Customer Acceptance Policy

Preamble

COMET SPACE IT SERVICES LLC (hereinafter referred to as “Company”) has already formulated a Group Anti Money Laundering (AML) Policy, which establishes the standards of AML compliance and is applicable to all activities of the Company. The Group AML Policy highlights Know Your Customer (KYC) as one of the key AML standards. The availability of customer information is a critical element in the effective management of Money Laundering (ML) risks. The Group AML policy as well as the KYC/AML procedures already laid down by the Company, cover the aspects of customer identification/verification, the due diligence procedures to be adopted and in general the Company’s overall policy in regard to acceptance of customers or establishing a relationship. The Customer Acceptance Policy would form an integral part of the Group AML Policy. The features of the Customer Acceptance Policy are detailed below.

Definition of Customer

The term ‘Customer’ would refer to any person or entity whether a natural person, a juristic entity, a firm, a trust, an unincorporated association of persons, acting for itself or in any fiduciary capacity, who (i) for itself or on behalf of another, maintains an account or (ii) has a business relationship with the Company for availing any of the products or services of the Company or (iii) is a beneficiary of the transactions conducted by Professional Intermediaries [Professional Intermediaries include Stockbrokers, Chartered Accountants, Solicitors etc. as permitted under law or customary practices] or (iv) is connected with a financial transaction which can pose significant reputational or other risks to the Company.

Due Diligence for Account Opening/Closing

· The Company shall not open any account(s) in anonymous or fictitious/benami name(s). Adequate due diligence is a fundamental requirement for establishing the identity of the customer. Identity generally means a set of attributes which together uniquely identify a natural person or legal entity. In order to avoid fictitious and fraudulent applications of the customers, and to achieve a reasonable degree of satisfaction as to the identity of the customer, Strategic Business Units (SBUs) shall conduct appropriate basic due diligence. The nature and extent of basic due diligence measures to be conducted by the SBUs at the time of establishment of account opening/relationship, would be dependent upon the risk category of the customers and involve the collection and recording of information (including those as may be prescribed by the regulators, if any) by using reliable independent documents, data or any other information. This may include identification and verification of the applicant and wherever relevant, ascertaining of occupational details, legal status, ownership and control structure and any additional information in line with the assessment of the ML risks posed

by the applicant and the applicant’s expected use of the Company’s products and services. In case of certain products, the Company may rely upon the KYC procedures conducted by other Company’s having satisfactory customer identification procedures.

For non-face to face customers, appropriate due diligence measures (including certification requirements of documents, if any) will be devised by the SBUs for identification and verification of such customer. The purpose of commencing the relationship/opening of accounts shall be established and the beneficiary of the relationship/account shall also be identified. The due diligence measures to be adopted for various customer/product segments shall be outlined in the respective KYC/AML procedures laid down from time to time. The information collected from the customer shall be kept confidential.

· Appropriate Enhanced Due Diligence measures shall be adopted for customers, with a high-risk profile, especially those for whom the sources of funds are not clear, transactions carried through correspondent accounts and customers who are Politically Exposed Persons (PEPs) resident outside and their family members/close relatives. Politically Exposed Persons are individuals who are or have been entrusted with prominent public functions in a foreign country, e.g. Heads of States or of Governments, senior politicians, senior government/judicial/military officers, senior executives of state-owned corporations, important political party officials, etc. The KYC/AML procedures shall also specify that after gathering sufficient information including the source of funds, the decision to open an account for PEPs shall be taken at a reasonably senior level in the Company. Such accounts shall be subject to enhanced monitoring on an ongoing basis. In respect of unusual or suspicious transactions/applications or when the customer moves from a low risk to a high-risk profile, appropriate enhanced due diligence measures shall be adopted. The enhanced due diligence measures to be adopted for various customer/product segments shall be outlined in the respective KYC/AML procedures laid down from time to time.

· The Company shall ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations etc. or any other internal negative lists of the Company.

· The Company shall not open an account where the Company is unable to apply appropriate customer due diligence measures i.e. Company is unable to verify the identity and /or obtain documents required due to non cooperation of the customer or non reliability of the data/information furnished to the Company. On the same grounds, if the Company is not able to apply appropriate customer due diligence measures on an existing account, the Company shall take steps to close the account. However, the decision to close an existing account shall be taken by the respective Head of Business Group, after giving due notice to the customer explaining the reasons for such a decision.

Risk Profiling of customer/product segments

· The Company has adopted a risk-based approach in implementing its AML framework as spelt out in the Group AML Policy of the Company. This approach includes

assessment of various risks associated with different types of customer/product segments.

· The customer/product segments shall be categorised into high, medium and low risk categories, depending upon the perceived ML risks and customer behaviour. For the purpose of risk categorisation, customer segments comprising such individuals and entities whose identities and sources of wealth can be easily identified and transactions in whose accounts by and large conform to the known profile, may be categorized as low risk. Appropriate ML risk indicators (including those relating to customer's background, nature and location of activity, country of origin, sources of funds and client profile etc.) shall be analysed for categorisation of customer segments into medium/high risk. Customer segments that are likely to pose a higher than average risk to the Company may be categorized as medium or high-risk. The risk categorization of the customers shall be reviewed periodically. Appropriate ML risk parameters shall be considered for categorization of product segments, which shall be laid down in the KYC/AML procedures for different products.

· The SBUs of the Company shall conduct risk profiling of the various customer segments periodically and submit the risk profile to the Money Laundering Reporting Officer (MLRO). The customer profile may contain information relating to customer’s identity, social/financial status, nature of business activity, information about clients’ business and their location etc. The MLRO shall approve the risk profiles with such changes thereto as may be required in consultation with the respective SBUs.

· The Company may prepare a profile of the customer based on available information. Considering the large volumes of business, it would be necessary that appropriate software systems would have to be developed to capture the individual customer profile information, especially for high risk customers. The customer profile information shall be a confidential document.

Documentation

· The Company shall obtain satisfactory evidence of the identity of the customer depending upon the perceived risks at the time of commencement of relationship/opening of account. Such evidences shall be substantiated by reliable independent documents, data or information or other means like physical verification etc. In order to avoid customer inconvenience, under special circumstances, the Company may rely on certain data/information available with itself or with external reliable sources for the purpose of establishing the identity of the customer. In such cases, a KYC report in a specified format shall be prepared and approved by an appropriate senior official, as may be specified in the KYC/AML procedures. The KYC report shall be stored properly along with other KYC documents.

· Customer specific documentation requirements and other information that is required to be collected would be spelt out separately in the KYC/AML procedures. These documentation requirements and other information requirements shall be reviewed from time to time and would also take into

account the requirements of the various laws/regulations including AML Laws and Central Bank guidelines

Account opened/operated on behalf of another person/entity

There could be occasions when an account is operated by a mandate holder or in a fiduciary capacity. Under such circumstances, appropriate procedures will be followed.