CUSTOMER ACCEPTANCE POLICY

CUSTOMER ACCEPTANCE POLICY

Preamble

COMET SPACE IT SERVICES LLC (hereinafter referred to as “Company”) has already formulated a Group Anti Money Laundering (AML) Policy, which establishes the standards of AML compliance and is applicable to all activities of the Company. The Group AML Policy highlights Know Your Customer (KYC) as one of the key AML standards. The availability of customer information is a critical element in the effective management of Money Laundering (ML) risks. The Group AML policy as well as the KYC/AML procedures already laid down by the Company, cover the aspects of customer identification/verification, the due diligence procedures to be adopted and in general the Company’s overall policy in regard to acceptance of customers or establishing a relationship. The Customer Acceptance Policy would form an integral part of the Group AML Policy. The features of the Customer Acceptance Policy are detailed below.

Definition of Customer

The term ‘Customer’ would refer to any person or entity whether a natural person, a juristic entity, a firm, a trust, an unincorporated association of persons, acting for itself or in any fiduciary capacity, who (i) for itself or on behalf of another, maintains an account or (ii) has a business relationship with the Company for availing any of the products or services of the Company or (iii) is a beneficiary of the transactions conducted by Professional Intermediaries [Professional Intermediaries include Stockbrokers, Chartered Accountants, Solicitors etc. as permitted under law or customary practices] or (iv) is connected with a financial transaction which can pose significant reputational or other risks to the Company.

Due Diligence for Account Opening/Closing

by the applicant and the applicant’s expected use of the Company’s products and services. In case of certain products, the Company may rely upon the KYC procedures conducted by other Company’s having satisfactory customer identification procedures.

For non-face to face customers, appropriate due diligence measures (including certification requirements of documents, if any) will be devised by the SBUs for identification and verification of such customer. The purpose of commencing the relationship/opening of accounts shall be established and the beneficiary of the relationship/account shall also be identified. The due diligence measures to be adopted for various customer/product segments shall be outlined in the respective KYC/AML procedures laid down from time to time. The information collected from the customer shall be kept confidential.

Risk Profiling of customer/product segments