1. Policy Statement It is the policy of Aon Corporation, including its affiliates and subsidiaries (“Aon”), to comply with applicable Anti-Money Laundering (“AML”) laws and regulations in all countries in which Aon operates. These laws may include specific requirements on Client Acceptance Due Diligence, commonly referred to as “Know Your Client” or “KYC”.This Policy is intended to establish the minimum requirements for all Aon global operations. In some jurisdictions specific standards are applied. This policy is not intended to replace existing policies and procedures that may be required by local laws. Business Unit management is responsible for determining what, if any, additional procedures are required according to the local laws and regulationsin the jurisdictions where they operate. All employees are responsible for reporting potential violations of AML laws and regulations directly to the Legal or Compliance department or via the Ethics Helpline, subject to the laws and procedural requirements of the countries in which Aon operates. Aon strictly prohibits retaliation against anyone who makes a good faith report of an ethical or legalconcern. 2. Scope This Policy is applicable to all directors, officers and employees of Aon and any other individual or entity acting for or on behalf of Aon, whether operating inside or outside the United States (collectively referred to as “Company personnel”). This Policy also applies to all Aon entities, including subsidiaries and jointventures in which Aon holds a controlling interest. Forentities not controlled by Aon, the Company will proceed in good faith to use its influence to the extent reasonable under the circumstances to require the entities to implement policies which are similar to these. 3. Objectives The objective of this Policy is to ensure Aon does not engage in or facilitate transactions with the proceeds of illegal conduct, as prohibited by applicable AML laws andregulations. This Policy provides guidance on processes to identify, evaluate, report and mitigate the money laundering risks associated with the products, advice and services offered by Aon. 4. Definition Money laundering is defined as conducting or attempting to conduct a financial transaction designed in whole or part to conceal or disguise the nature, locations, source, ownership, or control ofthe proceeds of specific unlawful activity. It is the policy of Aon to evaluate all financial transactions and to comply with applicable anti-money laundering laws and regulations. 5. Policy Requirements
Business Unit management is responsible for taking action to ensure compliance with all money laundering laws and regulations. 1. Annual Risk Assessment Business Unit management must arrangefor the preparation of an annual money laundering risk assessment which will include, but not be limited to the following: a. Products, advisory processes or services. This will include whether the product is understood to be a recurring purchase with many long-term and repeat customers, one time transactions, high/low volume, high/low value, etc. b. The type of clients, markets and othercounterparties (where applicable) served (e.g. individuals or publicly traded companies, government related organizations, etc.).
Anti-Money Laundering Policy Version 1.2—March 2011
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Global Anti-Money Laundering Policy
c. The geographic area of operations. Are the products, advice or services sold within the country of operation, or do the transactions involve foreign entities orplacements? Are the geographies considered tax havens or otherwise ranked poorly in terms of corruption or transparency?
d. Management’s conclusions on the money laundering risk profile of their business unit’s activities. Annual risk assessment findings must be submitted to the Regional Compliance Leader. 2. Minimum Due Diligence Business Unit management is required to ensure the due diligence...