customer’s identity, the ability to confirm identity documents through
online or other services offered by issuing authorities or other entities may also be factored in
documentation requirements and other information to be collected in respect of different
categories of customers depending on perceived risk and keeping in mind the requirements :

1: Kapsam shall not open an account where it is unable to apply appropriate CDD measures,
i.e., the Company is unable to verify the identity and /or obtain documents required as per the
risk categorisation due to non-cooperation of the customer or non-reliability of the
data/information furnished to the Company.

2: Before open a new account a screening will be performed so as to 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 or whose name
appears in the lists circulated by RBI/ SEBI/ NHB/ IRDA, United Nations Security Council (UNSC),
OFAC, as per section 51A of the Unlawful Activities (Prevention) Act, 1967, watch list by
Interpol, etc. These are done using the list/ information/ databases available on World-check,
Watch-out Investors, website of OFAC, UNSCR (as mentioned below) or such other
information sources/tools.

3:For the purpose of risk categorisation, individuals (other than High Net Worth 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 categorised as low risk.

4: Customer Identification Procedure to be carried out at different stages as under:
 Commencement of an account-based relationship with the customer;
 When the Company has a doubt about the authenticity or adequacy of the customer
identification data obtained by the Company. Customer identification means identifying
the customer and verifying his/ her/ its identity by using reliable, independent source
documents, data or information.

5: We shall obtain sufficient information necessary to establish, to its satisfaction, the
identity of each new customer, whether regular or occasional, and the purpose of the intended
nature of business relationship. Being satisfied means that the Company should be able to
satisfy the competent authorities that due diligence was observed based on the risk profile of
the customer, in compliance with the extant guidelines in place.

As a Company we shall have an ongoing employee training programme so that the members of
the staff are adequately trained in KYC and AML procedures. Training requirements shall have
different focuses for frontline staff, compliance staff and staff dealing with new customers. It
is crucial that all those concerned fully understand the rationale behind the KYC policy and
implement the same consistently.