Gogoro Anti-Money Laundering Policy
Gogoro Policy. It is the policy of Gogoro Inc. (“Gogoro”) to prevent money laundering and terrorist financing. Money laundering generally means the process by which criminals attempt to hide or disguise the true origin or ownership of the proceeds of their criminal activities, thereby avoiding prosecution, conviction and confiscation of the criminal funds. It typically involves transactions to conceal or change the source of criminal proceeds so that the money, after such processing, appears to have originated from a legitimate source. Terrorist financing may involve the use of criminal proceeds, but it may also involve the use of clean money to facilitate terrorism.
Money laundering and terrorist financing are subject to severe civil and criminal penalties, including imprisonment for individuals, and reputational damage. To prevent money laundering and terrorist financing, Gogoro complies with all applicable anti-money laundering laws and regulations. Further, Gogoro intends to conduct business only with reputable customers involved in legitimate business activities using funds derived from legitimate sources. Gogoro employees should avoid engaging in any transaction that is structured in any way that could be viewed as concealing illegal conduct or the tainted nature of the proceeds or assets at issue in the transaction.
Gogoro designed this anti-money laundering policy (“Policy”) to provide the processes by which we will comply with all applicable AML rules, laws, and regulations and to communicate its clear commitment to promoting a strong culture of compliance.
Applicability. This Policy applies globally to all Gogoro officers, employees and contractors/consultants. At a minimum, all Gogoro employees must not be willfully blind to any money laundering risks that might arise in our business.
Reporting Cash Transactions. Receiving payments in large amounts of cash or cash equivalents (e.g., money orders, cashier’s checks, etc.) can be seen as “red flags.” As such, without the prior approval of the General Counsel or Head of Legal Function, Gogoro does not accept any payments in the form of cash or cash equivalents in excess of $10,000 in a single transaction or a series of related transactions that exceed $10,000. Should the General Counsel or Head of Legal Function approve receipt of such payment(s), Gogoro will report the payments to the Internal Revenue Service in accordance with Title 31, Code of Federal Regulation 1010.330 by filing IRS Form 8300. IRS Form 8300 can be found here: https://www.irs.gov/pub/irs-pdf/f8300.pdf.
For the purpose of this requirement, cash includes the coins and currency of the United States and a foreign country. Cash may also include cashier’s checks, bank drafts, traveler’s checks, and money orders with a face value of $10,000 or less.
Recordkeeping. Gogoro will keep books and records which: (1) have reasonable detail; and (2) accurately and fairly reflect transactions and the disposition of assets. All Gogoro funds must be properly accounted for and no side, off-the-books, or “slush funds” may be maintained by Gogoro or its directors, officers, or employees. All officers, directors, and employees (not just those with assigned financial duties) must assist Gogoro in ensuring that books and records are accurate, complete, and reasonably detailed.
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