1.0. INTRODUCTION

SKILLWAVE SMART, a Technology company, which offers individuals a platform to network and get work opportunities under a safe work environment, is committed to the highest standards of Anti-Money Laundering (AML) compliance and ethical business conduct.

This policy outlines our commitment to detecting and preventing money laundering and terrorist financing activities in compliance with the requirements of the Special Control Unit Against Money Laundering (SCUML) under the Economic and Financial Crimes Commission (EFCC) in Nigeria, and other anti-money laundering/corruption laws.

2.0. Purpose of Policy

At Skillwavesmart Limited, we maintain a zero-tolerance stance on money laundering, terrorist financing and corruption in all its forms. This policy aims to prevent our platforms from being used to facilitate money laundering, corruption or terrorist financing activities, in accordance with the Money Laundering (Prohibition) Act, 2011, The Terrorism (Prevention) Act, 2011 and the Central Bank of Nigeria's (CBN) Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regulations.

Under no circumstances shall freelancers, employers, contractors, or third parties using our platforms engage in corrupt practices, money laundering, or any behavior that compromises the company’s commitment to ethics and legal compliance.

The Company is further committed to implementing a robust Know Your Customer (KYC) program to protect the integrity of our platform and its users. This Policy outlines the procedures we follow to detect and prevent the use of our services for money laundering, terrorist financing, or other illegal activities.

2.1. PURPOSE OF POLICY

This policy is designed to:

1. Protect the Company, its platform users (freelancers, employers, third parties), and other stakeholders from risks related to money laundering, terrorist financing and any/every other financial crimes;
2. Ensure compliance with applicable Nigerian Laws, including the Economic and Financial Crimes Commission (EFCC) guidelines, and the Special Control Unit Against Money Laundering (SCUML) regulations;
3. Safeguard the reputation of the Company by fostering transparency and ethical practices.

3.0. Scope

This policy applies to all users of our website and mobile app, including freelancers, employers, employees, workers and any other relevant parties who engage with our services. The scope of the policy includes:

1. Bribery and Corruption
   Bribery in any form, whether offering, giving, receiving, or soliciting, is strictly prohibited. This applies whether the bribe involves cash, gifts, hospitality, services, or any other advantage.
2. Third-Party Relationships
   SKILLWAVE SMART’s policy prohibits bribery or corrupt practices by any third party engaged with the company. All third parties, including agents, contractors, employers, workers, freelancers, must adhere to our anti-bribery and corruption standards.
3. Political Contributions
   We do not permit the use of company funds, resources, or assets for political contributions, either directly or indirectly. This includes monetary donations, gifts, or any form of support to political parties, candidates, or government officials that may influence business outcomes.

4.0. Definitions

1. Bribery
   Bribery is the offering, giving, receiving, or soliciting of anything of value to influence the actions of an individual or organization in charge of a public or legal duty. Bribery can take many forms, including gifts, hospitality, money, favors, or preferential treatment.
2. Facilitation Payment
   Facilitation payments are unofficial, typically small payments made to secure or expedite routine governmental actions. These payments are generally prohibited under anti-bribery laws, including those covered by this policy.
3. Corruption Corruption refers to the abuse of entrusted power for personal gain. This includes actions like bribery, embezzlement, nepotism, and the misappropriation of funds.
4. Money Laundering
   The process of disguising the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.
5. Suspicious Transaction
   A transaction that appears unusual or irregular, suggesting possible money laundering or terrorist financing.
6. Terrorist Financing
   The provision of funds or financial support to individual terrorists or terrorist groups.
7. SCUML
   Special Control Unit Against Money Laundering, a department under the EFCC responsible for overseeing compliance with AML regulations in designated non-financial businesses and professions (DNFBPs).

5.0. POLICY STATEMENTS

Risk Assessment and Management

• Conduct regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks.
• Implement risk-based procedures for customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk customers or transactions.

Customer Due Diligence (CDD)

• Verify the identity of all customers and beneficial owners before establishing a business relationship or conducting transactions.
• Maintain accurate and up-to-date customer information and documentation.
• Apply enhanced due diligence measures for politically exposed persons (PEPs) and other high-risk individuals or entities.

Transaction Monitoring

• Regularly review and monitor transactions for suspicious activity, such as large cash transactions or unusual payment patterns, including unusual or complex transactions that do not have a clear economic or lawful purpose.

Record Keeping

• Maintain records of all transactions, customer information, and due diligence documentation for at least five years.
• Ensure records are readily available for inspection by SCUML and other regulatory authorities.

Reporting Suspicious Activities

• Report any suspicious activities or transactions to the relevant authorities, including the Nigerian Financial Intelligence Unit (NFIU) and SCUML, in accordance with legal and regulatory requirements and also maintain Confidentiality.

Training and Awareness

• Provide regular AML training to all employees to ensure they understand their responsibilities and the importance of compliance with AML laws and regulations.
• Update training materials regularly to reflect changes in legislation, regulations, and industry best practices.

Internal Controls and Audit

• Establish robust internal controls and procedures to ensure compliance with AML policies and regulations.
• Conduct regular audits and reviews of AML controls and procedures to identify and address any weaknesses or areas for improvement.

Cooperation with Authorities

• Cooperate fully with SCUML, the EFCC, and other regulatory and law enforcement authorities in their investigations and compliance assessments.
• Provide timely and accurate information as required by regulatory authorities.

6.0. RESPONSIBILITIES

1. Platform Users: All platform users are responsible for ensuring compliance with this policy. This includes understanding and applying the rules, and reporting any suspicious activity or violation of the policy.
2. Management Team:Skillwavesmart Limited’s management team must foster a culture of compliance and ensure that their teams understand and comply with this policy. They are responsible for promoting ethical business conduct and ensuring their teams receive adequate training on antibribery and anti-corruption practices.
3. Compliance Officer:The Compliance Officer is responsible for ensuring the policy’s effectiveness and compliance with international and local anti-money laundering and corrupt practices regulations. The Compliance Officer shall manage in-house training of management team, monitoring, and updating of the policy to reflect legal and operational changes. The officer also handles reporting and investigation of violations.

7.0. REPORTING VIOLATIONS

SKILLWAVES LIMITED encourages all team members, platform users and associated third parties to report any concerns about bribery, corruption, or other unethical practices. Reports can be made anonymously, and we guarantee protection for whistleblowers against retaliation or victimization. Reports can be submitted via: Email: complaint@skillwaveng.com

Procedure for Reporting Suspicious Transactions

• Identify a suspicious transaction.
• Document all relevant information.
• Report to the Compliance Officer.
• Submit a Suspicious Transaction Report (STR)

All reports shall be treated confidentially and thoroughly investigated by the Compliance Officer.

8.0. NON-COMPLIANCE

Team members, Platform Users and third-party representatives who violate/fail to comply with this policy shall face all necessary legal action, including but not limited to, contract termination, and legal prosecution. Skillwavesmart Limited reserves the right to terminate any third-party relationships that violate this policy or show disregard for anti-bribery laws.

9.0. POLICY REVIEW AND UPDATES

This policy shall be reviewed and updated annually, or more frequently if needed, to ensure compliance with changing regulations, laws and/or business practices. Any amendments to the policy shall be communicated to all necessary/affected parties.

KNOW YOUR CUSTOMER (KYC) POLICY

1.0. INTRODUCTION

To maintain the security of our platforms, the Company follows a rigorous KYC process for both freelancers and employers before they can fully access our services.

2.0. USER VERIFICATION

All users (both freelancers and employers) must provide the following (and any other necessary) information:

1. Full name (as shown on government-issued ID)
2. Contact details
3. Identification Documents (e,g, government-issued ID, passport)
4. Business details (for employers, where necessary) including business name, address, etc.

3.0. VERIFICATION PROCESS

The Company shall verify the authenticity of the documents provided through secure third-party services where applicable. Users must successfully pass this verification process before gaining full access to the platforms.

4.0. ONGOING MONITORING

The Company reserves the right to conduct periodic reviews and request additional information from users if suspicious activity(ies) id detected or as a part of occasional routine compliance checks.

5.0. ACKNOWLEDGMENT

I acknowledge that I have read, understood, and agree to comply with SKILLWAVE SMART Limited’s Corrupt Practices and Anti-Money Laundering (AML) Policy and Know Your Customer (KYC) Policy. I understand that any violation of this policy shall result in disciplinary action, including possible termination of contract and legal consequences.

Conclusion

This Corrupt Practices and Anti-Money Laundering (AML) Policy and Know Your Customer (KYC) Policy underscores SKILLWAVE SMART Limited’s commitment to conducting business with integrity and transparency. By adhering to this policy, Team members, Freelancers, Employers, and other third parties shall help the company maintain its reputation for ethical business practices and ensure compliance with know your customers, anti-money laundering and anti-corruption laws locally and globally.