NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

1

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

KNOW YOUR CUSTOMER (KYC)

& ANTI MONEY LAUNDERING (AML) POLICY

Revision

History

:

Effective From

29

th

March, 2016

1

st

Amendment

29

th

June, 2019

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

2

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

KNOW YOUR CUSTOMER (KYC) POLICY& ANTI MONEY

LAUNDERING (AML) POLICY

(The Policy is formulated as per directive of NHB)

I. Introduction

Mentor Home Loans India Limited (herein after referred to as the Company) has a

policy to combat the money laundering activities which is known as “Know Your

Customer (KYC) Policy and Anti Money Laundering (AML) Policy”.

It is being realized world over, that money laundering is a serious threat not only to the

financial system of countries, but also to their integrity and sovereignty. To combat

this criminal act of Money Laundering, the Financial Action Task Force (FATF) was

established by G-7 summit in Paris. FATF Recommendations set out the basic

framework for anti-money laundering efforts and were designed with universal

application in mind.

However, In India Prevention of Money Laundering Act, enacted by the Parliament in

2002, makes it obligatory for all the financial intermediaries like banks, financial

institutions, Non-Banking Financial Companies (NBFCs), Housing Finance

Companies (HFCs) etc. to follow 'Know Your Customer' norms which basically define

the customer identification process. As per the KYC principles, intermediaries have to

collect documents known as KYC documents before entering into any transaction with

the customers. The KYC process includes making reasonable efforts to determine

true identity and beneficial ownership of accounts, source of funds, nature of

customer’s business, reasonableness of operations in the account visa-versa

customer’s business/income profile etc.

The KYC requirement is applicable to all categories of customers transacting with any

financial intermediary.

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

3

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

II. Need for the Policy

The Company is committed to contribute in the fight against money laundering and

terrorism financing and curb flow of such funds through its business activities. To

achieve this objective and to ensure that Mentor is not used as a vehicle for money

laundering and terrorism financing. Company has undertaken to frame the policy.

The main objective of this policy is:

 To establish and lay down the general framework for identification and acceptance of

customers through documentary and other means and to fight against money

laundering and terrorism financing and assist law enforcement agencies in this regard;

 To ensure compliance with the PMLA and the guidelines in force from time to time

 To protect its reputation and goodwill

 To lay down compliance norms for the employees

Risk involved in the event of non – compliance of the Act and guidelines:

Company is aware that it is exposed to several risks if appropriate Anti Money

laundering Measures is not established:-

 Reputation Risk: Company’s reputation being deteriorated, due to non-compliance

of Anti – Money laundering measures which in return causes lack of confidence

among creditors, business associates, stakeholders and general public at large.

 Compliance Risk:Risk of loss due to failure of compliance with key regulations

governing Mentor’s operations.

 Operations Risk: Risk of loss resulting from inadequate or failed internal process,

people and systems, or from external events.

 Legal Risk: Risk of loss due to any above risk or combination thereof resulting into

the failure to comply with law and having a negative legal impact on Mentor.

 Financial Risk: Risk of loss due to any of the above risk or combination thereof

resulting into negative financial impact on Mentor.

III. Objective

The objective of KYC process is to prevent financial intermediaries being used,

intentionally or unintentionally by criminal elements for money laundering to fund

various illegal activities including global terrorism. The KYC process has become the

utmost need of the hour for all financial intermediaries in wake of fast spreading

money-laundering menace across the globe.

Mentor has framed its KYC policy incorporating the following four key elements:

 Customer Acceptance Policy;

 Customer Identification Procedures;

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

4

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

 Monitoring of Transactions; and

 Risk management.

IV. Definitions

 “Act Rules and Regulations” Act means “The Prevention of Money Laundering

Act, 2002 (PMLA) as amended from time to time. The Rules shall mean the Rules

framed under PMLA. The Regulations shall mean the Regulations shall framed

under PMLA.

 “Person” means the following:-

(i) An individual

(ii) A Hindu Undivided Family

(iii) A Company

(iv) A Firm

(v) An Association of Persons or Body of Individuals, whether incorporated or not

(vi) Every artificial judicial persons not falling within any of the preceding sub

clauses

(vii) Any agency, office or branch owned or controlled by any of the above person

mentioned in the preceding sub clauses

 Customer

For the purpose of KYC policy, a “Customer” will be defined as:

(i) A person or entity that maintains an account and/or has a business relationship

with the Company.

(ii) One on whose behalf the account is maintained (i.e. the beneficial owner);

(iii) Beneficiaries of transactions conducted by professional intermediaries such as

Stock Brokers, Chartered Accountants, Company Secretaries, Solicitors etc. as

permitted under the law, and

(iv) Any person or entity connected with a financial transaction which can pose

significant reputation or other risks to the Company, say a wire transfer or issue

of a high value demand draft as a single transaction.

 “Records” include the records maintained in the form of books or stored in

computer or such other form as may be prescribed.

 “Suspicious Transaction” means a transaction whether or not made in cash, to a

person acting in good faith –

 Give rise to a reasonable ground of suspicion that it may involve the

proceeds of crime; or

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

5

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

 Appears to be made in circumstances of unusual or unjustified complexity; or

 Appears to have no economic rational or bonafide purpose; or

 Gives rise to a reasonable ground of suspicion that it may involve financing

of the activities relating to terrorism.

 “Transaction” includes loan disbursements, repayment/prepayment of loans,

payment of fees, whether in cash or by cheque, pay order or other instruments or by

electronic or other non-physical means and

In case there is any difference in definitions as provided in the PMLA, Rules as

amended from time to time, shall prevail.

V. Customer Acceptance Policy (CAP)

Customer Acceptance Policy, which lays down explicit criteria for acceptance of

customers, ensures the following aspects of the customer relationship:

a) No account is opened in anonymous or fictitious/benami name(s);

b) Customers are all assessed for location of residence, business if any including

type of clients and also the mode of transactions and payments (in MHFC’s

case, we require payments to be made through ECS unless in an emergency

(and in any case given our business – of low ticket size loans – the level of

cash handling is very minimal). ;

c) Volume of turnover, social and financial status, etc. to enable categorization of

customers into low, medium and high risk (these customers will require very

high level of monitoring). Currently given the size of our loans and type of

clients we deal with, all our customers are considered low risk;

d) Documentation requirements and other information collected in respect of

different categories of customers depending on perceived risk and keeping in

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

6

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

mind the requirements of PML Act, 2002 and guidelines issued from time to

time;

e) Company will not open an account where it is unable to apply appropriate

customer due diligence measures, i.e.Company shall not open any account or

give any loan nor sanction any loan in the following circumstances:

 Company is unable to verify the identity of the customer;

 Customer without any valid or convincing reasons refuses to provide

documents to the Company which are needed to determine the risk level

in relation to the customer loan applied for by the customer and his

paying capacity;

 Information furnished by the customer does not originate from the

reliable sources or appears to be doubtful due to lack of supporting

evidence.

 Identity of the customer, directly or indirectly matches with any individual

terrorist or terrorist or prohibited/unlawful organizations, whether existing

within the country or internationally, or if the customer or beneficiary is

found, even remotely, to be associated with or affiliated to any illegal,

prohibited or unlawful or terrorist organization as notified from time to

time either by Govt. of India, State Govt. or any other national or

international body/organization.

Subject to the above mentioned norms and caution, at the same time all the

employees of Company will also ensure that the above norms and safeguards

do not result in any kind of harassment or inconvenience to bonafide and

genuine customers who should not feel discouraged while dealing with

Company.

f) Circumstances, in which a customer is permit

ted to act on behalf of another

person/entity, will be clearly spelt out in conformity with the established law and

practices, as there could be occasions when an account is operated by a

mandate holder or where an account may be opened by an intermediary in a

fiduciary capacity, and

g) Checks against any notified list of the NHB or the RBI any other regulator,

before accepting a customer, 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, etc.

Company will prepare a profile for each new customer which may contain information

relating to the customer's identity, social/financial status, nature of business activity,

information about his clients' business and their location, etc. The nature and extent of

due diligence will depend on the risk perceived by Company. However, while preparing

the customer profile, Companywill seek only such information from the customer which

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

7

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

is relevant and is not intrusive. The customer profile will be a confidential document and

details contained therein will not be divulged for cross selling or any other purposes.

Given the nature of our business – small ticket loans to low income financially excluded

families – we have categorized our customers as low risk. It is highly unlikely that

Company will have any medium / high risk clients given its focus on the lower income

section of society, but for information, examples of customers requiring higher due

diligence may include:

(a) Non-Resident Customers,

(b) High Net worth Individuals,

(c) Trusts, Charities, NGOs and Organizations Receiving Donations,

(d) Companies Having Close Family Shareholding or Beneficial Ownership

(e) Firms with 'Sleeping Partners',

(f) Politically Exposed Persons (Peps) Of Foreign Origin,

(g) Non-Face to Face Customers, And

(h) Those With Dubious Reputation as Per Public Information Available, Etc

It is important to bear in mind that the adoption of Customer Acceptance Policy and its

implementation will not result in denial of services to the general public, especially to

those who are financially or socially disadvantaged.

VI. Customer Identification Procedure (CIP)

The Company will follow clear NHB guidelines on the Customer Identification Procedure

to be carried out at different stages, i.e. while establishing a relationship; carrying out a

financial transaction or when Companyhas a doubt about the authenticity/veracity or the

adequacy of the previously obtained customer identification data. Customer

identification means identifying the customer and verifying his/ her identity by using

reliable, independent source documents, data or information.

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

8

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

The Companywill 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 relationship. Being satisfied means that Companymust 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. Besides risk

perception, the nature of information/documents required would also depend on the

type of customer (individual, corporate etc).

Need for photographs:

• Passport size photographs should be obtained from borrowers, guarantors and

depositors

• In the case of joint accounts, partnership accounts, accounts of Societies, clubs,

HUF, Trust and those of minors etc photographs of the Authorized Signatories

should be obtained;

• In case of change in the Authorized Signatories, photograph of the new

signatory should be obtained duly countersigned by the competent authorities of

the concerned Institution /organization;

• Photographs should be obtained in NRI accounts

• Where the account is operated by the letters of Authority or Power of Attorney

Holder photograph of the authority holder should be obtained duly attested by

theBorrower/depositor.

Proof of customers’ address:

Accounts of Individuals: In order to confirm the correctness of the address given by

the account holder in the account opening form any one of the following documents of

the account holder may be obtained for verifying the address there from;

• Driving License

• Aadhar Card

• Passport

• PAN Card

• Telephone / Electricity Bills

• Rent receipt

• Municipal / Assessment Order

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

9

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

• Income Tax Assessment Order

• Voter’s identity Card

• Identity Card containing the address issued by the employer (subject to

satisfaction of the Company)

A Photostat copy of the above proof should be filed along with the account opening

forms / loan application. In case of need, Company Manager can depute an official to

visit the account holder / loan applicant at the given address to satisfy about the

genuineness of the address.

Accounts of companies: In order to confirm the correctness of the Name of the

company, Principal place of business, Mailing address of the company, Telephone / fax

number given in the account opening form, the following documents may be obtained

for verification:

• Certificate of incorporation and Memorandum and Article of Association

• Resolution of the Board of Directors to open an account and identification of

those who have authority to operate the account.

• Power of Attorney granted to its managers, officers or employees to transact

business on its behalf.

• Copy of PAN Allotment letter / PAN Card

• Copy of the telephone bill

A Photostat copy of the above proof should be filed along with the account opening form

/ loan application form. In case of need, Company Manager can depute an official to

visit the account holder / loan applicant at the given address to satisfy about the

genuineness of the address.

Account of Partnership firms: In order to confirm the correctness of the Legal Name,

Address, name of all partners and their addresses and Telephone numbers of the firm

and partners given in the account opening form, the following documents may be

obtained for verification:

• Registration certificate, if registered

• Copy of PAN Allotment letter / PAN Card

• Partnership deed

• Power of Attorney granted to a partner or an employee of the firm to transact

business on its behalf

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

10

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

• Any officially valid document identifying the partners and the person holding the

Power of Attorney and their addresses

• Telephone bill in the name of firm / partners A Photostat copy of the above proof

should be filed along with the account opening form / loan application. In case of

need, Company manager can depute an official to visit the account holder / loan

applicant at the given address to satisfy about the genuineness of the address.

Accounts of trusts and foundations: In order to confirm the correctness of the Name

of trustees, settlers, beneficiaries and signatories, Names and addresses o f the

founder, the manager / directors and the beneficiary/ies, Telephone / fax numbers, the

following documents may be obtained for verification:

• Trust Deed

• Copy of PAN Allotment letter / PAN Card

• Certificate of registration, if registered

• Power of Attorney to transact business on its behalf

• Any officially valid document to identify the trustees, settlers, beneficiaries and

those holdingPower of Attorney, founders / managers / directors and their

addresses.

• Resolution of the managing body of the foundation / association

• Telephone bill

A Photostat copy of the above proof should be filed along with the account opening form

/ loan application. In case of need, Company Manager can depute an official to visit the

account holder/ loan applicant at the given address to satisfy about the genuineness of

the address.

Accounts of unincorporated association or a body of individuals:

• Resolution of the managing body of such association or body of individuals

• Copy of PAN Allotment letter / PAN Card

• Power of attorney granted to him to transact on its behalf

• An officially valid document in respect of the person holding an attorney to

transact on its behalf

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

11

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

• And any other information/document as may be required by the Company to

collectively establishes the legal existence of such an association or body of

individuals.

As per the provisions of Rule 9 of the Prevention of Money-Laundering (Maintenance of

Records of the Nature and Value of transactions, The Procedure and Manner of

Maintaining and Time for Furnishing information and Verification and Maintenance of

Records of the Identity of the Clients of the Banking Companies, Financial Institutions

and Intermediaries) Rules, 2005 (hereinafter referred to as PML Rules), the Company

shall:

a) At the time of commencement of an account–based relationship, identify its

clients, verify their identity and obtain information on the purpose and intended

nature of the business relationship, and

(b) In all other cases, verify identity while carrying out:

o Transaction of an amount equal to or exceeding rupees fifty thousand,

whether conducted as a single transaction or several transactions that

appear to be connected,

or

o Any international money transfer operations.

In terms of proviso to rule 9 of the PML Rules, the relaxation, in verifying the identity of

the client within a reasonable time after opening the account/ execution of the

transaction, stands withdrawn.

Abiding by the provisions of Rule 9, the Company shall identify the beneficial owner and

take all reasonable steps to verify his identity. The said Rule also requires that the

Company should exercise on-going due diligence with respect to the business

relationship with every client and closely examine the transactions in order to ensure

that they are consistent with their knowledge of the customer, his business and risk

profile.

Understand the ownership and control structure of the customer and determine who the

natural persons areand who ultimately control the legal person. Where Company is

unable to apply appropriate KYC measures due to non-furnishing of information and /or

non-cooperation by the customer, Company may consider closing the account or

terminating the business relationship after issuing due notice to the customer explaining

the reasons for taking such a decision.

VII. Monitoring Of Transactions

Ongoing monitoring is an essential element of effective KYC procedures. The Company

can effectively control and reduce its risk only if it has an understanding of the normal

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

12

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

and reasonable activity of the customer so that it can identify transactions that fall

outside the regular pattern. However, the extent of monitoring will depend on the risk

sensitivity of the account. Since the Company will not have any deposit accounts, this

situation will hardly arise, but the Company will in any case pay special attention to all

complex, unusually large transactions and all unusual patterns which have no apparent

economic or visible lawful purpose, or transactions that involve large amounts of cash

inconsistent with the normal and expected activity of the customer.

The Company will put in place a system of periodical review of risk categorization of

accounts and the need for applying enhanced due diligence measures. The Company

will ensure that a record of transactions in the accounts is preserved and maintained as

required in terms of section 12 of the PML Act, 2002 (and the Amended Act, 2009). It

will also ensure that transactions of suspicious nature and/or any other type of

transaction notified under section 12 of the PML Act, 2002 (and the Amended Act,

2009), is reported to the appropriate law enforcement authority.

VIII. Risk Management

The Board of Directors of the Company has ensured that an effective KYC program is in

place and has established appropriate procedures and is overseeing its effective

implementation. The program covers proper management oversight, systems and

controls, segregation of duties, training and other related matters. Responsibility has

been explicitly allocated within Company to ensure that HFC’s policies and procedures

are implemented effectively.

The Board of Directors of Company is aware that while all customers will be of low risk

profile given the nature of its business, unless belonging to a higher risk profile listed

under above and approved as an exception, it will apply various Anti Money Laundering

measures keeping in view the risks involved in a transaction, account or business

relationship.

The Company’s Board through its Audit Committee will directly evaluate and ensure

adherence to the KYC policies and procedures, including legal and regulatory

requirements.

The Company has already ensured that its front line staff and credit staff are aware

that no loan accounts will be created unless the KYC procedures are adhered to

completely.

IX. Introduction Of New Technologies

Mentor will pay special attention to any money laundering threats that may arise from

new or developing technologies including on-line transactions that might favour

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

13

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

anonymity, and take measures, if needed, to prevent its use in money laundering

schemes.

Customer Education

For implementing KYC Policy, the Company shall have to seek personal and financial

information from the new and intended customers at the time they apply for availing

the loan facilities. It is likely that any such information, if asked from the intended

customer, may be objected to or questioned by the customers. To meet such

situation it is necessary that the customers are educated and apprised about the

sanctity and objectives of KYC procedures so that the customers do not feel

hesitantor have any reservation while passing on the information to the Company.

For this purpose, all the staff members with whom the customers will have their

first interaction/dealing will be provided special training to answer any query or

questions of the customers and satisfy them while seeking certain information in

furtherance of KYC Policy . To educate the customers and win their confidence in this

regard, Company may arrange printed materials containing all the relevant

information regarding KYC Policy and anti-money laundering measures. Such

printed materials will be circulated amongst the customers and in case of any

question from any of the customer, the Company staff will attend the same promptly

and provide explain reason for seeking any specific information and satisfy the

customer in that regard.

KYC Policy for Existing Customers

Although this KYC Policy will apply and govern all the new and prospective

customers, but some of theKYC procedures laid down in this policy particularly which

deal with Customer Identification, Monitoring of Transactions and Risk Management

can be effectively applied to the existing customers and their loan accounts? While

applying such KYC procedures to the existing loan accounts if any unusual pattern is

noticed, the same should be brought to the notice the Head of the concerned

department and the Principal Officer appointed by the Company as per RBI

directives. In case any existing customer does not co-operate in providing the

information required as per KYC policy or conducts himself in such manner which

gives rise to suspicion about his identify or credentials, such matters will be brought

to the notice of Principal Officer who in turn will make necessary inquiries and if

required shall forward the name of such customers to the concerned authorities for

appropriate action. Besides above, in such situation the Company, for reasons to be

recorded, may recall the loan granted to such customers and take recourse to legal

remedy against the customers as well as security furnished by such Customer.

X. Appointment of Designated Director and Principal Officer

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

14

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

The Company has appointed Designated Director and Principal Officer for the

effective implementation of KYC and AML Policy:-

Appointment of Designated Director

The Company has appointed its Managing Director to be designated as

“Designated Director”in compliance of Rule 2 (ba) of the Maintenance of Record

Rules of the Prevention of Money laundering Act, 2002 (PMLA). The Designated

Director is responsible for the following:

 To ensure overall compliance with the obligation imposed under Chapter 4 of the

Act and Rules/ Regulations thereunder.

 To ensure implementation and compliance of the policy framed from time to time.

Appointment of Principal Officer

The Company has appointed its Chief Operating Officer to be designated as

“Principal Officer”in compliance of Rule 2(f) of the Maintenance of Record Rules of

the PMLA.

The Principal Officer under the supervision and guidance of the Designated Director

shall be responsible to ensure overall compliance with the obligations imposed under

the Act and the Rules/ Regulations thereunder.

The Designated Director and Principal Officer will, inter- alia will be responsible for:

 Implementing the policy by drawing up the procedures

 Ensuring procedures formulation in co-ordinations with Operation Head

 Coordinating with Operation Head/ Regional Manager’s (RM’s)/ Area Manager’s

(AM) for monitoring the compliance of the policy on KYC and AML

 Allocating duties and responsibilities to ensure implementation and compliance

of the policy framed

 Ensuring that the new procedures and practices applied in case of new products

are in line with KYC and AML policy.

 Training and dissemination of information concerning guidelines and other rules

and regulations on KYC and AML and updating staff/customers of the changes

taking place from time to time.

 Ensuring that suspicious transactions are reported promptly within the stipulated

period from the date of reaching the conclusion, to the designated agency

 Submission of Quarterly Audit notes and compliance to the Audit Committee.

 To implement Internal Audit system to verify the compliance with KYC/ Anti –

Money Laundering (AML) policies and procedures.

Senior Management

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

15

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

As per the Employee Policy of the Company, Senior Management includes Directors,

Key Managerial Personnel (KMP), H1 category Employees or as any employee

identified by the Company.

XI. Maintenance Of Records Of Transactions

As unlikely as it will be in Company’s case, due to its focus on lower income families,

Company has a system of maintaining proper record of transactions prescribed under

Rule 3, of the Prevention of Money-Laundering and value of transactions, the

procedure and manner of maintaining and verification and maintenance of records of

the identity of the clients of the Banking Companies, Financial Institutions and

Intermediaries) Rules, 2005, as mentioned below:

• All cash transactions of the value of more than rupees ten lakh or its equivalent

in foreign currency;

• All series of cash transactions integrally connected to each other which have

been valued below rupees ten lakh or its equivalent in foreign currency where

such series of transactions have taken place within a month and the aggregate

value of such transactions exceeds rupees ten lakh;

• All cash transactions where forged or counterfeit currency notes or bank notes

have been used as genuine and where any forgery of a valuable security has

taken place;

• All suspicious transactions whether or not made in cash and by way of as

mentioned in the rules.

XII. Information To Be Preserved

As per the NHB guidelines, the Companyis required to maintain the following

information in respect of transactions referred to in Rule 3 of PML:

• The nature of the transactions;

• The amount of the transaction and the currency in which it was denominated;

• The date on which the transaction was conducted; and

• The parties to the transaction.

XIII. Maintenance And Preservation Of Records

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

16

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

The Company has a system for proper maintenance and preservation of account

information in a manner that allows data to be retrieved easily and quickly whenever

required or when requested by the competent authorities.

Company will maintain for at least ten years from the date of cessation of transaction

between the bank and the client, all necessary records of transactions, both domestic

or international, which will permit reconstruction of individual transactions (including

the amounts and types of currency involved if any) so as to provide, if necessary,

evidence for prosecution of persons involved in criminal activity.

Company will also ensure that records pertaining to the identification of the customer

and his / her address (e.g. copies of documents like passports, identity cards, driving

licenses, PAN, utility bills etc.) obtained while opening the account and during the

course of business relationship, are properly preserved for at least ten years after the

business relationship is ended.

The identification records and transaction data will be made available to the

competent authorities upon request.

XIV. Reporting To Financial Intelligence Unit-India

In terms of the PMLA rules, the Company will report information relating to cash and

suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at

the following address:

Director, FIU-IND, Financial Intelligence Unit-India,

6th Floor, Hotel Samrat, Chanakyapuri,

New Delhi-110021

The Company will ensure that the provisions of PMLA Rules framed and the Foreign

Contribution and Regulation Act, 1976, wherever applicable, are adhered to strictly.

XV. Modification Of Policy

The Board of Director of Company provide for periodical review of the compliance at

various levels of management. A consolidate report of such reviews(if required) may

be submitted to the Board at regular intervals, as may be prescribe by it.

The Company reserves to itself the right to alter/delete/add to these codes at any time

without prior individual notice and such alterations /deletion/addition shall be binding.

Pawan Kumar Goyal

NHB Registered

U67120RJ1995PLC009580

MENTOR HOUSE, GOVIND MARG, SETHI COLONY, JAIPUR,

RAJASTHAN – 302004, Tel : 0141 – 2611999, 8946800800 Email:-

info@mentorloans.co.in,Website: www.mentorloans.co.in

17

Mentor Home Loans India Limited: KYC Policy

And Anti Money laundering (AML) Policy

Managing Director

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