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Financial Crime Policy

Last updated: April 9, 2025

1. Introduction

Kuinji is committed to maintaining the highest standards of ethics and integrity in all our business activities. This Financial Crime Policy outlines our approach to preventing, detecting, and responding to financial crimes, including fraud, bribery, corruption, money laundering, terrorist financing, and sanctions violations.

2. Policy Statement

Kuinji has zero tolerance for financial crime of any kind. We are committed to:

  • Complying with all applicable laws and regulations related to financial crime
  • Implementing robust controls to prevent and detect financial crime
  • Promoting a culture of integrity throughout our organization
  • Conducting thorough due diligence on clients, business partners, and third parties
  • Training employees to identify and report suspicious activities
  • Cooperating fully with law enforcement and regulatory authorities

3. Scope

This policy applies to all employees, directors, contractors, consultants, and business partners of Kuinji. It covers all business activities and operations, including client engagements, procurement, and financial transactions.

4. Anti-Fraud Measures

To prevent and detect fraud, we have implemented the following measures:

  • Segregation of duties in financial transactions and approval processes
  • Regular internal audits and financial controls
  • Robust due diligence procedures for clients and business partners
  • Whistleblowing mechanisms for reporting suspected fraud
  • Regular fraud risk assessments

5. Anti-Bribery and Corruption

Kuinji prohibits all forms of bribery and corruption. We do not offer, give, request, or accept bribes, facilitation payments, or other improper advantages, directly or through third parties. Our anti-bribery measures include:

  • Due diligence on business partners and third parties
  • Controls over gifts, hospitality, and political or charitable contributions
  • Transparent and accurate record-keeping of all transactions
  • Regular training on anti-bribery and corruption for employees

6. Sanctions Compliance

We comply with all applicable economic and trade sanctions. Our sanctions compliance measures include:

  • Screening clients and business partners against sanctions lists
  • Conducting enhanced due diligence for high-risk jurisdictions
  • Ongoing monitoring of business relationships
  • Regular review and updating of our sanctions compliance procedures

7. Risk Assessment

We conduct regular risk assessments to identify and mitigate financial crime risks in our business. These assessments consider:

  • Country and geographic risks
  • Client and business partner risks
  • Transaction and service risks
  • Delivery channel risks

8. Due Diligence

We apply risk-based due diligence to all business relationships. This includes:

  • Identifying and verifying the identity of clients and business partners
  • Understanding the nature and purpose of business relationships
  • Identifying beneficial owners and controlling interests
  • Assessing the financial crime risk posed by the relationship
  • Applying enhanced due diligence for higher-risk relationships

9. Monitoring and Reporting

We monitor transactions and business relationships for suspicious activity. Any suspicious activity will be promptly reported to the appropriate authorities in accordance with applicable laws and regulations.

10. Training and Awareness

All employees receive regular training on financial crime risks and prevention. This training covers:

  • Types and indicators of financial crime
  • Applicable laws and regulations
  • Internal policies and procedures
  • Responsibilities for preventing and reporting financial crime

11. Roles and Responsibilities

All employees are responsible for complying with this policy and for reporting suspected financial crime. Specific responsibilities include:

  • The Board of Directors is responsible for overseeing the implementation of this policy
  • The Compliance Officer is responsible for day-to-day management of financial crime risks
  • Department managers are responsible for implementing controls in their areas
  • All employees are responsible for following procedures and reporting suspicious activities

12. Policy Violations

Violations of this policy may result in disciplinary action, up to and including termination of employment or business relationships. Violations may also result in criminal prosecution or civil penalties.

13. Review and Updates

This policy will be reviewed annually or more frequently if required by changes in regulations or business practices to ensure its continued effectiveness.

14. Contact Information

For any questions or concerns regarding this policy, please contact our Compliance Officer:

Email: compliance@kuinji.com
Address: 123 Business Avenue, Suite 500, Astana, Kazakhstan