4. Roles and Responsibilities

Board of Directors

The Board of Directors of Importa Holdings Company LTD is ultimately responsible for the effectiveness of the AML/CFT compliance program. In accordance with applicable regulations across jurisdictions of operation and the Central Bank of Nigeria’s AML/CFT Regulations, 2022. The Board shall:

a. Provide active oversight and governance over the AML/CFT program and ensure that it is adequately resourced and implemented effectively across all business units.

b. Approve the Global AML policy and review it at least annually.

c. The Board and Chief Compliance Officer must ensure that Importapay’s controls reflect both Nigeria and other jurisdictions’ AML/CFT requirements, including obligations under the MLPPA 2022, TPPA 2022, and CBN AML/CFT Regulations 2022

d. Understand the institution’s risk profile and ensure that a risk-based approach is applied to AML compliance.

e. Support and empower the Chief Compliance Officer with sufficient authority, independence, and resources.

f. Review independent audits and regulatory findings, ensuring timely remediation of any deficiencies.

g. Promote a culture of compliance and ensure AML/CFT obligations are integrated into strategic decision-making.

The Board may delegate operational responsibility to management and the Compliance Officer but retains ultimate accountability for the institution’s compliance posture.

Chief Compliance Officer

The company’s Chief Compliance Officer (CCO) has the authority to develop, supervise, and enforce the program’s required policies, procedures, monitoring, and training. The CCO is authorized to make changes to the program’s policies and procedures, as necessary. The CCO is also responsible for providing regular updates and reporting to senior management and the Board of Directors on the status of the AML program, identified risks, regulatory developments, and any significant compliance issues.

General CCO responsibilities include the following:

a. To establish and maintain this policy;

b. Review and ratify any substantive changes to this policy annually;

c. Ensure adequate tools and resources are available and appropriately used to carry out the directives of this policy;

d. Be knowledgeable of AML/CTF laws;

e. Understand the company’s products, services, and customer demographics;

f. Understand and detect potential money laundering and terrorist financing risks; and

g. Ensure the program allows the company to support the Partner’s obligations under AML/CTF laws.

The CCO will have direct access to and will work with senior management to ensure the effective integration of products and services into the company's operations in compliance with applicable laws, regulations, and the program. The CCO will ensure that strategic goals do not conflict with the directives of this policy.

Any conflicts with the program’s policies, procedures, or training should be submitted immediately to the CCO.

Senior Management

Company officers are responsible for the comprehension and implementation of the program and ensuring employees’ understanding of their responsibilities. If at any time an employee is uncertain about the proper method of handling a situation or transaction, he or she should refer the issue to their immediate supervisor or contact the CCO for further clarification.

It is also the responsibility of senior management to ensure their respective departments are adhering to the requirements of the program