Kem Bahrain W.L.L.

(Crypto-Asset Licensee – Category 3)

1. Purpose

This policy establishes the human resources framework for Kem Bahrain W.L.L., ensuring compliance with the Central Bank of Bahrain (CBB) requirements, including the Fit and Proper Module, Training & Competency Module, and High-Level Controls. It sets standards for recruitment, training, conduct, and governance of all employees.

2. Scope

This policy applies to:

• The Board of Directors,
• Senior Management Functions (SMFs) requiring CBB approval, and
• All employees of Kem Bahrain W.L.L.

SMFs include the CEO, Head of Finance, Head of Operations, Head of Risk Management, Compliance Officer, and MLRO.

3. Recruitment & Appointment

• Fit and Proper Assessments will be performed prior to hiring, covering:
  • Integrity & Reputation – regulatory, criminal, and reference checks.
  • Financial Soundness – bankruptcy/credit history checks.
  • Competence – qualifications, industry knowledge, and relevant experience.
• CBB approval (Form 3) is required before appointing any SMF or Board Director.
• A Statement of Responsibilities (SoR) will be prepared for each SMF and signed within one month of appointment.
• Probation Period: All staff are subject to a six-month probation period, during which performance and conduct will be closely monitored.

4. Training & Competency

• All new staff will complete an induction programme covering CBB regulations, AML/CFT, cybersecurity, and internal policies.
• SMFs and senior staff must complete at least 15 hours of CPD annually.
• Compliance/ops will conduct an annual training needs assessment and prepare a structured training plan.
• Training records will be maintained for at least 5 years.