Anti-Money Laundering and Combating the Financing of Terrorism
and Weapons of Mass Destruction Policy

1. Purpose

         To be a framework for operational governance, enabling executives and employees to act in compliance with the Anti-Money Laundering Act and the Act on the Prevention and Combat of Financing of Terrorism and the Proliferation of Weapons of Mass Destruction.

2. Scope

         Personnel of Bangkok Life Assurance Public Company Limited and its subsidiaries (“the Company”) must study, understand, and strictly abide by this policy.

3. Effective Date

         This policy shall be effective from the date of approval by the Board of Directors.

4. Review Frequency and Revision

         This policy must be reviewed annually, or when a significant change arises.

5. Responsible Function

         The Compliance Office is the responsible function of this policy.

6. Definition

     “The Company” means Bangkok Life Assurance Public Company Limited.

     “Subsidiary” means companies in which the Company holds shares directly or indirectly over 50% of voting shares.

     “Personnel of the Company” ” means directors, executives, employees, and staff at all levels of Bangkok Life Assurance Public Company Limited and its subsidiaries.

     “Customer” means an individual, an entity, or a person with legal agreement who builds business relationship or makes transactions with the Company, such as life insurance customers, loan customers, and mutual fund customers.

     “Money Laundering” means conversion of money or assets derived from illicit activities or illegal means to legally-obtained money or assets, or conversion of illegally-obtained money or assets to make them appear as though they are legitimately earned.

     “Transaction” means engagement into a juristic act, contract, or any interaction with another person, involving financial, commercial, or asset-related matters.

     “Terrorist Act” means an act which constitutes an offense related to terrorism under the Penal Code, or an act which constitutes an offense within the scope of international conventions and treaties related to terrorism to which Thailand is a party or acceded, regardless of whether such act is committed within or outside the Kingdom.

     “Designated Person” means a person, group, legal persons, or entity included, by a resolution or notification of the United Nations Security Council, on the list of people committing an act of terrorism or proliferation of weapon of mass destruction, which has been announced by the Office. It also includes a person, group, legal person, or entity who, by the Court’s consideration and order, is identified as a designated person under Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing Act B.E. 2559 (2016).

7. General Principle

         The Company recognizes the importance of preventing money laundering, terrorism financing, and the proliferation of weapons of mass destruction, and is committed to preventing itself from becoming a tool or channel for money laundering or the financing of terrorism and the proliferation of weapons of mass destruction. Therefore, the Board of Directors has established this “Anti-Money Laundering, and Financing of Terrorism and Proliferation of Weapons of Mass Destruction Policy”.

8. Requirement

8.1 Risk Management for Money Laundering, and Financing of Terrorism and Proliferation of Weapons of Mass Destruction

     The Company establishes measures to evaluate and manage the risks associated with money laundering, and financing of terrorism and proliferation of weapons of mass destruction in accordance with the laws and international standards, including Organizational Risk Management, Customer Risk Management, and Partner Risk Management.

8.2 Accepting Customers

     The Company establishes processes for approving or rejecting the establishment of business relationships or transactions customers, including customer identification, Know Your Customer (KYC) assessment, and verification of customer information, ultimate beneficial owners, and those related to the customer, as per the criteria specified by laws.

8.3 Internal Control Measures

     The Company establishes internal control measures appropriate to the organization's risks, encompassing governance structures, employee selection, pre-employment and ongoing employee training, and independent internal audit mechanisms.

8.4 Reporting Transactions to the AMLO

     The Company establishes criteria for reporting transactions in accordance with the anti-money laundering law and related ministerial regulations.

8.5 Maintenance of KYC Information, Customer Verification, and Transaction Reporting Information

     The Company establishes methods for storing customer data and documents related to customer identification, transactions, and due diligence; and reports transactions through secure and reliable methods, ensuring they are available for audit and legal reference.

8.6 Processes to Ensure Compliance with Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation of Weapons of Mass Destruction Laws

     The Company has measures in place to verify customer information, occasional transactions, contractual partners, and other individuals associated with customers in transactions with the Company against a database of designated persons before approving the establishment of business relationships or transactions. This is to prevent the Company from being used by designated persons as a conduit for financial support of terrorism and the proliferation of weapons of mass destruction.
     The Company refuses or terminates any business relationship or transaction if it finds that a customer, occasional transacting party, individual associated with a customer in a transaction with the Company, contracting party, or trading partner is a designated person, and will deal with such person in accordance with the criteria prescribed by law.
     The Company does not engage in any financial or asset-related activities related to terrorism or the proliferation of weapons of mass destruction, whether through direct or indirect support, including any actions involving designated persons or persons associated with terrorism or the proliferation of weapons of mass destruction.

9. Penalty

         Violation of this policy is considered violation of the Company’s Code of Conduct for All Personnel, and those who violate the law may be held liable under the Anti-Money Laundering Act and the Act on the Prevention and Combat of Financing of Terrorism and the Proliferation of Weapons of Mass Destruction.