Voce Systems – Know Your Customer (KYC) Policy

1. Introduction

   At Voce, we are committed to providing high-quality telecommunications services to our valued Business to Business (B2B) customers. To ensure the integrity of our business relationships and to help prevent fraud and abuse, we have established this Know Your Customer (KYC) policy. The purpose of this policy is to guide our procedures for identifying, verifying, and understanding our B2B customers.

2. Scope

   This KYC policy applies to all employees, agents, and contractors of Voce who engage with B2B customers. It also encompasses any third-party partners or intermediaries who assist us in our customer onboarding process.

3. Customer Due Diligence (CDD)

      a. Identification of Customers: Before entering into a business relationship with any B2B customer, we will gather and verify the following information:

• Full legal name of the business
• Legal structure (e.g., corporation, partnership)
• Registered business address
• Contact information (phone, email, and point of contact)

   b. Ownership and Control: We will determine the beneficial ownership and control structure of the business, including identifying the ultimate beneficial owners and senior management.

   c. Purpose of the Relationship: We will understand the nature and purpose of the business relationship, including the anticipated volume of telecommunications services required.

4. Risk Assessment

   a. Customer Risk Profiling: We will assess the risk associated with each B2B customer based on factors such as industry, location, size, and historical data. This will help us prioritize due diligence efforts.

   b. Enhanced Due Diligence (EDD): In cases where higher risks are identified, we may conduct enhanced due diligence, which may include additional verification steps.

5. Customer Monitoring

   a. Ongoing Monitoring: We will periodically review and update customer information.

   b. Transaction Monitoring: We will monitor the telecommunications services provided to ensure they align with the customer’s stated business purpose.

6. Data Protection and Privacy

   We will handle customer information in compliance with all applicable data protection and privacy laws. Customer information will be securely stored and accessed only by authorized personnel.

8. Training and Awareness

   All employees and relevant third parties will receive training on this KYC policy to ensure compliance.

9. Review and Updates

   This KYC policy will be reviewed regularly to ensure it remains effective and up-to-date.

10. Conclusion

   By adhering to this KYC policy, we aim to establish and maintain strong and trustworthy relationships with our B2B customers, prevent fraud and abuse, and ensure compliance with all legal and regulatory requirements.