1. Full Legal Corporate Name
2. Has the country in which you are located established laws designed to prevent ABC, AML and CTF? YesNo
3. Has the country in which you are located established a central reporting agency for the purpose of collecting and assessing suspicious transaction reports? YesNo
4. Are there written policies and procedures in place to prevent your Company being used to conduct money laundering or terrorist financing activities according to applicable law? YesNo
5. Is your Company compliant with the AML/ CTF of the jurisdiction in which you operate? YesNo
6. Within the last 5 (five) years has your Company been subject to civil or criminal penalties stemming from deficiencies or failings that relate to your AML/CTF requirements? YesNo
7. Has your Company implemented written policies and procedures in place to ensure compliance with International Sanctions* when dealing with commodities, individuals, entities, or any of their beneficial owner(s)? These include Financial, Trade, Terrorism, Diplomatic or Regional Sanctions YesNo
8. Based on the definition below, does your Company have any Politically Exposed Persons (“PEPs”) involved as a shareholder, beneficial owner, director, key employee/authorised signatory etc.? DEFINITION: PEPs are defined as: ‘individuals who are or have, at any time in the preceding year, been entrusted with a prominent public function by a non-UK country, the European Community or an international body’. The definition extends to individuals who hold a legislative, administrative or judicial position of any kind and includes government officials and those working for international organisations. It also extends to any such individuals’ immediate family members and close associates. YesNo
9. Is your Company in any way, owned, managed, controlled, or funded by any Government Organization? YesNo
10. Has your organization, affiliates, or any current or former owners, managers, directors or employees, ever been debarred from competing for or bidding on government contracts in any territory in which you have done business, or contracts with non-governmental bodies (e.g. World Bank) YesNo
11a. Does your Company have a code of conduct or policy which includes zero tolerance of bribery? YesNo
11b. Does your Company provide training for staff in relation to Anti Bribery practices? YesNo
12. Does your company operate a Whistle Blowing process? YesNo
13. Are any beneficial owners, directors or key employees currently the subject of any criminal proceedings or investigations? YesNo
14. Have any beneficial owners, directors or other key employees ever been convicted of any criminal offence? YesNo
15. Have any beneficial owners, directors or other key employees ever been adjudged by a court or tribunal (whether criminal, civil or administrative) for any fraud, misfeasance, negligence, wrongful trading or other misconduct? YesNo
16. Are you aware of any legal action that is intended to be taken against the company or any of its beneficial owner’s directors or other key employees? YesNo
17. Are any of your company's owners, managers, directors or employees barred from acting as Directors in any country? YesNo
18. Does your company abide by the Child Labour principles? YesNo
I hereby certify and declare that all of the information provided above is true, accurate, complete and not misleading by error, omission or otherwise. I confirm that I am a duly authorised representative of the Company and I have the authority to sign on behalf of the Company. We undertake to promptly inform Kimura Capital LLP, as permitted by law, of any civil or criminal penalties imposed on the Company that relate to a failing of our AML/CTF responsibilities and obligations. Additionally, we undertake to promptly inform Kimura Capital LLP upon the identification of any blocked persons, individuals or entities, or any beneficial owners relating to any business placed with Kimura. Finally, we undertake to inform Kimura of any other material changes to the information provided within this document. We expressly recognise the right of Kimura to terminate any business or contractual relationship maintained with the Company in view of a Sanction breach or failure to provide information or documentation that may be required by regulatory or legal obligation.
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