Acceptance policy for customers

Responsible Insurance: Know your customer

Buy law Insurance companies, insurance advisors and insurance intermediaries need to know with whom they do business with. This investigation is also referred to as screening. In doing so, we prevent transactions from being processed from relationships that deliberately launder money, evade taxes or finance terrorism or other criminal activities.

Services to customers may imply that Pogona Insurance BV (hereafter Pogona Insurance) are exposed to risk of doing business with unethical relationships and/or committing an economic offense. By adhering to the customer integrity policy and the compliance with Sanctions Regulations.

Pogona Insurance wants to prevent from acting carelessly or culpably in money laundering transactions, terrorist financing, fraud and/or other risky non-integer or norm-transgressing behaviour. Know your customer forms part of the obligations Pogona Insurance has in the field of sound business operations. Pogona Insurance accepts new customers with the required care and strives for the best possible knowledge of the customer. In doing so, we examine who the customer is, what activities they carry out, who the ultimate beneficial owner is with a legal entity. And Pogona Insurance wants its activities to comply with laws and regulations and its internal standards. With this in mind, Pogona Insurance will:

• Take all reasonable measures to only have customers in good standing;
• Take all reasonable measures to discover cases where it is being abused for money laundering or financing terrorism;
• Take all reasonable measures to cooperate with competent governmental authorities to implement anti-money laundering and terrorist financing laws

Pogona Insurance will not accept customers in the following cases:

• If the customers survey does not lead to identification;
• If the customers survey leads to suspicion of money laundering of financing terrorism;
• Sanction Regulation apply to the customer (Sanctions Act);
• Branches and customers who do not act in accordance with generally accepted and ethical principles such as:
• Human rights violations;
• Child labour
• forced labour and international
• labour rights;
• The production of or trade of (controversial) weapons;
• Forms of corruption or fraud;
• A customer associated with ‘negative’ publicity (adverse media).

Compliance with Sanctions Regulations

Pogona Insurance complies at all times with the Sanctions Regulations. Relationships are monitored against the sanctions lists of the EU, the UN and Dutch sanctions list. This screening of relations takes place upon acceptance, periodically and/or with changes to the customer base and changes to the sanction lists.