to provide proof of incorporation or similar evidence of the legal status of the legal person or arrangement, as well as information concerning the business partner’s name, the names of trustees, legal form, address, directors, and provisions regulating the power to bind the legal person or arrangement.
Any person purporting to act on behalf of the customer, supplier, or other business partner must validate that he/she is authorized to do so, and the identity of the person must be provided.
All new customers and suppliers must complete the Customer/Supplier Verification Form.
IGCJD must take reasonable measures to identify and verify the identity of the Ultimate Beneficial Owner (UBO) of any customer, supplier, or other business partner, including forming an understanding of the ownership and control structure, such that IGCJD is satisfied that it knows who the UBO is. The type of measures needed to satisfactorily perform this function would require the following actions:
- identification of the UBOs: the natural persons who, whether acting alone or together or through one or more juridical persons, exercise control through ownership or voting rights, or who ultimately have a controlling ownership interest.
- if unable to identify the UBO, identification of the natural persons who comprise the Senior Management of the legal person or arrangement.
- after identification of the UBO or Senior Management: verification of the data through the Bureau Van Dijk global KYC Database, which contains 250 million companies worldwide with information about directors, shareholders, UBOs, FATF countries, sanction lists, and individuals worldwide, and to which IGC has access. The database comprises two sets of data:
- Orbis: Company Verification Database
- WorldCompliance: Individuals Verification Database
Where the customer, supplier, or the owner of the controlling interest is a public listed company that is subject to regulatory disclosure requirements, it is not necessary to seek identification and verification of the identity of any shareholder of that company.
Additional documentation is required:
- AML declaration completed and signed;
- RJC COP compliance declaration completed and signed;
- U.S. Patriot Act and BSA Compliance Form completed and signed.
IGCJD must conduct ongoing due diligence on their business relationships and scrutinize all transactions undertaken throughout the course of that relationship. Any customer, supplier, or other business partner with whom no transactions have been conducted over the past 12 months, and with whom a new transaction is presented, will automatically be subject to a fresh and integral KYC identification and verification procedure.
IGCJD bears the ultimate responsibility for accepting a business partner and conducting a transaction. Therefore, strict and comprehensive due diligence is substantial to protect IGCJD and its business.
RISK ASSESSMENT, MANAGEMENT, AND MITIGATION
IGCJD must identify, assess, and prioritize potential risk and undertake the required actions to mitigate, monitor, minimize, and control the probability of money laundering activity. The Compliance Officer must intensify his/her investigation measures to the degree of perceived risk in situations that seem to bear an increased chance of money laundering or terrorism financing.
IGCJD appoints an internal Compliance Officer who is responsible for implementing the KYC policy and procedure and updating the information on a regular basis.
IGCJD works together with an external Compliance Officer of IGC Group NV, who manages the customer/vendor inquiries and database.
The external Compliance Officer reviews the management system on a regular basis, at least once per year, and discloses in a yearly report to the IGCJD BOD if any red flags or concerns were detected.
The external Compliance Officer verifies that IGCJD’s main suppliers have carried out due diligence and annually reviews this information.