• Version 1.0

• Prepared by: @Lorraine Sebata

• Approved by: @Feli Capron

• Reviewed date: 2025-07-24

• Next review date: 2026-07-24

1. Purpose

This SOP details the step-by-step process for implementing the Know Your Employee (KYE) Policy at Easyterms. Its purpose is to ensure consistent and effective screening, monitoring, and training of employees to mitigate internal risks and ensure compliance with relevant AML/CTF regulations.

2. Scope

This SOP applies to the Human Resources Department, Compliance Department, Money Laundering Reporting Officer (MLRO), and all employees involved in the recruitment, management, and training of staff at Easyterms.

3. Related Policies

• Know Your Employee (KYE) Policy

• Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

• Customer Data Privacy Policy

• Recruitment Policy

4. Roles and Responsibilities

• Human Resources (HR) Department: Manages the recruitment process (including liaison with outsourced providers), maintains employee files, and coordinates training logistics.

• Edma Human Resource & Business Support: Handles initial recruitment stages, including advertising, background checks, and first-round interviews.

• Compliance Department / Money Laundering Reporting Officer (MLRO): Oversees ongoing employee monitoring, develops and delivers AML/CTF training content, and investigates suspicious activities reported by employees.

• Hiring Managers: Conduct second-round interviews and observe employee conduct.

• Chief People Officer (CPO) and Chief Executive Officer (CEO): Conduct final interviews for shortlisted candidates.

• All Employees: Adhere to KYE procedures, participate in training, and report suspicious activities.

5. Procedure: Know Your Employee (KYE)

5.1 Recruitment and Pre-Employment Screening

5.1.1 Vacancy Notification and Initial Outsourcing (HR Department & Edma)

Whenever a position becomes available within Easyterms, the HR Department will engage Edma Human Resource & Business Support to handle the initial stage of the recruitment process.

5.1.2 Advertising, Background Checks, and First-Round Interviews (Edma)

Edma Human Resource & Business Support will be responsible for:

• Advertising the vacancy.

• Conducting comprehensive background checks on prospective employees. This includes verifying identity, previous employment history, educational qualifications, and, where legally permissible and relevant to the role, criminal record checks.

• Carrying out first-round interviews.

• Obtaining and verifying professional and, where appropriate, character references from previous employers with the candidate's consent.

• Documenting all findings and any discrepancies in the candidate's file.

5.1.3 Shortlisting and Subsequent Interviews (HR Department, Hiring Managers, CPO, CEO)

Once Edma Human Resource & Business Support has shortlisted candidates, the list will be submitted to the HR Department.

• Second interviews will be conducted by the relevant Hiring Manager.

• Final interviews will be conducted by the Chief People Officer (CPO) and the Chief Executive Officer (CEO).

5.2 Ongoing Employee Monitoring (Compliance Department / MLRO)

5.2.1 Monitoring for Unusual Transaction Activities:

The Compliance Department, in coordination with relevant operational departments, shall monitor internal employee-related transactions (e.g., expense claims, internal transfers) for unusual patterns or amounts that deviate from normal behavior. Implement systems to flag transactions that meet predefined suspicious criteria.

5.2.2 Monitoring for Unusual Increase in Business Activities:

For employees involved in sales or client-facing roles, monitor for sudden, unexplained, or disproportionate increases in business activities (e.g., new client acquisitions, transaction volumes) that may indicate undisclosed external interests or illicit activities.

5.2.3 Association with Persons Known to be Involved in Criminal Activities:

Employees are encouraged to report any knowledge of colleagues associating with individuals known to be involved in criminal activities to the MLRO or HR, maintaining strict confidentiality. The MLRO will assess such reports and, if necessary, initiate an internal investigation.

5.3 Staff Awareness and Reporting (All Employees & MLRO)

5.3.1 Familiarization with Policies and Procedures:

All new employees must be provided with copies of the AML/CTF Policy (AML-001) and this KYE SOP during their onboarding. Existing employees will receive updates on policy revisions.

5.3.2 Identifying, Recording, and Internal Reporting of Suspicious Persons or Transactions:

Employees are trained to identify red flags indicative of suspicious activities or persons. Any employee who suspects a transaction or activity is related to money laundering or terrorist financing, or who has concerns about a colleague's conduct, must report it immediately to the MLRO using the prescribed internal suspicious activity report form. All reports will be handled with strict confidentiality and without fear of reprisal.

5.3.3 Acknowledgement of AML/CFT Policy Manual:

All employees must formally acknowledge their understanding and acceptance of the AML/CFT Policy manual (Appendix 3 of AML-001, if applicable) upon joining and annually thereafter.

5.4 Education and Training Programmes (Compliance Department / HR Department)

5.4.1 Annual Mandatory Training:

Pursuant to the Financial Intelligence (Transaction Reporting) Regulations (FITRR) and internal policy, AML/CFT/PF training shall be conducted on an ongoing basis, with a minimum of one mandatory session annually for all relevant employees. Training content will focus on the recognition and handling of transactions carried out by or on behalf of any person who is or appears to be engaged in money laundering or terrorist financing.

5.4.2 Awareness of Statutory Provisions:

Training programs will ensure employees are aware of the provisions of:

• Financial Intelligence Unit Act

• Financial Transactions Reporting Act

• Financial Corporate Services Providers Act

• Proceeds of Crime Act

• Any other statutory provision relating to money laundering or terrorist financing.

• The internal procedures maintained in compliance with the duties imposed by the Financial Intelligence (Transaction Reporting) Regulations, 2001.

5.4.3 Documentation of Training:

Records or registers of attendance, any certificates issued, test results, or any other documentation of training completion shall be placed on each employee's personnel file to demonstrate compliance.

5.4.4 Updates on Legislation and Guidelines:

New legislation, Rules, Guidelines, policies, or any relevant updates received from a regulator are to be distributed to all management and employees eligible for AML/CFT/PF training upon receipt. Where deemed necessary by the Compliance Department, additional training sessions will be conducted as soon as feasible after such updates.

6. Documentation and Records

• Employee Background Check Reports (including those provided by Edma)

• Reference Check Documentation (including those provided by Edma)

• Internal Suspicious Activity Reports (SARs)

• Employee Training Attendance Registers

• Training Materials and Test Results

• Acknowledgement Forms for AML/CFT Policy

7. Training

All new and existing employees, particularly those in roles susceptible to financial crime risks, will receive mandatory training on this SOP and the related KYE Policy and AML/CTF Policy. Refresher training will be conducted annually or upon significant policy or regulatory changes.

8. Review and Revision

This SOP will be reviewed annually by the Human Resources and Compliance Departments to ensure its continued effectiveness, compliance with evolving regulations, and alignment with the company's risk management objectives.