Anti-Money Laundering Policy

1.1. General rule
MediCard prohibits and shall actively prevent money laundering and any activity that facilitates the laundering of proceeds of a crime. The same applies to any activity that involves financing of terrorism or other criminal offences. 

MediCard is committed to acting fairly and with integrity in all of its business dealings and relationships, and shall only conduct business with partners involved in legitimate business activities with funds derived from legitimate sources. MediCard shall take reasonable steps to prevent and detect any illegal form of payments, and prevent MediCard’s financial transactions from being used by others to launder money or finance illegal activity. 

Doing business within the insurance industry MediCard recognises this sector’s particular responsibility to participate in the prevention of money laundering and the financing of terrorism. 

This policy applies to the members of the Board of Directors of MediCard, its officers, managers, employees, whether regular or contractual, its agents and other representatives including its subsidiaries and affiliates.

1.2  Preventive approach
The preventive measures outlined in the MediCard Code of Conduct shall in particular be followed in regard to complying with the prohibition against money laundering and terrorism financing. As described in the Code of Conduct the preventive approach shall among other things consist of: 

• Training and communication 
• Risk assessments 
• Integrity due diligence 
• Record keeping 
• Whistle blowing encouragement 
• Monitoring 
• Follow up on non-compliance 

In this appendix regarding anti-money laundering policies, particular preventive measures with regard to money laundering and terrorism financing are described in further detail.

MediCard shall adopt measures towards striving compliance with all applicable anti-money laundering laws, including but not limited to (i) national anti-money laundering legislation of the Philippines and the jurisdictions where its counter parties are bound, (ii) anti-money laundering legislation where the work or services is performed, (iii) international anti-money laundering treaties such as the United Nations Convention against Anti-Money Laundering and the Suppression of the Financing of Terrorism (resolution 54/109), the FATF 40 Recommendations in the fight against money laundering and the FATF 9 Special Recommendations on terrorist financing, and the European Parliament and Council Directive on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (2005/60/EC) (referred collectively as “anti-money laundering laws”).

For the purpose of this policy “money laundering” means to convert proceeds from criminal activities into assets which appear to be derived from legitimate sources. This includes any activity that seeks to acquire, possess, use, convert, transfer, conceal or disguise the true nature, origin, location, disposal, movement or ownership of assets, in the knowledge that such assets are derived from criminal activity or from participation in criminal activity. 

Terrorism financing means the direct or indirect financing of terrorists, terror activity and terrorist organizations. Terrorism financing may involve proceeds from both illegitimate and legitimate sources. The definition includes the providing, depositing, distribution or collecting of funds, by any means, directly or indirectly, intended to be used, or knowing that they are to be wholly or partially used, for the committing of terrorist acts. 

Generally speaking, the money laundering process, very closely linked to the financing of terrorism, consists of three stages: 

I.        Placement
Introduction of cash originating from criminal activities into financial or non-financial institutions. 

II.       Concealment
Separating the proceeds of criminal activity from their source through the use of layers of complex financial or non-financial transactions. These layers are designed to hamper the control of the funds, disguise their origin and provide anonymity. 

III.       Integration
Placing the laundered proceeds back into the economy in such a way that they re-enter the financial system as apparently legitimate funds. Financial institutions may be used at any point in the money laundering or terrorism financing process.

4.1. Introduction
To prevent money laundering and terrorism financing it is core to know the true identity of the parties of the financial transactions. 

MediCard shall at all times ensure that the true identity of its customers and members are sufficiently ascertained. Prior to entering into a lasting business relationship or performing a single transaction or deal, MediCard shall know its customers by obtaining satisfactory evidence of their identity and having effective procedures to verify the authenticity of the information furnished by new customers. 

For the purpose of private individuals this means to e.g. obtain a copy of the person’s passport or driver’s license. For the purpose of legal entities this means to e.g. obtain the entity’s certificate of incorporation, confirmation of good standing, FSA registration, ticker transcript or similar documentation. 

MediCard shall establish and verify the identity of the ultimate beneficial owner who owns or controls more than 25% of the customer or its assets, or alternatively on whose behalf the transaction is carried out or the business relationship is established. 

MediCard shall maintain the Application Forms required to be filled in by customers/members and have it updated on a regular basis. 

4.2. Risk based approach
On the basis of the information obtained from its customers and the risk in the particular case, MediCard will consider whether further information is needed to verify the identity of the persons or entities in question. 

MediCard shall analyze any logical inconsistencies in the information it obtains about its customers. 

No payment shall be made to or on behalf of any customer, member or supplier, which are considered to be suspicious. 

4.3. Prohibited customers
For money-laundering and terrorism financing risk control purposes, MediCard will not accept the following categories of customers: 

• Persons included in any of the official lists of sanctions (“applicable lists”). 
• Persons about whom information is available indicating possible involvement in criminal activities. 
• Persons with businesses that make it impossible to verify the legitimacy of their activities or the source of funds. 
• Persons who refuse to provide the required information or documentation. 
• Legal entities whose shareholder or control structure cannot be determined. 
• Casinos or gambling/betting establishments that are not officially authorized. 
• Financial institutions resident in countries or territories without being physically present (also referred to as “shell banks”) and which do not belong to a regulated financial group. 
• Persons involved in production and distribution of weapons. 

So-called PEPs: Persons who are high-level public officials and their family members, and well known personalities wishing to open accounts or conduct transfers outside their native countries, and it is not clear that the relationship even though is considered low risk.

MediCard will regularly monitor its compliance with the anti-money laundering and terrorism financing policy. The organization will frequently perform audits of both the implementation of and the compliance to the policies.

Any commercial contract which MediCard enters into with third parties shall include provisions where the third party undertakes not to do or permit anything that might put MediCard in breach of relevant anti-money laundering laws, and also include termination and indemnity provisions which are triggered in the event of the counter party’s non-compliance with the said anti-money laundering undertakings.

MediCard will investigate suspicious transactions and report to the public authorities if it has reason to believe that the transaction involves money laundering or terrorism financing.