One IBC safeguard

One IBC statement on conduct

Background

The One IBC approach to conduct is designed to ensure that through our actions and behaviours we deliver fair outcomes for our customers and do not disrupt the orderly and transparent operation of our business. Conduct is the critical component within all business activities including, including but not limited to strategy, business models and planning, our culture and behaviours including staff recruitment/performance management, our interaction with customers, our products and services, our business operations, and our governance and oversight processes.

Our approach to conduct is key to winning and retaining our customers’ trust and loyalty. Focus on conduct is integral to One IBC’s values and business principles and supports the Group strategy for sustainable growth and streamlining of business processes and procedures.

One IBC has defined global outcomes relating to conduct which must be delivered by global businesses, global functions, and Operations, Services and Technology, each responsible for conduct within the scope of their activities, and must develop and maintain approaches, tailored to their markets and operations, which deliver the required global conduct outcomes.

Global conduct outcomes

Strategy and Business Models

• Our strategy, business models, and the decisions we make deliver fair treatment of customers and do not disrupt market integrity.

Culture and Behaviours

• Our culture supports our people and empowers them to consistently do the right thing for our customers and markets in which we operate.
• Our people are competent and committed to the fair treatment of customers and not disrupting the integrity of markets.
• We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes.
• We reward and incentivise performance, behaviours and attitudes which deliver the fair treatment of customers and uphold market integrity.

Customer

• We know our customers and understand their needs – we actively listen to them and ask the right questions.
• Our products are designed to meet the different needs of our customers, to be competitive and to be understandable.
• Our products and services provide a balanced exchange of value between One IBC and our customers.
• Throughout our sales and servicing we are efficient, transparent and customer-focused.
• We manage our products and services so that our customers’ experience is in line with the expectations we set.

Markets

• We seek to prevent and will proactively identify actions and behaviours that constitute market misconduct, and respond appropriately.
• Trades are executed in a timely, clear and controlled manner ensuring that optimal execution is achieved for our customers and that One IBC trades are not manipulative.
• We manage conflicts of interest and appropriately handle information to reduce the opportunity for misuse

Governance and Oversight

• Our governance framework provides effective oversight of how we fairly treat customers and uphold market integrity.
• We engage with regulatory bodies in a timely, open and transparent manner.

Activity and decision making within each global business, global function, and One IBC Operations, Services and Technology is expected to provide positive contribution to the global conduct outcomes, to ensure appropriate delivery of these outcomes.

Complaints handling

Our commitment to the highest standards of conduct and their embedding within our day to day activities is illustrated for example by our policy relating to complaints handling, which supports outcome:

We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes

Our global complaints policy sets out clear standards for:

• The processes by which we investigate and resolve complaints in a timely, unbiased, and effective manner
• Providing appropriate training to staff on our complaints processes, emphasising the need for empathy with customers
• Ensuring customers are aware of how to make a complaint via a variety of channels (for example via relationship managers, face to face, telephone, on-line, in writing)
• Resolving complaints at first point of contact wherever possible, and where this is not possible, providing an acknowledgement to the customer clearly setting out next steps
• Ensuring customers are kept regularly informed of progress to resolve the complaint
• Providing responses to customers upon completion of an investigation, clearly detailing the outcome and including, where appropriate, details of remedial action and any redress
• Notification to customers of any available rights of referral or appeal if the customer is dissatisfied with the handling of, or response to, the complaint
• Regular review of any “root causes” of complaints received to identify and address any systemic issues, and to inform process improvements where applicable
• Monitoring the quality and efficiency of our complaints handling, including adherence to relevant local regulatory requirements

Product governance and sales

This conduct commitment is further illustrated by our policy and procedures in respect of product governance and sales which support the customer pillar outcomes, and encompass standards for:

• The design, approval and ongoing maintenance of appropriate products/services, matched to customer needs, knowledge and experience
• Customer communications that are clear, fair and not misleading – for example highlighting risks and benefits in equal proportion
• Procedures where advice is provided and where advice is not provided
• Ongoing services for customers, post-sale
• Regular reviews of products to ensure they remain fit for purpose, and comply with applicable laws and regulatory requirements
• Sensitivity to, and support for, customers who are, or may become, vulnerable by reason for example of illness, disability, bereavement, or other changes in life circumstances
• Fair treatment of customers during account closure or product withdrawal/maturity, for example in terms of communication of what is happening and what alternatives are available
• Oversight of any third party manufacturers or distributors of our products
• Development and maintenance of our peoples’ training and competency, and applicable licences and regulatory approvals

Our Charter

Our Charter makes clear that if our staff have concerns that the standards contained in our policies and procedures, or any other aspects of our conduct are not being adhered to, they can speak up – for example:

• Direct to their line manager, HR or Regulatory Compliance, or
• Anonymously through One IBC Confidential our multi-channel, confidential, disclosure and follow-up investigation service.

One IBC - Client KYC requirement

What can I show for identification and proof of address?

Your proof of identity

Provide one of the documents below and make sure it's both current and a certified copy (not the original).

• Your current passport or travel document (copies of passports should include all pages that contain signatures, the passport number and any extension dates where applicable)

Your proof of address

Provide one of the documents below and make sure it's both recent and certified.

• Your valid overseas driving licence (a copy, not the original)
• A utility bill (Water, Electricity ) or Telephone bill or home broadband, Sky or cable TV bill, dated within the last four months. Mobile phone bills are not acceptable.
• A bank statement. It needs to be dated within the last four months

How do I get my documents certified?

Ask one of the possible certifiers below to write the relevant statement on each of the documents they verify, if any of the documents are more than one page long ask the certifier to write the statement on the first page and sign any subsequent page.

We can only accept the following certifiers, they must be registered and active; financial institutions, lawyers, solicitors and notaries.

Next, ask your chosen certifier to write this on the document they are certifying:

For documents that contain a photo:

I (full name of certifier) confirm that this is an accurate copy of the original and the photo is a true reflection of the applicant.

For documents that don't contain a photo:

I (full name of certifier) confirm that this is a true copy of the original document for (full name of customer).

Each document must also include:

• certifier's signature and full name, they need to sign as an individual not a company
• certifier's occupation, company, professional address and phone number, ideally on letter headed paper
• certifier's professional registration number if they have one
• date of certification

It is important each document contains this information as without it we may not be able to accept them. The person signing the document must be active in the profession and can't be a relative, friend or someone who lives at your address. We may contact them for verification.

Please remember your documents must:

• be a certified true copy
• be in English or a certified translation to English
• certification and translation must be completed by the same person
• date of certification must be within the last three months
• not be an internet or branch print out
• show your full name (not initials) and address matching your application

The same document cannot be used twice to verify identify and address, so a different document must be used to meet the regulations and the One IBC criteria.

ANTI-MONEY LAUNDERING AND COUNTER FINANCING TERRORISM POLICY
ONE IBC LIMITED

Version: 1.1

First version date: 01 April 2018. Latest update: 03 September 2018

One IBC: One IBC LIMITED, Trust or Company Service Providers (TCSPs) licensed no.: TC001305

I.INTRODUCTION

ONE IBC is Private Limited company, a Company Services Provider (non-financial services) support to client worldwide to incorporation company, maintain and compliance with Hong Kong Company Registry as well as other related authority. ONE IBC committed to the highest standards in effort to comply with the applicable Anti Money Laundering and Counter Financing Terrorism (AML-CFT) standards. The Policy provides an introduction to anti money laundering and counter financing terrorism regulation.

The Management (BOD) and all employees are required to adhere the standards to protect ONE IBC and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.

Government has enacted laws and rules designed to implement the anti-money laundering and counter financing terrorism. The goal of these laws is to detect and prevent money laundering and potential terrorist financing. ONE IBC will adhere to applicable laws and regulations in Singapore.

ONE IBC will verify its AML – CFT framework, goals and strategies on an periodical basis and maintain an effective program for the ONE IBC’s business that reflects the best practices for financial institution in general.

II.STRUCTURE AND POLICY

ONE IBC has active Supervisory Board under Compliance Officer, and the implementation of AML – CFT Program handled by AML – CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to applicable AML – CFT Program derived from AML-CTF procedure.

ONE IBC has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML – CFT regulations.

The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:

1. Active supervision of the Board of Directors
2. Policies and Procedures;
3. Internal Control;
4. Information Management System; and
5. Human Resources and Training

III.CUSTOMER DUE DILIGENCE

ONE IBC has implemented know your customer (KYC) procedure to assure all kinds of customers are subject to identification and verification process. The KYC has been implemented in all branches and business units. The goals are ONE IBC has sufficient information and data about the customers profile, whom they deals with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and customers from high risk businessess or countries, name screening, and the ongoing monitoring and updating data of all existing customers.

ONE IBC shall refuse to support or has to close an existing clients, if the following:

• Cannot fix a reasonable belief that it knows the true identity of the customer and/or UBOs and/or the nature of business concerning the identification of the customers are not met;
• Known and/or suspected the utilization of fake documents;
• Assets that are known or suspected to be the proceeds of criminal activity;
• Enter into business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or listed on sanction lists;
• Maintain anonymous accounts or accounts operate for shell banks.

IV.REGULATORY REPORTING

ONE IBC has an obligation to report cash transaction with certain amount based on relevant regulation, suspicious transaction/activity, and international fund transfer. Suspicious transactions must be handled and escalated with approval of Compliance Officer prior reporting to regulator.

V.AML - CFT ENTITY RISK ASSESSMENT

The AML-CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML-CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on customer, country or geographical factors, products, services, transactions or distribution channels (delivery channels).

VI.SANCTIONS COMPLIANCE

Sanctions Compliance Implementation is important in ONE IBC activities. ONE IBC obligates to establish restrictions and controls on the movement of goods, services, and customers' funds were transacted through the products and services that provided by ONE IBC. Sanctions Compliance implementation goal is to keep ONE IBC from compliance risk, operational risk and reputational risk exposure. ONE IBC implements AML-CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation based on ONE IBC and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.

VII.RECORD RETENTION

ONE IBC has to record all data and or information regarding customers documents, client’s companies and/or its financial transactions (if any). ONE IBC maintains customers documentations for minimum of 5 (five) years, notwithstanding to longer retention as required. ONE IBC will provide information and/or documents competent authorities as ordered by laws and regulations, when required.

VIII.TRAINING

ONE IBC has implemented AML – CFT training program for all staff. ONE IBC’s training program is tailored to the operations and business unit to assure all staffs are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML – CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.

IX.INTERNAL CONTROL

ONE IBC has an effective internal control system. ONE IBC’s AML – CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML – CFT Program.

This Policy is an integral part of ONE IBC’s Anti-Money Laundering and Counter Financing Terrorism Procedure and shall take effect from 01 April, 2018.

Regards,

Vu Dai Duong

Risk & Compliance Manager.