papmall® Safeguard

papmall® statement on conduct

Background

papmall® approaches to conduct is designed to ensure that through our actions and behaviors we deliver fair outcomes for our customers and do not disrupt the orderly and transparent operation of our business. Conduct is the critical component within all business activities including, including but not limited to strategy, business models and planning, our culture and behaviors including staff recruitment/performance management, our interaction with customers, our products and services, our business operations, and our governance and oversight processes.

Our approach to conduct is key to winning and retaining our customers’ trust and loyalty. Focus on conduct is integral to papmall®’s values and business principles and supports the Group strategy for sustainable growth and streamlining of business processes and procedures.

papmall® has defined global outcomes relating to conduct which must be delivered by global businesses, global functions, and Operations, Services and Technology, each responsible for conduct within the scope of their activities, and must develop and maintain approaches, tailored to their markets and operations, which deliver the required global conduct outcomes.

Global conduct outcomes

Strategy and Business Models

• Our strategy, business models, and the decisions we make deliver fair treatment of customers and do not disrupt market integrity.
• Culture and Behaviours
• Our culture supports our people and empowers them to consistently do the right thing for our customers and markets in which we operate.
• Our people are competent and committed to the fair treatment of customers and not disrupting the integrity of markets.
• We are open to challenges, we acknowledge when things go wrong, we fix things and we learn from our mistakes.
• We reward and incentivise performance, behaviours and attitudes which deliver the fair treatment of customers and uphold market integrity.

Customer

• We know our customers and understand their needs – we actively listen to them and ask the right questions.
• Our products are designed to meet the different needs of our customers, to be competitive and to be understandable.
• Our products and services provide a balanced exchange of value between papmall® and our customers.
• Throughout our sales and servicing we are efficient, transparent and customer-focused.
• We manage our products and services so that our customers’ experience is in line with the expectations we set.

Markets

• We seek to prevent and will proactively identify actions and behaviours that constitute market misconduct, and respond appropriately.
• Trades are executed in a timely, clear and controlled manner ensuring that optimal execution is achieved for our customers and that papmall® trades are not manipulative.
• We manage conflicts of interest and appropriately handle information to reduce the opportunity for misuse
• Governance and Oversight
• Our governance framework provides effective oversight of how we fairly treat customers and uphold market integrity.
• We engage with regulatory bodies in a timely, open and transparent manner.

Activity and decision making within each global business, global function, and papmall® Operations, Services and Technology is expected to provide positive contribution to the global conduct outcomes, to ensure appropriate delivery of these outcomes.

Complaints handling

Our commitment to the highest standards of conduct and their embedding within our day to day activities is illustrated for example by our policy relating to complaints handling, which supports outcome:

We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes

Our global complaints policy sets out clear standards for:

• The processes by which we investigate and resolve complaints in a timely, unbiased, and effective manner
• Providing appropriate training to staff on our complaints processes, emphasising the need for empathy with customers
• Ensuring customers are aware of how to make a complaint via a variety of channels (for example via relationship managers, face to face, telephone, on-line, in writing)
• Resolving complaints at first point of contact wherever possible, and where this is not possible, providing an acknowledgement to the customer clearly setting out next steps
• Ensuring customers are kept regularly informed of progress to resolve the complaint
• Providing responses to customers upon completion of an investigation, clearly detailing the outcome and including, where appropriate, details of remedial action and any redress
• Notification to customers of any available rights of referral or appeal if the customer is dissatisfied with the handling of, or response to, the complaint
• Regular review of any “root causes” of complaints received to identify and address any systemic issues, and to inform process improvements where applicable
• Monitoring the quality and efficiency of our complaints handling, including adherence to relevant local regulatory requirements

Product governance and sales

This conduct commitment is further illustrated by our policy and procedures in respect of product governance and sales which support the customer pillar outcomes, and encompass standards for:

• The design, approval and ongoing maintenance of appropriate products/services, matched to customer needs, knowledge and experience
• Customer communications that are clear, fair and not misleading – for example highlighting risks and benefits in equal proportion
• Procedures where advice is provided and where advice is not provided
• Ongoing services for customers, post-sale
• Regular reviews of products to ensure they remain fit for purpose, and comply with applicable laws and regulatory requirements
• Sensitivity to, and support for, customers who are, or may become, vulnerable by reason for example of illness, disability, bereavement, or other changes in life circumstances
• Fair treatment of customers during account closure or product withdrawal/maturity, for example in terms of communication of what is happening and what alternatives are available
• Oversight of any third party manufacturers or distributors of our products
• Development and maintenance of our peoples’ training and competency, and applicable licences and regulatory approvals

Our Charter

Our Charter makes clear that if our staff have concerns that the standards contained in our policies and procedures, or any other aspects of our conduct are not being adhered to, they can speak up – for example:

• Direct to their line manager, HR or Regulatory Compliance, or
• Anonymously through papmall® Confidential our multi-channel, confidential, disclosure and follow-up investigation service.

ANTI-MONEY LAUNDERING AND COUNTER FINANCING TERRORISM POLICY (AML/CFT) papmall®

I. STRUCTURE AND POLICY

PAPMALL LIMITED. has an active Supervisory Board under Compliance Officer, and the implementation of AML - CFT Program handled by AML - CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to the applicable AML - CFT Program derived from AML - CTF procedure. PAPMALL LIMITED. has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML - CFT regulations. The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:

1. Active supervision of the Board of Directors;
2. Policies and Procedures;
3. Internal Control;
4. Information Management System; and
5. Human Resources and Training.

II. PARTNER DUE DILIGENCE

PAPMALL LIMITED. has implemented know your partner procedure to assure all kinds of partners are subject to identification and verification process. The know your partner procedure has been implemented in all business units. The goals are to have sufficient information and data about all partners’ profiles, whom they deal with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and partners from high risk businesses or countries, name screening, and the ongoing monitoring and updating data of all existing parnters. PAPMALL LIMITED. shall refuse to support or has to close an existing parnter, if the following:

• Cannot fix a reasonable belief that it knows the true identity of the partner and/or UBOs and/or the nature of business concerning the identification of the partners are not met;
• Known and/or suspected the utilization of fake documents;
• Assets that are known or suspected to be the proceeds of criminal activity;
• Enter into business relationships with individuals or entities known or suspected
• to be a terrorist or a criminal organisation or listed on sanction lists;
• Maintain anonymous accounts or accounts operate for shell banks.

III. REGULATORY REPORTING

PAPMALL LIMITED. has an obligation to report cash transactions with a certain amount based on relevant regulations, suspicious transactions/activities, and international fund transfers. Suspicious transactions must be handled and escalated with the approval of the Compliance Officer prior to reporting to the regulator.

IV. AML - CFT ENTITY RISK ASSESSMENT

The AML - CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML - CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on the partner’s country or geographical factors, products, services, transactions or distribution channels (delivery channels).

V. SANCTIONS COMPLIANCE

Sanctions Compliance Implementation is important in PAPMALL LIMITED. activities. PAPMALL LIMITED.'s obligations to establish restrictions and controls on the movement of goods, services, and partners’ funds were transacted through the products and services that were provided by PAPMALL LIMITED. Sanctions Compliance implementation goal is to keep PAPMALL LIMITED. from compliance risk, operational risk and reputational risk exposure. PAPMALL LIMITED. implements AML - CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation is based on PAPMALL LIMITED. and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.

VI. RECORD RETENTION

PAPMALL LIMITED. has to record all data and or information regarding partners’ documents, partners’ companies and/or its financial transactions (if any). PAPMALL LIMITED. maintains partners’ documentations for a minimum of 5 (five) years, notwithstanding longer retention as required. PAPMALL LIMITED. will provide information and/or documents to competent authorities as ordered by laws and regulations, when required.

VII. TRAINING

PAPMALL LIMITED. has implemented AML - CFT training program for all staff. PAPMALL LIMITED.’s training program is tailored to the operations and business unit to assure all staff are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML - CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.

VIII. INTERNAL CONTROL

PAPMALL LIMITED. has an effective internal control system. PAPMALL LIMITED.’s AML - CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML - CFT Program. This Policy is an integral part of papmall® Singapore Pte. Ltd’s Anti-Money Laundering and Counter Financing Terrorism Procedure and shall take effect from 01 January, 2021.