Customer Due Diligence (CDD) and Know Your Customer (KYC) Policy

### Purpose

To ensure Urjadata Solar Renewable Energy Pvt Ltd maintains a robust framework for collecting and confirming the legitimacy of information regarding its customers’ business activities, thereby complying with regulatory requirements and safeguarding against financial crimes.

### Policy Statement

Urjadata Solar Renewable Energy Pvt Ltd is committed to implementing a comprehensive Customer Due Diligence (CDD) and Know Your Customer (KYC) process to verify the legitimacy of its customers and their business activities. This policy outlines the procedures for collecting, verifying, and maintaining customer information.

### Customer Due Diligence (CDD) Requirements

**1. Customer Identification:**
– Obtain and verify identification information for all new customers. This includes, but is not limited to:
– Full name
– Address
– Date of birth (for individuals)
– National identification number or equivalent
– Legal entity name and registration number (for businesses)
– Contact information

**2. Business Verification:**
– Verify the business activities of the customer by obtaining the following documents:
– Certificate of Incorporation
– Business registration documents
– Articles of Association or equivalent
– Description of business activities
– List of directors and beneficial owners
– Recent financial statements or tax returns
– Business licenses or permits

**3. Risk Assessment:**
– Conduct a risk assessment to determine the level of risk associated with each customer. Factors to consider include:
– Nature of the business
– Geographic location
– Customer’s industry sector
– Volume and types of transactions
– Source of funds

**4. Enhanced Due Diligence (EDD):**
– For high-risk customers, implement Enhanced Due Diligence (EDD) measures, which may include:
– Obtaining additional identification documents
– Conducting background checks
– Gathering information on the customer’s source of wealth and funds
– Ongoing monitoring of the customer’s transactions

### Verification Procedures

**1. Document Verification:**
– Verify the authenticity of identification documents through appropriate means, such as:
– Checking government-issued ID numbers
– Contacting issuing authorities
– Using third-party verification services

**2. Business Activity Verification:**
– Confirm the legitimacy of the customer’s business activities by:
– Reviewing official business documents
– Conducting site visits, if necessary
– Contacting business references or partners
– Verifying business licenses and permits

**3. Continuous Monitoring:**
– Implement ongoing monitoring procedures to ensure continuous compliance. This includes:
– Regularly updating customer information
– Monitoring transactions for suspicious activities
– Conducting periodic reviews based on the customer’s risk profile

### Record Keeping

**1. Documentation:**
– Maintain comprehensive records of all CDD and KYC information collected, including:
– Copies of identification documents
– Business verification documents
– Risk assessments and due diligence reports
– Transaction records

**2. Retention Period:**
– Retain all records for a minimum period of [X years], or as required by applicable laws and regulations.

### Compliance and Reporting

**1. Training:**
– Provide regular training to employees on CDD and KYC requirements and procedures to ensure compliance and awareness.

**2. Compliance Officer:**
– Appoint a Compliance Officer responsible for overseeing the implementation of this policy, ensuring adherence, and conducting audits to verify compliance.

**3. Reporting:**
– Report any suspicious activities or discrepancies to the appropriate regulatory authorities as required by law.

### Enforcement

**1. Internal Audits:**
– Conduct periodic internal audits to ensure compliance with this policy and identify areas for improvement.

**2. Disciplinary Actions:**
– Non-compliance with this policy will result in disciplinary actions, which may include termination of employment or business relationships, depending on the severity of the breach.

By implementing these procedures, Urjadata Solar Renewable Energy Pvt Ltd aims to create a secure and compliant environment for conducting business, thereby protecting the company and its stakeholders from financial crimes and regulatory breaches.

21 July 2024

Manish Patel – Founder and CMD
Urjadata Solar Renewable Energy Pvt Ltd (A GoI Recognized Startup DIPP98030)
Foodgod Farmer Producer Company Limited (A GoI Recognized Startup DIPP105083)
President – Kusum Kisan Urja Surksha Samiti (Reg No. 06/09/08/14238/22)
DGCA Certified Remote Pilot
DRP (District Resource Person) – MOFPI, PMFME Scheme
Retd. G.M. John Deere U.S.A.
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