Anticorruzione - Namdar Diamods

Anti-bribery

Anti-Money Laundering & Know Your Counterparty (KYC) Policy and Procedure Template (COP12)

This policy confirms NAMDAR DIAMONDS commitment to prevent money-laundering and the financing of terrorism in its business practices and and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

NAMDAR DIAMONDS has established Know Your Counterparty (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.

NAMDAR AVISHAY responsible for development and implementation of this policy and relevant procedures, and NAMDAR DIAMONDS commits to review our KYC policy and procedure every year.

To support our KYC policy and procedures, KYC, NAMDAR DIAMONDS has developed a KYC form which we send to all our counterparties (this is our business partners: suppliers and customers) to collect relevant business information to identify risks of money-laundering. We require the form to be completed for all existing and new counterparties. nuove.

By collecting and reviewing the information in completed KYC forms, NAMDAR DIAMONDS commits to:

establishing the identity of our counterparties
checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in high-risk jurisdictions (FATF – linknamed on government sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRA – link)
maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses
maintaining KYC records for at least five years
maintaining records of all single or linked cash (or cash-like) transactions above 1.000,00 EUR (example for Italy)
monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

Cease trading with the counterparty
Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list
Make an on-site visit to the high-risk counterparty.

Approved on 05/11/2024

Our Strength

Professionalism and expertise

Excellent Make

Our goods are well selected and appreciated for cut and color (D-H), fundamental for the final effect on the finished product.

Round & Fancies

Our stock ranges from the classic round cut to more shapes in fancy cuts for batches or precise measurements, always maintaining a high quality of the product.

Ethics

We are pleased to be members of the Responsible Jewellery Council (RJC) to provide maximum transparency to our customers regarding the provenance of natural diamonds.

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Office: +39 0131 924550

Email: diamanti@diamonds.it

Anti-bribery

NAMDAR AVISHAY responsible for development and implementation of this policy and relevant procedures, and NAMDAR DIAMONDS commits to review our KYC policy and procedure every year.

By collecting and reviewing the information in completed KYC forms, NAMDAR DIAMONDS commits to:

establishing the identity of our counterparties

maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses

maintaining KYC records for at least five years

maintaining records of all single or linked cash (or cash-like) transactions above 1.000,00 EUR (example for Italy)

monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.

If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:

Cease trading with the counterparty

Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list

Make an on-site visit to the high-risk counterparty.