Version 1.0
Prepared by: @Lorraine Sebata
Approved by: @Feli Capron
Reviewed date: 2024-07-25
Next review date: 2025-07-25
This Know Your Employee (KYE) Policy outlines Easyterms's commitment to mitigating internal risks, including those related to financial crime, fraud, and reputational damage, by establishing a robust framework for screening, monitoring, and training its employees. Its purpose is to ensure the integrity of the workforce and compliance with relevant anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.
This policy applies to all prospective and current employees, agents, and contractors of Easyterms across all departments and business lines. It covers the entire employment lifecycle, from recruitment and pre-employment screening to ongoing monitoring and training.
Easyterms recognizes the diverse range of internal risks, including reputational, legal, and operational risks, that can arise from employee misconduct. This policy establishes procedures to mitigate such risks by ensuring the integrity and trustworthiness of its workforce.
All prospective employees shall undergo comprehensive background and reference checks to assess their suitability and identify any potential risks. This initial screening process may be outsourced to qualified third-party providers. This includes, but is not limited to, verification of identity, employment history, educational qualifications, and character references.
The Company's recruitment process, whether conducted internally or outsourced, will include defined stages to ensure thorough vetting. This includes initial screening, interviews, and final approvals to ensure alignment with KYE principles.
The Company shall implement continuous monitoring procedures for employees, particularly those in sensitive roles, to detect unusual activities or associations that may indicate involvement in illicit activities or pose a risk to the company. This includes monitoring for unusual transaction activities, unexplained increases in business activities, or associations with persons known to be involved in criminal activities.
All employees shall be regularly informed and trained on the company's policies and procedures designed to detect and prevent money laundering and terrorist financing. This includes training on identifying, recording, and internally reporting suspicious persons or transactions, and acknowledging their personal obligations under AML/CTF statutory law.
The Company is committed to full compliance with all applicable national and international laws, regulations, and guidelines related to Know Your Employee (KYE) and Anti-Money Laundering (AML)/Counter-Terrorist Financing (CTF), including but not limited to the Financial Intelligence Unit Act, Financial Transactions Reporting Act, Financial Corporate Services Providers Act, Proceeds of Crime Act, and any other relevant statutory provisions.
Comprehensive records of all employee screening, monitoring activities, and training participation shall be maintained for a minimum period as required by law or internal policy. This includes documentation from outsourced screening activities.
The implementation of this Know Your Employee (KYE) policy is critical to safeguarding the integrity and reputation of Easyterms. By establishing robust screening, monitoring, and compliance measures, the company can effectively mitigate the risks associated with employee misconduct and ensure the trustworthiness of its workforce.
Senior Management / Board of Directors: Overall responsibility for approving and overseeing the KYE policy and ensuring adequate resources are allocated for its implementation.
Human Resources Department: Responsible for managing the overall recruitment process, including liaison with outsourced providers (e.g., Edma Human Resource & Business Support), overseeing the pre-employment screening procedures, maintaining employee records, and coordinating employee training programs.
Edma Human Resource & Business Support (Outsourced Partner): Responsible for initial recruitment stages, including advertising vacancies, conducting background checks, and carrying out first-round interviews as per agreed service level agreements and Easyterms's KYE standards.
Hiring Managers: Responsible for conducting second-round interviews for shortlisted candidates.
Chief People Officer (CPO) and Chief Executive Officer (CEO): Responsible for conducting final interviews and providing ultimate approval for new hires.
Compliance Department / Money Laundering Reporting Officer (MLRO): Responsible for developing and overseeing ongoing monitoring procedures, providing guidance on suspicious activity identification, and ensuring training programs align with AML/CTF requirements.
All Employees: Responsible for understanding and adhering to this policy, participating in required training, and reporting any suspicious activities or concerns to the appropriate channels (e.g., MLRO, HR).
This policy will be reviewed at least annually, or more frequently if there are significant changes in laws, regulations, business operations, or identified risks related to internal threats. This includes changes to recruitment processes, such as the engagement of outsourced partners.