1. This Policy inter-alia includes the following:

a. Appointment of key personnel and duties of the management team
b. Investors’ due diligence
c. Limited due diligence of the investee entity
d. AML monitoring and reporting procedure
e. Maintenance and Retention of records
f. Employee hiring and training
g. Vendors and suppliers support
h. Key responsibilities of internal audit teams
i. Compliance with Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS)

i. Appointment of key personnel and duties of the management team
The Partners and senior management of the Investment Manager are fully committed to establishing appropriate policies and procedures for preventing money laundering and ensuring their effectiveness and compliance with the relevant legal and regulatory requirements. The Designated Partner , Partners shall appoint the following personnel for specific KYC and AML responsibilities:

(a) Designated Partner/ Partner: As required under the PML Rules, a Designated Partner, Partner (as applicable) of the Investment Manager shall be appointed as the Designated Partner, Partner responsible for the overall compliance of this Policy and related procedures.

(b) Principal Officer/ Compliance Officer: A senior officer, with required skill sets and experience, shall be appointed as the ‘Principal Officer/ Compliance Officer’ for the purpose of ensuring day to day compliance and implementation with this Policy and procedures and reporting to regulators/authorities. The responsibilities of the Principal Officer shall, inter-alia, include:

• Acting independently and reporting directly to the Designated Partner, Partners periodically regarding the Investment Manager’s systems and controls in managing money laundering activities and recommending necessary improvements;
• Monitoring the implementation of investor and investee entity due diligence requirements as prescribed by SEBI from time to time;
• Monitoring of transactions, and reporting of all suspicious transactions* and sharing of information as required under the law and relevant regulations;

* The PML Rules define Suspicious Transaction to mean a transaction, including an attempted transaction, whether or not made in cash, which to a person acting in good faith –
1 – gives rise to a reasonable ground of suspicion that it may involve proceeds of an offence specified in the Schedule to the Act, regardless of the value involved; or
2 – appears to be made in circumstances of unusual or unjustified complexities;

• Maintaining close liaison with regulators and concerned authorities on AML and KYC matters;
• Overseeing and ensuring overall compliance with the relevant regulatory guidelines;
• Co-operating with the relevant law enforcement authorities, including the timely disclosure of information.
• Communicating the Policy to all the staff and arranging their training with respect to the Policy.
  ii. Investor Due Diligence
  Investor due diligence means taking into consideration all of the parameters and factors that the Investment Manager needs to identify and verify the investor’s identity and determine whether an investor is and continues to be acceptable to the Investment Manager/Fund as per it risk assessment standards.
  (a) Policy for acceptance of investors
  The Investment Manager will adopt risk-based approach for conducting the overall due diligence of investors. Such due diligence will be carried out based on factors such as legal status of the entity, organizational structure, publicly available information, nature of transactions, terms agreed under the Fund’s documents, etc.

The Investment Manager to follow the safeguards enumerated in the SEBI Master Circular dated October 15, 2017 while accepting investors.

(b) Procedure for due diligence

The Investment Manager will conduct adequate due diligence of the investor or the person on whose behalf the investment is being made, as well as the identified key personnel of such investee entity. Such due diligence will be conducted at different levels i.e. at the time of on-boarding and at subsequent regular intervals as prescribed by this Policy document, while carrying out transactions or as mandated by the regulator from time to time. For conducting due diligence, the Investment will obtain documents listed under Annexure A of this Policy as prescribed under the PML Rules, Directives and circulars issued by SEBI.

While conducting the due diligence, the Investment Manager shall:

a. Carry out independent research on the concerned entities through reliable publicly available information and keep on record information obtained from reliable sources. Information and documents available from the KYC Registration Agency (KRA) and Central KYC Registry (CKYC) database and available in the public domain may not be called for by the investors. KRA and CKYC are repositories of KYC records of customers in the financial sector with uniform KYC norms and inter-usability of the KYC records across the sector with an objective to reduce the burden of producing KYC documents and getting those verified every time when the customer creates a new relationship with a financial entity. The documents shared by the investors /investee entity shall be self-attested and in English language (documents in foreign language shall need to be translated into English);

b. In the case where the KYC registration has not been done by the client, the following steps may be performed:
i. Procurement of duly executed KYC forms from investors;
ii. Performance of KYC checks and obtaining KYC documents;
iii. Following guidelines for customer identification requirements;
iv. Uploading all the information obtained through these with SEBI registered KRA and CKYC.

c. Conduct verification of the investors where considered necessary and ensure that the details are the same as that in the KYC form; conduct checks by subscribing to relevant databases for identified individuals against civil or criminal proceedings by any enforcement agency worldwide;

d. Conduct checks for identified individuals against Politically Exposed Person (PEP) including family members and close relatives of PEPs, non-residents, high net-worth clients, trust, charity and non-governmental organisations receiving donations, companies having close family shareholding or beneficial ownership, company offering foreign exchange, client in high-risk country, client with dubious public reputation, based on publicly available information;

e. Submit its report to Principal Officer on the status and findings of the due diligence for approval;

f. The Principal Officer will take necessary guidance and advice, as required, from the Designated Partners, Partners to complete the due diligence including additional information and monitoring processes for PEP, onboarding of whom may take place only with the approval from the Management.
iii. Limited due diligence of investee entity
From an integrity perspective, the Investment Manager shall also obtain necessary information and documents from the investee entities to conduct the due diligence. Such due diligence shall, inter alia, include obtaining documents related but not limited to legal status of investee entities and senior management information.
The Investment Manager may conduct ongoing due diligence where it notices inconsistencies in the information provided
iv. AML Monitoring and Reporting Procedures
(a) The Investment Manager will, at regular intervals, monitor the transactions conducted by the investors with the Fund (such as drawdown of funds, distribution of funds, transfer of units, etc.) to ensure that the payments being made by the investors are in accordance with the respective contribution agreements, with respect to factors like mode of payment, third party transfers etc.

(b) The Fund or the Investment Manager will not undertake any ‘cash’ dealings with the investors.

(c) Suspicious transactions, if any noticed by the employees shall be communicated to the Principal Officer, who upon suitable investigation of the same will report such transactions in a Suspicious Transaction Report (STR) to the director, Financial Intelligence Unit – India (FIU-IND). The Principal Officer will ensure that there is no tipping off to the entities about any such reporting to authorities. Communication with the entities will be conducted in accordance with the directions of the regulators in such cases.

(d) Reporting under the Unlawful Activities (Prevention) Amendment Act, 2008 (UAPA):

The Investment Manager, upon receipt of the list of individuals and entities subject to UN sanctions (referred to as designated lists or UNSCRs Sanctions Committee List) from SEBI, will screen all its investors / authorized representatives / entities against such list and report such details to SEBI and FIU-IND in case any match is found. The Investment Manager will also ensure expeditious and effective implementation of the procedure prescribed under Section 51A of UAPA with regard to freezing/ unfreezing of financial assets of the designated individuals/entities enlisted in the United Nation Security Council Resolution (UNSCR) and especially, with regard to funds, financial assets or economic resources or related services held in the form of securities. The same is being circulated for necessary compliance as required under provisions of SEBI “Guidelines on Anti-Money Laundering (AML) Standards and Combating the Financing of Terrorism (CFT) / Obligations of Securities Market Intermediaries under the Prevention of Money Laundering Act, 2002 and Rules framed there under” issued on July 04, 2018.
v. Maintenance and Retention of records

(a) The Investment Manager shall maintain the records of identification and transactions as follows:

S.No Nature of record Period of retention of records
1. Transaction related records (Fund documents, business correspondences, etc.) 10 years from the date of termination/ end of term of the Fund or underlying investment period in each investment
2. Identity records of investor, investee, etc. 5 years from the date of termination of the investor/ investee–Fund relationship

(b) These records will include both domestic as well as international transactions. The Investment Manager shall ensure that all relevant records and information are made available on a timely basis to the investigating authorities. Where required by the investigating authorities, the Investment Manager shall retain certain records exceeding the above-mentioned period.

(c) The Investment Manager will periodically update the relevant documents obtained from the investors/investees /authorized representatives as part of its due diligence process.

(d) The Investment Manager will maintain and preserve the records of information related to transactions, whether attempted or executed, which are reported to the Designated Partners, Partners,, FIU – IND, for a period of 5 years from the date of the transaction between the investor and the Fund.

(e) The Investment Manager will retain the following information for the accounts of its clients in order to maintain a satisfactory audit trail:

i. the beneficial owner of the account;
ii. the volume of the funds flowing through the account; and
iii. for selected transactions:
1. the origin of the funds
2. the form in which the funds were offered or withdrawn, e.g. cheques, demand drafts etc.
3. the identity of the person undertaking the transaction;
4. the destination of the funds;
5. the form of instruction and authority.
vi. Employee Hiring and Training
The Investment Manager shall conduct adequate background checks of all individuals. At the same time, the Investment Manager shall provide periodic training to all its employees with respect to various operational and AML regulatory provisions and ensure that new employees undergo the same after joining the Investment Manager. Such trainings will be devised based on the role and responsibility of the employees.
vii. Vendors and suppliers support
The Investment Manager will not carry out any cash transaction in excess of INR 20,000 in the ordinary course of its activities. Additionally, receipts or payment of money will be made directly with the counterparty and through a proper banking channel. Financial transaction with unknown third parties shall be prohibited.
viii. Key responsibilities of the internal audit team
An independent review shall be conducted on a periodic basis to review and assess the adequacy of, and level of compliance with, the Investment Manager and the Fund’s AML Policy, KYC procedures and investor due diligence process. This review shall be conducted by either an independent and qualified third-party or an internal audit team. If an internal audit team is used to conduct the review, a sufficient separation of functions will need to be maintained in order to ensure the independence of such review. The results of this review shall be reported to the Principal Officer and Designated Partner. The Principal Officer will ensure that each of the resulting recommendations is addressed and will implement additional procedures, if necessary.
ix. Compliance with Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS)
The Investment Manager will at the time of conducting investor due diligence and at various subsequent intervals undertake necessary due diligence of all the reportable accounts as prescribed under FATCA and CRS guidelines. Further, such information shall be maintained and reported in the prescribed forms.
x. Dissemination of Policy

This Policy on Know your Client and Anti Money Laundering to be communicated to the Management and all the employees of the Investment Manager who handle account information, securities transactions, money and client records etc.