Bajaj Infraventures LLP is committed to conducting its business with the highest level of integrity, transparency, and adherence to all applicable laws and regulations. In compliance with the Prevention of Money Laundering Act (PMLA), 2002, we have developed a comprehensive policy to mitigate the risk of money laundering and terrorist financing through our business operations.

Key Definitions

• Money Laundering: The process of concealing or disguising the origin of illicit funds to make them appear legitimate.
• Reporting Entity: Bajaj Infraventures LLP, as defined under the PMLA, is a reporting entity required to maintain and report certain records.

Objective

The primary objective of this policy is to:

• Prevent the misuse of Bajaj Infraventures LLP's services for money laundering or terrorist financing.
• Establish robust systems to detect and report suspicious transactions.
• Ensure full compliance with the PMLA, its rules, and any guidelines issued by relevant authorities.

Scope

This policy applies to all employees, associates, franchisees, and clients of Bajaj Infraventures LLP, as well as to all transactions conducted through our business verticals, including but not limited to lands, retail, commercial, industrial, pre-lease properties, F&B, entertainment, healthcare, and hospitality.

Compliance Framework

Customer Due Diligence (CDD)

• Verify the identity of clients through reliable and independent documentation (e.g., Aadhaar, PAN, Passport).
• Conduct Enhanced Due Diligence (EDD) for high-risk clients and transactions, including politically exposed persons (PEPs).

Record-Keeping

• Maintain records of all transactions exceeding INR 10 lakhs, including details of payment methods, counterparties, and agreements.
• Retain records for a minimum of five years from the date of transaction completion.

Reporting Obligations

• Report all suspicious transactions (STRs) to the Financial Intelligence Unit-India (FIU-IND) within the prescribed time frame.
• Submit Cash Transaction Reports (CTRs) for cash transactions exceeding INR 10 lakhs in a single day.

Internal Controls and Training

• Establish a robust internal control system to detect and prevent money laundering activities.
• Provide periodic AML training to employees, associates, and franchisees to ensure awareness of compliance requirements.

Monitoring and Auditing

• Regularly monitor all transactions to identify unusual patterns or suspicious activities.
• Conduct periodic audits to assess the effectiveness of the AML framework and address any gaps.

Prohibited Practices

• Accepting or facilitating transactions without adequate documentation.
• Engaging with clients or entities appearing on sanctioned lists or those with known links to illicit activities.
• Structuring transactions to evade reporting thresholds.

Consequences of Non-Compliance

Failure to adhere to the provisions of the PMLA, 2002, and this policy may result in:

• Reporting of the violation to regulatory authorities.
• Legal penalties, including fines and imprisonment as per the PMLA, 2002.
• Termination of employment or association with Bajaj Infraventures LLP.

Client Responsibilities

We encourage our clients to:

• Provide accurate and complete information during transactions.
• Promptly update any changes in their identification or business details.

Whistle-blower Mechanism

Employees and associates are encouraged to report any suspected instances of money laundering or violations of this policy. Reports will be treated confidentially, and individuals will be protected from retaliation.

Policy Review

This policy will be reviewed periodically to ensure its effectiveness and alignment with regulatory changes.

Contact Information

For any queries or concerns regarding this policy, please contact our Compliance Officer at –