's policy is to prohibit and actively carry outmoney laundering prevention activities and any activities that help to laundermoney or finance terrorist or criminal activities. The company requires itsmanagers, employees, and branches to comply with these standards to prevent theuse of its products and services for money laundering purposes.

1.1 Definition

For this policy, money laundering is usually defined asparticipating in an act aimed at disguising the real source of income fromcrime, so that illegal income appears to originate from a legitimate source orconstitute a legal asset.

Generally, money laundering is divided into three stages. Cashfirst enters the financial system during the "placement" phase,during which cash generated from criminal activities is converted into monetaryinstruments, such as money orders or traveler's checks, or is deposited intothe accounts of financial institutions. In the "stratification"stage, funds are transferred to other accounts or other financial institutionsfurther to separate the money from the source of the crime. In the"integration" phase, funds are reintroduced into the economy and usedto purchase legal assets or provide funds for other criminal activities orlegitimate businesses. Terrorist financing may not involve the proceeds ofcriminal acts but attempts to conceal the source or intended use of funds andthen use them for illegal purposes.

1.2 Policy statement

The following statement will guide the principles andprocedures of the anti-money laundering compliance program.


·        ·        ·        ·        ·        ·        ·        Communicate this policy effectively to raise employees' Awarenessof the issue of anti-money laundering/terrorism financing

2. Maintenance requirements and record retention

FOODKOKO will keep all necessary domestic and internationaltransaction records for at least five (5) years after the transaction iscompleted or for a more extended period required by the SEC or NFIU. Allsuspicious transactions will be kept in the same period.

3. Normative and law enforcement agency requests for AMLrecords

At the request of regulatory agencies or law enforcementagencies, FOODKOKO will provide documents related to AML compliance or itscustomers as soon as possible from the date of the request.

4. Transaction report

FOODKOKO will conduct due diligence to identify and reportsuspicious transactions. Suspicious transactions will include:

• Structured transactions to avoid reporting and recordretention requirements.

• FOODKOKO believes that there is a change or wrongidentification, inconsistent information or any transaction involving criminalactivity

• Entities that belong to individuals or organizationsregarded as terrorists.


FOODKOKO will ensure the timely and accurate delivery of allAML returns specified in the SEC AML rules and regulations and other relevantregulations/acts/guidelines/circular letters that various government agenciesmay regularly issue.


5. Awareness and training

FOODKOKO will enhance its employees' Awareness of AML througha robust training program (including formal courses, workshops, andnewsletters). Such training will incorporate current developments and changesto relevant guidelines, as well as internal policies, procedures, processes,and monitoring systems.

FOODKOKO will also use other channels such as e-mail, screensavers for laptops, displays, posters, etc.

6. Scope

This policy manual applies to FOODKOKO and its board ofdirectors, administrative and personnel boards to comply with the rules andregulations governing its operations. Explicitly, the "Anti-MoneyLaundering Policy” will incorporate business marketing, business origins,market regulations, review panel operations, and any other relevant groups inFOODKOKO.

7. Results

Violation of anti-money laundering laws and combating thefinancing of terrorism are serious crimes that can lead to lengthyinvestigations, significant fines, and criminal penalties (includingimprisonment of employees).

8. Reference

The policy complies with the requirements of the Nigeria Securitiesand Exchange Commission (SEC) regarding capital market operators' efforts tocombat money laundering and terrorist financing (AML).

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