NHB guidelines on ‘ KNOW YOUR CUSTOMER’ & ‘ANTI MONEY LAUNDEERNG MEASURES’ for HFCs issued vide circular no NHB/ND/DRS/Pol-No. 33/2010-11 dated 11th October 2010 and revisions there after are the basis for Nivara’s policies and processes with respect to the following four pillars:

Customer Acceptance Policy

Customer Identification Procedures

Monitoring of Transactions

Risk management

For the purposes of KYC policy, a ‘Customer’ is defined under the guidelines as:

A person or entity that maintains an account and/or has a business relationship with Nivara

One on whose behalf the account is maintained (i.e. the beneficial owner)

Beneficiaries of transactions conducted by professional intermediaries, such as Stock Brokers, Chartered Accountants, Solicitors, etc. as permitted under the law, and

Any person or entity connected with a financial transaction which can pose significant reputational or other risks to the HFC, say, a wire transfer or issue of a high value demand draft as a single transaction.