CLIENT ONBOARDING POLICY & KYC STATEMENT

Gorilla Unit Consulting Pty Ltd (“GUC”) is committed to a principled and integrity-focused approach to client engagement. As part of our internal risk management framework, we implement a comprehensive client onboarding policy that includes Know Your Client (KYC) procedures, even though we do not operate as a regulated financial institution.

1. Purpose and Scope
This policy applies to all individuals and entities seeking to engage GUC for consultancy services. It is designed to:
– Mitigate reputational, legal, and operational risks;
– Ensure GUC’s alignment with international anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions compliance principles;
– Uphold a secure and transparent operating environment for all parties involved.

2. Verification Requirements
Prior to formal engagement, GUC may request documentation and information including, but not limited to:
– Government-issued identification for individuals;
– Corporate registration, beneficial ownership structure, and authorised signatories for entities;
– Nature and purpose of the proposed engagement;
– Source and intended use of any funds associated with the matter (where relevant).

Engagement is conditional upon the satisfactory review of submitted information. GUC reserves the absolute right to decline engagement without explanation.

3. Regulatory Alignment
Although GUC is not subject to financial services regulation, our internal compliance model incorporates international best practices aligned with:
– The Financial Action Task Force (FATF) Recommendations;
– The Australian AML/CTF Act 2006, where applicable;
– Relevant due diligence obligations under GDPR, APPs, and international privacy laws.

4. Confidentiality and Data Protection
All information collected during onboarding is treated as strictly confidential and managed in accordance with our Privacy Policy. Data is stored securely, accessed only by authorised personnel, and retained only for as long as necessary to fulfil our due diligence obligations or legal requirements.

5. Ongoing Monitoring and Risk Review
GUC reserves the right to conduct ongoing monitoring of its client relationships. Any material change in a client’s structure, operations, jurisdictional exposure, or reputation may trigger a renewed due diligence review. Engagements may be suspended or terminated if compliance thresholds are no longer met.