DOMICILE

Oasis Capital B.S.C.(c) (the “Company”) is licensed as an Investment Business Firm (Category-1) by the Central Bank of Bahrain. The Company is located in the capital Manama, Kingdom of Bahrain.

The main activities of the Company include asset management of real estate & private equity investments.

LAWS AND SUPERVISION

The Company is under the supervision of the CBB and complies with the CBB Decree Law No. (4) of 2001 with respect to the Prevention and Prohibition of the Money Laundering.

The CBB has adopted and is compliant with the forty recommendations plus nine special recommendations issued by the Financial Action Task Force (FATF), which are the international standards, for effective anti-money laundering regimes.

The Kingdom of Bahrain is a member of the Gulf Cooperation Council (GCC), which is a member of FATF. The Kingdom of Bahrain is also a member of MENAFATF, which is an associate member of FATF.

THE Company’S POLICIES

The Company will conduct its business in conformity with high ethical standards and will adhere to all laws and regulations pertaining to financial institutions.

The Company will conduct its business in compliance with the following general principles:

• Ensuring that the highest standards of due diligence are applied to the “Know Your Customer” principles. Every staff member complies with legislation requirements and appropriate guidelines in the jurisdictions in which the Company operates.
• Protecting the Company, beneficial owners, our clients and staff from money laundering & terrorist financing at all times.
• Maintaining written AML policy and procedures, addressing a system of internal controls to ensure ongoing AML compliance by the MLRO and take appropriate action, in case any suspicious transaction is detected.
• Compliance with applicable anti-money laundering & terrorist financing laws and regulations as established by CBB in accordance with the recommendations of the Financial Action Task Force on Money Laundering & Terrorist Financing.
• Application of the Company’s anti-money laundering policies to all business units.
• Ongoing monitoring of compliance with the Company’s anti-money laundering policies through a combination of internal audit, external audit and regulatory reviews of compliance with relevant anti-money laundering legislation and/or regulations.
• Ensuring that the Company does not conduct any business with a Shell Company. In addition to this, the Company does not open anonymous accounts.
• Initial and ongoing training of staff on KYC and anti-money laundering policies and new AML laws and regulations. Training and Career Development has an ongoing training program for the appropriate staff with emphasis on anti–money laundering and terrorist financing.
• The Company has a system in place to detect transactions involving clients who are on the UN Sanction List and other similar international lists.
• Conducting Enhanced Due Diligence for all high risk customers.
• The Company has effective procedures for verifying client identification, source of funds and for retention of all customer due diligence information.
• Reporting all identified instances of suspicious activity to the relevant authorities as provided under all applicable laws.
• Not initiating, developing relationship or entertaining prohibited accounts, as instructed by CBB.
• Cooperating fully with law enforcement and regulatory agencies in executing their duties under all applicable laws.