POLICY FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING

1. Introduction

SafeKids Foundation (the Foundation) is an independent non-profit organisation established to bridge the gap in safety kills required for all child handlers through knowledge dissemination, with the objective of protecting the Nigerian child in schools and homes.

The Foundation is committed to equipping every child handler with safety skills and ensuring that every school in Nigeria adopts functional safety management systems through collaborative stakeholder engagement.

The Board of Trustees and management of SafeKids Foundation acknowledge good corporate citizenship as a means of creating enduring organisational value by upholding strict ethical standards, which meet the expectations of stakeholders, constituted authorities and the society at large.

Consequently, the Board considers the organisation as a veritable partner with relevant authorities as the first line of defence against exploitation of its resources, brand, and goodwill, as well as those of its partners and beneficiaries, as a conduit for money laundering and financing of terrorism.

The Board's commitment to this objective is reaffirmed in this policy which provides guidance for compliance with the Anti-Money Laundering and Counter Financing of Terrorism regime in Nigeria, as set out in the Money Laundering (Prevention and Prohibition) Act, 2022 and relevant regulations issued by the Special Control Unit against Money Laundering (SCUML).

Compliance with the contents of this policy is mandatory for all employees, volunteers, and representatives of SafeKids Foundation;therefore, its effective application requires that all employees and volunteers be familiar with its contents and the laws and regulations under which they were written. The Foundation shall provide all relevant personnel with a copy of this manual to serve as an operational guide in protecting the Foundation against fraud, reputational, and other forms of risk.

Vision

To equip every child handler with safety skills; and every school in Nigeria with functional Safety Management Systems in order to protect the Nigerian Child.

Mission

To bridge the gap in safety skills required for all child handlers through knowledge dissemination, providing a platform for stakeholders to collaborate effectively for child protection

Values

We are ICE! - An Integrity, Child-centred, and Excellent Tribe!

• I - we are accountable for every spend, reach, and impact.
• C - our focus is on the child and their wellbeing.
• E - committed to meeting and surpassing stakeholder expectations

2. Definition of Terms

3. Controls to Prevent Money Laundering

The Foundation shall implement robust systems and controls to prevent, detect, and respond to money laundering and related financial crimes. These measures shall include:

• Establishing and maintaining effective internal controls, policies, and procedures to ensure ongoing compliance with applicable laws and regulations.
• Appointing a designated Compliance Officer responsible for overseeing AML compliance.
• Developing and maintaining comprehensive record-keeping systems for all financial transactions and Donor identification and verification processes.
• Implementing clear internal procedures for identifying and reporting suspicious activities.
• Providing regular training and awareness programmes to ensure all staff understand applicable AML requirements and their responsibilities.

In addition, internal controls and policies shall be designed and documented to:

• Ensure that any employee or volunteer who suspects money laundering is aware of the appropriate reporting channels and promptly reports such suspicions to the Compliance Officer; and
• Enable the Compliance Officer to adequately assess reported suspicions and determine whether such matters should be escalated to the appropriate regulatory authorities, including the Nigerian Financial Intelligence Unit (NFIU) and the Special Control Unit Against Money Laundering (SCUML).

4. Anti-Money Laundering Compliance Officer

All employees and volunteers are required to promptly notify the Compliance Officer where they know, suspect, or have reasonable grounds to suspect that any transaction or activity may be linked to money laundering or other financial crimes, whether such activity has occurred or is likely to occur.

Employees and volunteers are also encouraged to consult the Compliance Officer for guidance on any questions, uncertainties, or concerns relating to the Foundation's Anti-Money Laundering policies and procedures.

5. Donor Identification (Partners/Donors/Sponsors)

The Foundation's Anti-Money Laundering policies and procedures are designed to ensure that, prior to accepting any funds, all reasonable and practicable steps are taken to verify the identity of partners, donors, and sponsors. Where reliance is placed on third parties for donor identification such as banks, financial institutions, or other intermediaries, the Foundation shall ensure that such parties adhere to equivalent due diligence and verification standards.

Accordingly, the Foundation shall only accept funds from new or existing donors where: [cite: 74]

• The donor's identity has been duly verified, and the donor is confirmed to be acting on their own behalf, unless full disclosure is made that the donor is acting for a third party; or
• Where the donor is acting on behalf of another person or entity, the identities of the ultimate beneficial owners or underlying parties have been satisfactorily verified.

Donor identification procedures shall be applied on a risk-based approach, taking into account the specific characteristics and risk profile of each donor. The Compliance Officer may, at their discretion, require enhanced due diligence measures where deemed necessary, even where a donor is not formally classified as high-risk. An Individual Partner/Donor/Sponsor Know-Your-Customer (KYC) Checklist shall be used as a guiding tool in the identification process.

All documentation obtained and checklists completed in the course of donor identification shall be properly retained by the Compliance Officer in accordance with the Foundation's records retention policy.

6. Suspicious Transaction Reporting (STR)

A suspicious transaction is any transaction which, having regard to its nature, pattern, or circumstances, gives rise to a reasonable suspicion of money laundering, terrorist financing, or other unlawful activity. Pursuant to the Money Laundering (Prevention and Prohibition) Act 2022, a transaction shall be deemed suspicious where it:

• Involves an unjustifiable or unreasonable frequency of transactions
• Is surrounded by conditions of unusual or unjustified complexity
• Appears to have no economic justification or lawful objective; or
• In the opinion of the Foundation, involves terrorist financing or is inconsistent with the known profile, activities, or legitimate operations of the partner, including grantees, consultants, service providers, or any other stakeholder engaged by the Foundation.

In applying this provision, the Foundation shall exercise reasonable care and professional judgment, taking into account its mandate of safeguarding children and ensuring that all partnerships and transactions align with lawful and ethical standards. All personnel must promptly report any suspicious activity to the Compliance Officer.

7. Reporting Procedure

All employees and volunteers shall promptly make internal reports to the Compliance Officer upon forming any knowledge, suspicion, or reasonable grounds to suspect that a transaction or activity may be linked to money laundering or related financial crimes.

Upon receipt of such a report, the Compliance Officer shall conduct a thorough assessment of the circumstances and determine whether further action or escalation is required. Where, upon review, the Compliance Officer confirms that the suspicion is reasonable, a report shall be made to the appropriate regulatory authorities, including but not limited to the Special Control Unit Against Money Laundering (SCUML) and the Nigerian Financial Intelligence Unit (NFIU), within the timeframe prescribed by applicable laws and regulations.

Under no circumstances shall any employee or volunteer disclose to a donor or any third party that a report of suspicious activity has been made or is being considered. Any such disclosure constitutes "tipping-off" and is strictly prohibited.

8. Record Keeping

The Foundation shall establish and maintain comprehensive and accurate records of all donor identification processes and financial transactions undertaken by the Foundation.

All records relating to Anti-Money Laundering compliance, including due diligence documentation and transaction records, shall be retained for a minimum period of five (5) years following the termination of the relationship with the donor or the completion of the transaction, as applicable. The Foundation shall ensure that all records are securely stored, readily accessible when required, and maintained in compliance with applicable legal and regulatory requirements.

9. Prohibited Conduct

It is strictly prohibited for any employee or volunteers of the Foundation to accept funds from unidentified or anonymous sources or to knowingly engage with donors whose identities cannot be satisfactorily verified. Employees and Volunteers shall not assist, advise, or facilitate any attempt by a donor to circumvent applicable laws, regulations, or internal controls.

Furthermore, employees must not ignore or fail to report suspicious financial activity, and under no circumstances shall they disclose the existence or submission of a suspicious activity report to any donor or third party, in compliance with the prohibition against tipping-off.

10. Monitoring, Review, and Audit

This Policy shall be subject to periodic review to ensure its continued effectiveness and alignment with applicable laws and regulations. The Foundation shall conduct regular internal or external audits to evaluate the adequacy and effectiveness of its Anti-Money Laundering framework. Where necessary, updates and amendments shall be made to reflect changes in legal or regulatory requirements and operational developments.