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Step 1 of 2

1.) COMPANY DETAILS

1.2 Registered Address
1.3 Is Business Address same as Registered Address?
Write N/A if not listed anywhere
Write N/A if no website
Write N/A if no answer
**Please provide a Group Chart via Email

2.) BUSINESS ACTIVITY

2.2 Does the company hold a license to conduct its business(es)?

3. BENEFICIAL OWNERS

3.1 List of All Shareholders : (Please mention all the shareholders)

*** If more than 5 entries, please send the shareholding chart with KYC on email.

3.2 List of All Ultimate Beneficial Owners : (Please mention all the UBO)

*** If more than 5 entries, please send the shareholding chart with KYC on email.
3.3 Does your Company or any of your Shareholders / UBOs / Directors falls under the category of PEP?

4. MANAGEMENT STRUCTURE

4.1 Board of Directors :

4.2 Details of Authorized Signatory :

4.3 Department Information :

5. HUMAN RESOURCES

6. ORIGIN OF PHYSICAL PRECIOUS METALS

6.1 Type of Entities of your precious metals suppliers
6.3 Is the Company legally required to have a licence to import / Export precious metals? (If Yes, Copy required)

7. FACILITIES

7.1 Does the company have any melting or refining facilities?
7.2 Does the Company have any manufacturing facilities?
7.3 Does the Company produce its own jewellery?
7.4 What are the types & forms of precious metals sourced by the Company?
7.5 What type of precious metals is the Company planning to send for refining?
7.6 What is the form of precious metals planned to be sent for refining?

8. RESPONSIBLE PRECIOUS METAL SUPPLY CHAIN POLICY

8.1 Did your institution establish a responsible supply chain of gold from conflict-affected and high risk areas policy which is consistent with the standards set forth in the model supply chain policy in Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas?
*If Yes, Copy of the policy Required
8.2 Does your institution comply or plan to comply with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas?
8.3 Is the company complying with any of the following industry initiatives?

9. ANTI MONEY LAUNDERING (AML) & COMBATING FINANCIAL TERRORISM (CFT)

9.1 Is your institution subject to Anti-Money Laundering / Combating financial terrorism Law / Regulations?

10. BRIBERY POLICY

10.1 Does your Company have any bribery policy in place?
10.2 Has the company or the Senior Management ever been charged anywhere in the world for violation of applicable anti-bribery laws or regulations?

11. DATA PRIVACY PROTECTION

11.1 Does your company have Data Protection Policy?
11.2 Does your company have a certified data storage system or an information system?

12. PRECIOUS METALS SUPPLIERS DUE DILIGENCE QUESTIONAIRE

12.1 Does the Company have a person responsible (Compliance Officer) for all AML-CFT matters (Due Diligence, AML policies, internal training)?
12.2 Is the Company subject to an AML-CFT audit by an independent party or a governmental party?
12.3 Does the Company have an AML-CFT training for the employees?
12.4 Does the Company delegate to third parties some of the compliance functions to be carried out?

12.6 What type of information does the Company request from its precious metals suppliers?

Companies / Banks / Any other Institutions
Individuals Suppliers / Shareholders / UBO's
12.7 Does the Company have a risk-based assessment of its precious metals suppliers (e.g. low, medium or high risks)?
12.8 Does the Company screen precious metals suppliers and transactions against sanctioned lists of persons, entities or countries issued by government / competent authorities?
12.9 Does the Company perform enhanced due diligence for high risk precious metals suppliers?
12.10 Does the Company assess its corporate precious metals suppliers’ AML-CFT and purchase procedures and practices?
12.11 Does the Company perform a risk-based assessment to understand the normal and expected transactions of its suppliers (in order to identify the unusual transactions)?
12.12 Does the Company have a monitoring program for unusual and potentially suspicious activity that covers funds transfers and monetary instruments (e.g. traveller’s cheques) or third party payments?
12.13 Does the Company have to register all purchases and sales?
12.14 By what mode does the company accept / make payment to its client?
12.15 Does the Company have a procedure in place to prevent, detect and report suspicious transactions from its suppliers to the relevant Authority?
12.17 Where cash transaction reporting is mandatory, does the Company have procedures to identify transactions structured to avoid such obligations?

13. TRANSACTION MONITORING ON PURCHASE FROM INDIVIDUALS

13.1 Does the company deals with Individuals?
13.2 Does the Company perform statistics on precious metals sold by person in order to identify unusual transactions?
13.3 Does the Company have a specific procedure if a deal with an individual is significantly higher than the average deal?
13.4 Is the Company able to verify that a person does not come several times to the counter / to the different counters to sell each time a small amount which leads to a considerable amount in total (smurfing)?

14. INDUSTRIAL SOURCING (To Be Filled Only By Industrial Companies)

14.1 Does your company falls under the category of Industrial Company?
14.2 What is the form of precious metals planned to be sent for refining?
14.4 From whom do you source your precious metal products?

15. BANK DETAILS

16. SIGNATURES

I hereby declare that the information given above is true and accurate as of the date of writing.
I undertake to inform Zenith Metals DMCC of any material changes in the above details immediately.
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