Shan Poornam Sdn Bhd and its group of companies (collectively, the Group, we, us or our)
conducts due diligence on a risk-based approach i.e. it is to be tailored to the facts and
circumstances surrounding the activity or person. In addition to the risk posed by the Group’s
participation in the activity or relationship with the person, the nature, type and extent of due
diligence undertaken will depend on the Group’s ability to obtain sufficient information and
the cost of obtaining such information.