Prevention and Combat Money Laundering and Financing of Terrorism Policy

Version 01/2022

Approving Body: Executive and Operational Board

Application Area: Brazil

Approval date: 02/05/2022

Release Date: 18/05/2022

 

1. OBJECTIVE

This Policy for Preventing and Combating Money Laundering or Concealment of Assets, Rights and Values ​​and Financing of Terrorism (“Policy”) aims to establish principles, guidelines and procedures that must be observed by all members of the INNOVEA HUB (“Organization”) in the course of its commercial operations, including Customers, Providers, Candidates and Partners, in order to prevent its systems and operational structure from being used to commit money laundering and terrorist financing practices.

It is noteworthy that both the observation of specific legislation and the stipulation of internal controls will be adapted to i. size and area of ​​activity of the Organization, ii. profile of customers and partners, iii. type and complexity of services and products offered, thus adapting to your risk profile.

In this sense, the INNOVEA HUB is willing to cooperate with any regulatory bodies if requested.

 

2. REFERENCE STANDARDS

The Brazilian legislation that specifically deals with the crime of money laundering or concealment of assets, rights and values ​​is Law No. 9.613, of March 3, 1998. In addition, there is Law No. 13.260 that disciplines terrorism. In addition INNOVEA HUB seeks to respect the rules, circulars, circular letters and communications issued by the competent authorities such as the Central Bank of Brazil (BACEN) and the Financial Activities Control Council (COAF), especially those listed below, in what is applicable and compatible with the activities of INNOVEA HUB, and the standards used as a reference for the preparation of this Policy are:

• Law No. 9.613 of 1998.
• Law No. 13.260 of 2016.
• BACEN Circular No. 3.978 of 2020.
• BACEN Circular Letter No. 4.001 of 2020.
• COAF Resolution No. 40 of November 22, 2021

 

3. SCOPE OF APPLICATION

The terms of this Policy must be observed by all employees, service providers, customers using the platform services and members of the Executive and Operational Board of INNOVEA HUB.

 

4. PRINCIPLES

Below are listed the principles that must be followed by all employees, service providers and members of the Executive and Operational Board of INNOVEA HUB:

• ZERO TOLERANCE: Involvement of partners, employees and customers of the company is not tolerated. INNOVEA HUB money laundering and terrorist financing. In addition, the use of TaaS and intermediation services by the Platform of INNOVEA HUB for illicit activities. Likewise, non-compliance with the internal AML/FT rules set forth in this policy is not allowed.
• RISK-BASED APPROACH: Its objective is to analyze and identify the LD/FT risks of the operation, in order to establish specific internal procedures to prevent financial crime.
• ANALYSIS OF OPERATIONS: There will be monitoring of operations by the team of INNOVEA HUB in order to identify atypical transactions.

 

5. DEFINITIONS

• Money laundry – It is characterized by a set of commercial or financial operations that aim to make illicit money lawful, so that the criminal hides or disguises the nature, origin, location, disposition, movement or ownership of goods, rights or values ​​arising, directly or indirectly, of criminal offense, so that these assets have an apparently lawful origin.
• Financing of Terrorism – Providing or collecting funds with the intention of using them or knowing that they will be used, in whole or in part, for the commission of acts that constitute international offenses, or that cause death or serious bodily harm to civilians or persons who are not participate directly in armed conflict.

 

6. MONEY LAUNDERING PHASES

The washing process is dynamic and consists of 3 (three) phases:

• Placement – ​​Refers to the placement of money from an illicit origin in the economic system, which can occur through deposits, purchase of negotiable instruments or purchase of goods. A characteristic of this phase is the fragmentation of the amount arising from illicit origin so that it is not noticed by Organs inspection bodies.
• Concealment – ​​Consists of hindering the accounting and financial tracking of illicit resources. At this stage, the criminal will carry out complex and diverse financial transactions in order to disassociate the money from its illegal origin.
• Integration – In this last stage, the money is incorporated into the economic system, presenting an apparently legal character and being made available to criminals again.

 

7. RESPONSIBILITIES OF INNOVEA HUB AND ITS PROFESSIONALS

All professionals from INNOVEA HUB , within their activities and regardless of their hierarchical positions, they have functions and responsibilities related to preventing and combating money laundering and the financing of terrorism. The organizational structure mentioned below is directly identified with the responsibilities of each of the professionals with the conduct of preventing and combating the crime of money laundering and respecting the aforementioned legislation and standards.

7.1. Executive and Operational Board

It is the responsibility of the Executive and Operational Board to:

• Implement and monitor compliance with this Policy and other rules related to it, as well as keep them updated;
• Provide financial and human resources so that this Policy can be implemented, developed and improved, together with the procedures and internal controls necessary for its execution;
• Analyze the reports and request that risk mitigation measures be implemented by specific sectors and professionals, whose mission is to develop, improve and monitor compliance with this Policy, as well as to disseminate the culture of preventing and combating money laundering and the financing of terrorism .
• Communicate to partner companies, contractually linked to the INNOVEA HUB and whose services are developed in cooperation, on possible suspicious operations of money laundering and financing of terrorism so that the partner company can take the measures it deems appropriate.
• Check, based on samples, compliance with the guidelines of this Policy and the procedures implemented as a result of it.

7.2. Human Resources

It is the responsibility of the Human Resources Team:

•  Promote periodic training, in order to inform employees and service providers about this Policy, legal and regulatory determinations, as well as existing internal procedures;
• Investigate the data and reputational analysis of employees and service providers at the contracting stage, as well as accompany them in the execution of their activities within the INNOVEA HUB, with special attention to cases in which there is a sudden or unjustifiable change in financial condition, external negotiations, direct involvement with platform users and/or partners.

7.3. Customer Registration and Compliance

It is the responsibility of professionals working in the Registration area to validate data and request additional documents and/or clarifications from the client/user, as well as the essential compliance with all procedures defined here, adhering to normally expected practices. as basic, with special attention to:

• Identify and be able to prove the veracity of the data provided by the user of the platform, whether natural or legal, in accordance with the “Know Your Customer” or “Know Your Customer” Policy.Know Your Customer";
• Keep the user registration always updated, seeking to require the renewal of information in a period not exceeding 12 (twelve) months or a shorter period eventually defined by law or specific regulation;
• Consult the Executive Board or the responsible internal department when there is any indication of irregularity or questioning regarding the procedures adopted by users. Consult the possible presence of clients in restrictive lists such as, Slave Labor Dirty List, Specially Designated Nationals and Blocked Persons (SDN) it's theoffice of Foreign Assets Control (OFAC) and if these clients are listed, not provide intermediation services within the Platform.

7.4. Information Technology and Support Team

It is the responsibility of the Information Technology and Support Team:

• Ensuring that all online/offline systems of the INNOVEA HUB operate fully;
• In the event of adjustments, revisions or acts of God and force majeure that result in the temporary unavailability of services or reduce their functions, you must communicate this fact to the sector responsible for direct contact with users, so that they can receive the appropriate guidance by part of the team INNOVEA HUB.

7.5. All other sectors and respective Professionals

All other sectors, professionals and partners that are not listed here must respect the binding rules set forth in this Policy, as well as adopt a reputable posture consistent with the legal and normative determinations issued by the competent authorities, so that if suspicious activity of professionals is identified, customers and/or partners, has the obligation to report this fact immediately to the Executive and Operational Board or to another responsible sector.

 

8. INNOVEA HUB BEST PRACTICES FOR PREVENTION/PROTECTION

8.1. Getting to know our Clients, Contractors, Providers, Candidates and Professionals

A INNOVEA HUB always adopts a transparent and responsible attitude in the hiring of its professionals. Before starting to work in Innovea hub.

Furthermore, the professionals received periodic training on the prevention of money laundering and terrorist financing, among other matters relevant to the maintenance and development of the company's compliance environment. INNOVEA HUB.

8.2. Knowing our Customers

Respecting the legislation in force and regulatory standards, in what is applicable and consistent with its activities, the INNOVEA HUB seeks to establish a set of internal rules and procedures with the aim of getting to know its customers/users and partners (Clients, Contractors, Providers, Candidates, etc.), aiming to identify the risk profile, financial capacity, nature of their business, as well as understanding the motivation for contracting the services offered by the INNOVEA HUB, so it is obliged to collect and process this data in accordance with the General Personal Data Protection Law (Law No. 13.709 of 14/08/2018).

In this sense, the INNOVEA HUB does not maintain a relationship with third parties that show any indication of a relationship with any activities of a criminal nature or those that have business, whose nature of the activity does not allow minimal verification of the legitimacy of the activities or the origin of the funds handled or, finally, refuses to provide information or documents requested by the INNOVEA HUB, for security reasons provided for in legislation and anti-money laundering rules.

For the purpose of adapting to the best practices of identification and qualification of customers/users, INNOVEA HUB will have Central Bank Circular No. 3.978 of 2020 as a parameter.

It is recommended that the internal risk assessment be updated in periods not exceeding 24 (twenty-four) months, except for specific legislation applicable to the INNOVEA HUB which determines different period. All customers/users may, perhaps, be submitted to a list of restrictive CPFs/CNPJs that cannot use/contract the services offered by a INNOVEA HUB.

Among the specific and unique analyzes of each client/user of the Platform, special characteristics will always be observed that allow the understanding of the inherent risks of the INNOVEA HUB or tracking evidence of criminal conduct, which may be listed here, but not limited to the following points:

• Client Companies, Contractors and Service Providers, Candidates and Partner Professionals whose corporate structure is made up of Politically Exposed Persons (PEP);
• Client Companies, Contractors and Service Providers, Candidates and Partner Professionals whose corporate structure includes people residing in or trading in Sensitive Countries;
• Client Companies, Contractors and Service Providers, Candidates and Professional Partners who are residents or who trade in Tax Havens.
• Client Companies, Contractors and Service Providers, Candidates and Partner Professionals whose corporate structure are or have 1st and 2nd degree family members who are Politically Exposed Persons (PEP).

8.3. Getting to know our Partners and Third-Party Service Providers

A INNOVEA HUB will analyze the profile of partners and outsourced service providers, according to internal criteria, and may carry out a due diligence procedure compatible with the third party's risk profile, in order to understand the real risks of contracting, allowing it to occur within legal standards and in a manner transparent and suitable.

Due diligence will also consist of the process of analyzing the data, history and references of the Partners that seek to work with the INNOVEA HUB. It is essential to operate with Partners capable of bearing any losses they may cause, in order to guarantee minimum liquidity to all those involved in the services provided by INNOVEA HUB.

 

9. TREATMENT OF OCCURRENCES AND COMMUNICATION TO THE COMPETENT BODIES

If from the internal control and monitoring procedures the INNOVEA HUB suspect the occurrence or situations that cover up money laundering or terrorist financing by customers within its Platform or partners, the INNOVEA HUB undertakes to:

• Analyze suspicious transactions and situations within a maximum period of 45 (forty-five) days, counted from the date of selection of the transaction or situation, according to paragraph one, art. 43 of Circular 3.978 of 2020;
• Formalize a dossier capable of identifying those involved, the amounts transacted, dates, as well as the decision to communicate to the competent authorities must be substantiated;
• After formalizing the dossier, if the Executive and Operational Board concludes that the actions taken by clients or partners actually constitute a Money Laundering risk to INNOVEA HUB undertakes to take all reasonable measures to not allow unlawful actions to continue to occur on the Platform;
• Communicate the suspicious transaction to the institutions authorized by Banco do Brasil, when involved in the payment chain of the INNOVEA HUB, still, the INNOVEA HUB reserves the right to communicate such suspicion, together with the dossier, to the competent authorities, such as the Civil Police or COAF, as well as to cooperate with authorized financial institutions and competent authorities, for the purpose of complying with a legal duty, demonstrating zeal and diligence.

All information dealing with eventual occurrences will not be disclosed to customers and third parties, under any circumstances, except in those in which the judiciary determines under penalty of liability of the INNOVEA HUB.

Finally, especially with regard to reports of suspicious occurrences, provided for in BACEN Circular 3.978 of 2020, the INNOVEA HUB will not report such situation to the suspicious individual or legal entity, with the data and information referring to suspicious financial transactions used exclusively by the Regulatory and investigative Bodies for examination.

 

10. FINAL PROVISIONS

This Policy was prepared for internal use, and in cases that the Board of Directors of INNOVEA HUB necessary, make available to third parties, and the submission must be sent by physical or digital means with the respective copyright protections and anti-copy code.

10.1. Period for maintaining data and information of Customers, Partners, Employees and Service Providers

The documents and registration information of customers, employees, partners and service providers will be kept in the internal records of INNOVEA HUB, for the period indicated in the applicable legislation or when omitted, according to internal criteria.

Furthermore, it is the obligation of the partner institutions of the INNOVEA HUB, which are authorized by the Central Bank of Brazil to operate, respecting the specific deadlines for preserving data and information on partners, customers and operations.

10.2. Professional Science

All professionals declare here that they are aware that the INNOVEA HUB may monitor any and all activities carried out in the physical and virtual spaces of the INNOVEA HUB, whether or not exercising their activities related to the positions/functions, with the sole purpose of identifying suspicious conduct and giving effect to this Policy, in addition to the other applicable internal rules.

Also in this sense, in the event of breach of this Policy by professionals, partners or service providers, the INNOVEA HUB reserves the right to analyze the conduct, the severity of the damage caused and terminate the service agreement in force between the Parties.

It is also clarified that, under no circumstances does the termination make unfeasible any action for damages on the part of the INNOVEA HUB, in the face of the agent that caused the non-compliance.

10.3. Policy Update
The update of this Policy will occur whenever (i.) relevant legislative or regulatory changes occur, (ii.) the Organization's business scenario changes; or if (iii.) as a result of the review of the risk analysis it is so necessary, being the responsibility of the Executive and Operational Board or the compliance sector, if already implemented, make the changes and submit it for approval by the Executive and Operational Board .

 

11. AREAS INVOLVED

This Policy was prepared by the external legal department, which at the request of the Executive and Operational Board may revise it.

 

12.APPROVAL AND TERM

This Policy was approved on 02/05/2022, by the members of the Board of Executive Officers, entering into force on the date of its approval.

Furthermore, the validity of this Policy is indefinite and may only be replaced by an updated version.

 

May 18, 2022.