PREVENTION OF MONEY LAUNDERING ACT (PMLA) POLICY

For Invexmart Financial Services Pvt. Ltd.

Effective Date: [10/03/2025]

Approved By: Board of Directors

Review Date: [Annually or as required]

1. Objective

The objective of this policy is to ensure compliance with the Prevention of Money Laundering Act, 2002 (PMLA), rules, and regulations issued thereunder. This policy aims to prevent Invexmart Financial Services Pvt. Ltd. from being used, intentionally or unintentionally, for money laundering or terrorist financing activities.

2. Applicability

This policy applies to all employees, directors, and agents of Invexmart Financial Services Pvt. Ltd. engaged in brokerage, trading, or any other securities-related activities.

3. Definitions

– Money Laundering: Any process to conceal the origin of illegally obtained money to make it appear legal.

– Beneficial Owner: The natural person(s) who ultimately owns or controls a client and/or the person on whose behalf a transaction is conducted.

– Suspicious Transaction: A transaction which raises suspicion in the mind of the reporting entity as defined under PMLA rules.

4. KYC (Know Your Customer) Procedures

1. Client Identification:
   – Mandatory KYC documents: PAN card, Aadhaar, Passport, Voter ID, or any other government-issued ID.
   – Proof of address: Utility bills, bank statements, or government-issued documents.
2. Verification:
   – Documents must be verified through original presentation or digital verification.
   – Ongoing monitoring for changes in client profile.
3. Risk Profiling:
   – Clients will be classified as low, medium, or high risk based on transaction patterns, occupation, location, and business activity.

5. Record Keeping

– Maintain records of all transactions for minimum 5 years.
– Keep KYC documents, transaction records, and correspondence available for inspection by regulators.

6. Reporting of Suspicious Transactions

– Any transaction identified as suspicious must be reported to the Principal Officer.
– The Principal Officer is responsible for reporting to the Financial Intelligence Unit – India (FIU-IND) as per PMLA guidelines.
– Maintain confidentiality of reported transactions.

7. Appointment of Principal Officer

– Invexmart Financial Services Pvt. Ltd. shall appoint a Principal Officer responsible for ensuring compliance with PMLA and AML guidelines.
– The details of the Principal Officer shall be communicated to FIU-IND.

(Name : Mrs. Subashini D Designation: Principle Officer Contact Details: 7824888855)

8. Employee Training

– All employees must undergo periodic training on AML laws, KYC procedures, and identification of suspicious transactions.
– Training records should be maintained by HR/Compliance Department.

9. Internal Controls and Audit

– Regular internal audits to ensure compliance with PMLA.
– Review of unusual transactions, client risk categorization, and record-keeping practices.

10. Confidentiality

– All client information and transaction data collected under this policy are confidential.
– Disclosures are only made to competent authorities as mandated by law.

11. Policy Review

– This policy shall be reviewed at least once a year or as per regulatory changes.
– The Board of Directors approves any amendments to this policy.

Approved By: Mrs. Dhandapani Velu Lakshmi Devi
Date: 10/03/2025

Principal Officer: Subashini D