Anti-money Laundering Policy

It is the policy of R. Raphael & Sons Plc (trading as Raphaels Bank and hereinafter referred to as the "Bank") to undertake due care and diligence to ensure that it conducts its business only with reputable customers involved in lawful activities undertaken in good faith, and to create an effective Anti-Money Laundering (AML) regime throughout the Bank's activities.

The Bank rigorously adheres to all current money laundering and terrorist financing prevention laws and regulations (the "Regulations").

To ensure that the Bank implements and enforces the Regulations, the Bank maintains a comprehensive set of AML procedures and controls ("AML Procedures") that comply with and implement the requirements of the Regulations to enable the Bank's staff to detect any criminal activity or suspicious circumstances and so disrupt the process of money laundering and combat the financing of terrorism and comply with all directives and orders issued by HM Treasury regarding current financial sanctions regimes and freezing orders.

All customers and parties on whose behalf the Bank does business are subject to identification procedures (supported by original or certified documentation and any other searches or referrals that the Bank may deem to be appropriate) to establish that the customer is properly identified if an individual, and if a company or firm, that it is properly constituted, and that all the direct and ultimate shareholders or beneficiaries of the company or firm are identified as being fit and proper persons with whom to do business. Overall the AML regime requires that all the persons involved in a transaction, and the transaction itself, is lawful and undertaken in good faith.

The Bank has appointed a Money Laundering Reporting Officer (MLRO) and deputies to provide the focus of all AML activities within the Bank. Staff are required to record and promptly report all suspicious activities to the appointed MLRO with a view to the MLRO making a formal Suspicious Activity Report ("SAR") to the Serious Organised Crime Agency ("SOCA").

The Bank's staff are regularly trained to ensure that they are committed to the AML regime adopted by the Bank and that the AML Procedures and the Regulations will be strictly upheld.

The Bank regularly monitors and reviews its AML Procedures to ensure efficient implementation, and strict compliance.

The Bank's AML Procedures and controls are updated from time to time to comply with any changes to the Regulations and to ensure that best market practice is adopted.

The Bank is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

April 2013