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AML and KYC Policy

AML policy and KYC "Know Your Client" requirements

HFSTH & Coll. attaches great importance to combating money laundering and terrorist financing, both within the company and within the framework of the projects it supports.

HFSTH & Coll. is committed to conducting its business in an objective, honest and impartial manner, ensuring the primacy of the interests of the company, its customers and the integrity of the market. This commitment to respecting the highest standards of ethical and professional behavior serves not only to ensure compliance with the laws and applicable regulations in the various jurisdictions in which Atrium operates, but also to maintain the confidence of its customers, shareholders, Employees and to attract and secure long-term partners.​

Money Laundering / Terrorist Financing
Due to the nature of HFSTH & Coll.' s activities. Money laundering and terrorist financing pose special and significant risks from a legal point of view and to protect your reputation. Compliance with anti-money laundering laws and regulations in place in the countries in which Atrium operates is of the utmost importance. With this in mind, Atrium has developed a program that includes:

– Appropriate internal procedures and controls (monitoring measures) – A recruitment training plan that is regularly updated


Monitoring
Good Know Your Client (KYC – Know Your Client) includes the mandatory identification and verification of the identity of the client, including, where appropriate, the powers of persons acting on behalf of the client, to ensure the security of dealing with a legitimate and lawful client.

– If it is a natural person: by presenting an official document, currently being validated, accompanied by a photograph. Information to be collected and stored is the surname(s) - in the case of married women also the maiden name, first names, date and place of birth of the person (nationality) as well as the type, date, place of issue and validity of the document, the name and the designating authority or the person who issued the document and, if applicable, the name of the person who certified it;

– If it is a legal entity, by sending the original or a copy of files or extracts from official registers no older than three months, its legal form, the address of the head office and the identity of its shareholders and social partners

The following information is also required:
Full address, phone numbers and/or GSM, email(s) occupation(s)

As well as the following documents:
Copy of passport, CV, bank statements, bank reference letter. If necessary, additional identification documents (ID card, driving license, residence permit.
This is not an exhaustive list and other information may be taken into account depending on the circumstances.
HFSTH & Coll. expects accurate and up-to-date information from its customers and the customer has a duty to inform them of any changes as soon as possible.

Measures in case of suspected fraud:
In the event of suspicion of money laundering or terrorist financing, or even beyond doubt as to the accuracy or relevance of the documents received to prove identity, HFSTH & Coll. undertakes:
not enter into business relationships or conduct transactions; Terminate all business dealings without providing any required explanation.​

In order to comply with current international anti-money laundering and customer due diligence (CDD) regulations, all customers and their authorized representatives must provide:
– Passport copy of the (ultimate) beneficial owner and a lawyer or other representative nominated by the beneficial owner. – Confirmation of the residential address of the beneficial owner and/or lawyer (agent) in the form of a utility bill, bank or credit card statement not older than 3 months and with the name and residential address of the person. – Description of the intended business activity of the new company, including geographical areas of application and approximate sales. – curriculum vitae – bank details

If a legal entity is part of the corporate structure (company shareholder or company director), additional related documents may be required to verify the ultimate beneficial owners of the ultimate entity.

Please note that HFSTH & Coll. reserves the right to request additional information for compliance purposes and in such cases detailed instructions will be provided by a HFSTH & Coll. All data provided by customers are for HFSTH & Coll. strictly confidential. The data protection declaration applies.

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