AML Policy

AML POLICY

Last updated: 01/11/2023

I. This AML Policy is meant to provide the information that Lavagames B.V., a limited liability company registered in Curacao with company registration number 164444 with registered address Julianaplein 36, Curaçao (“Company”), licensed in Curaçao under the Licence 1668 JAZ issued by Curaçao eGaming for the provision of online games of chance strictly complies with all applicable laws and regulations of anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) policies. Thereby the Company carries out group of actions aimed at revealing criminally obtained funds and their legalization countermeasures in correspondence with the international requirements. The present AML Policy is renewed every three months.

II. The infrastructure for anti-money laundering and combating the financing of terrorism (AML/CFT) on Curaçao finds its legal basis in the National Ordinance on identification when rendering services (LID) and the National Ordinance on the reporting of unusual transactions (LMOT). These ordinances determine that all service providers offering the opportunity to participate in games of hazard in general, casinos, lotteries, and offshore games of hazard fall within the regulatory scope. On February 15, 2019, the Curaçao Gaming Control Board (GCB) was officially appointed AML/CFT supervisor for all gambling in and from Curaçao.

III. The Company may use one of the following searching tools in order to identify the client/partners and fulfill the PEP, Blacklists and Sanctions controls: SEON, Onfido, Trulioo, Refinitiv, Token of Trust, ComplyAdvantage etc.

1. IDENTIFICATION AND VERIFICATION OF CLIENTS

1.1. According to AML and Know Your Client (“KYC”) policies, the Company identifies the Client / Counterparty and verifies their true identity on the basis of documents and data both at the moment of starting a business relationship with the Client / Counterparty and on ongoing basis.

1.2. The Client (or the Counterparty) provides by email the identification information to the Company including its full name, date of birth, country of residence, mobile number and email (for individuals) and corporate details with precise information on the beneficiaries (for the legal entities).

1.3. After receiving the identification information, the Company should verify the information requesting the appropriate documents.

1.3.1. The appropriate document verifying the Client’s / Counterparty’s identity is a high-resolution scanned copy or a photo of a passport or a driving license or any other national ID (for the individuals) and corporate set not older than three months with full set of identification documents for the beneficiaries (for the legal entities).

1.3.2. The appropriate document verifying proof of address is a high-resolution copy or a photo of a utility bill or a bank reference issued within the last 3 months.

1.4. At the Company’s request the Client is required to provide a scanned copy or a photo of front and back side of the credit/debit card. The front side should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number. The back side should show the cardholder’s signature, CVC2/CVV2 code must be covered.

1.5. The Company shall monitor the Client’s / Counterparty’s due diligence and accounts on the regular basis in order to determine the level of risk they pose and to reveal whatever changes in information about the Client / Counterparty.

1.6. If the Company believes the business relationship with the Client / Counterparty to pose a potentially high risk of money laundering or terrorism financing, the Company is entitled to ask for whatever additional data and documents that may be deemed necessary in the situation.

1.7. The Client / Counterparty is obliged to inform immediately of any changes in the personal or contact information.

2. KYC PROCEDURE

In order to open an account to use the Website services, you should provide your e-mail address, choose a password and fill in the information required to complete the registration by providing us the personal information, including your name, date of birth and phone number.

We follow the rules of KYC procedures (“Know Your Customer”). Your name on Your Account shall match your true and legal name and identity. To verify your identity, the Company reserves the right to request at any time satisfactory proof of identity (including but not limited to copies of a valid passport / identity card and/or any payment cards used). If you fail to supply the information and documents requested, we shall be entitled to suspend the activity of your account until the provision of the information requested and/or close your account. The Company reserves the right to review the documents within 30 (thirty) calendar days.

You hereby certify and agree that you have provided accurate, complete and true information about yourself upon registration and you shall maintain the accuracy of that information by promptly updating it if there are any changes. Failure to do so may result in account closure, account limitations or voiding transactions (bonus, winnings).

You shall only open a single account at the Website. In all cases, only one account per customer, per address, per shared computer and per shared IP address shall be allowed. Any other account you open on the Website shall be considered as the duplicate account. You shall inform the Company that you wish to create a duplicate account due to the original account access loss or any other important reason and receive a permission from the Company before the creation of the duplicate account. In any other cases all duplicate accounts may be immediately closed by the Company and:

- all transactions made from the duplicate account shall be considered null and void;

- any returns, winnings or bonuses which you have gained or accrued within the use of the duplicate account shall be forfeited from you and a return may be claimed by us. Any funds withdrawn from the duplicate account shall be returned to us on demand;

- the Company shall not compensate any funds from both bonus and real money balances of the duplicate account. The Company reserves the right, at its sole discretion, to claim the return of any lost funds that were used for bets effected via the duplicate account;

- the Company shall not accept any requests on fund returns which have been lost or initially deposited on the duplicate account provided that the duplicate account was created with intention to receive bonuses and other promo offers from the Company, as well as if a number of duplicate accounts was created with a purpose of receiving a return of the first deposits made on previously created duplicate accounts, which is considered to be an abuse. If the Company at its sole discretion assumes that the duplicate accounts were created only with a purpose of fraud and/or abuse of hereunder, then the funds deposited on this duplicate account shall not be returned to the player.

The Company confirms that anonymous bank accounts are prohibited by EU AML/CFT rules and the Company observes such prohibition and does not accept the anonymous accounts.

3. PAYMENT POLICY

3.1. In order to minimize the risk of money laundering and terrorism financing the Company neither accepts nor pays off cash money under no circumstances.

3.2. The Company reserves the right to refuse processing a transaction at its any stage, if the Company believes the transaction to be connected in any way with money laundering or criminal activity.

3.3. According to international legislation, the Company is prohibited from informing the Client that they have been reported for suspicious account activity.

3.4. The name of a person making a deposit of funds should be the same as the Client’s name in the Company’s records. Payments from third parties are not accepted.

3.5. The Company requires strict adherence to established deposit/withdrawal procedure. Funds can be withdrawn to the same account and using the same method as when depositing. When withdrawing, a name of a payee should be the same as the Client’s name in the Company’s records. If the deposit has been made via wire transfer, the funds should be withdrawn via the same transfer to the same bank and to the same bank account as when depositing. If the deposit has been made by means of a payment system, the funds can be withdrawn via online transfer to the same payment system and to the same account as when depositing.

3.6. The compliance with the AML policy requires withdrawal of funds to be made in the same currency as when depositing.

3.7. The Company maintains transaction records for a minimum of 5 years after termination of the business relationship with the Client.

4. PERSONNEL TRAINING

4.1. The Company appoints an AML Compliance Officer who is fully responsible for the Company’s compliance with CFT and AML policies, establishing and maintaining the Company’s AML program, AML training employees, receiving, investigating and maintaining internal suspicious activity reports.

4.2. All the employees, managers and directors of the Company are suitably trained while entering into employment.

4.3. Employees who are dealing with clients or are involved in any AML checking, verification or monitoring undergo AML training. Each new employee has to follow an AML training plan. The AML training program includes suspicious transactions identification training as well as training in prevention, detection and reporting of money laundering and terrorism financing crimes.

4.4. Any violation of the AML policy must be reported to the AML compliance officer, unless the violation implicates the AML Compliance Officer, in which case an employee must report the violation to the CEO.

5. HIGH-RISK JURISDICTIOS

The Company considers the following countries to be the high-risk countries: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, Democratic People's Republic of Korea (DPRK), Haiti, Iran, Jamaica, Jordan, Mali, Malta, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, Uganda, United Arab Emirates, Yemen. The Company performs additional checks, controls on cooperation with these countries. On 7 January 2022, the European Commission adopted a new Delegated Regulation in relation to third countries which have strategic deficiencies in their AML/CFT regimes.

6. RISK ASSESSMENT

A money laundering and terrorist financing risk assessment attempts to identify, analyse and understand money laundering and terrorist financing risks. It serves as the first step in addressing the risks and, ideally, involves making judgments about threats, vulnerabilities and consequences. The Company shall identify the threats (persons, or groups of people, objects or activities with the potential to cause harm, including criminals, terrorist groups and their facilitators, their funds, as well as past, present and future money laundering or terrorist financing activities), vulnerabilities (things that can be exploited by the threat or that may support or facilitate its activities and means focusing on the factors that represent weaknesses in AML or CTF systems or controls or certain features of a country, particular sector, financial product or type of service that make them attractive for money laundering and terrorist financing), consequences (this refers to the impact or harm that money laundering or terrorist financing may cause, including the effect of the underlying criminal and terrorist activity on financial systems and institutions, the economy and society more generally. The Company adopts an approach that attempts to distinguish the extent of different risks to assist with prioritizing mitigation efforts, rather than being a generic box-ticking exercise. That is why the Company performs the identification (the identification process begins by developing an initial list of potential risks or risk factors when combating money laundering and terrorist financing. Risk factors are the specific threats or vulnerabilities that are the causes, sources or drivers of money laundering and terrorist financing risks), analysis (analysis involves consideration of the nature, sources, likelihood, impact and consequences of the identified risks or risk factors. The aim of this stage is to gain a comprehensive understanding of each of the risks, as a combination of threat, vulnerability and consequence, in order to assign a relative value or importance to each of them. Risk analysis can be undertaken with varying degrees of detail, depending on the type of risk, the purpose of the risk assessment, and the information, data and resources available), evaluation (the evaluation stage involves assessing the risks analysed during the previous stage to determine priorities for addressing them, taking into account the purpose established at the beginning of the assessment process. These priorities can then contribute to development of a strategy for the mitigation of the risks). The Company pays special attention to country and geographic risk (some countries pose an inherently higher money laundering and terrorist financing risk than others. In addition to considering their own experiences, casino operators should take into account a variety of other credible sources of information identifying countries with risk factors in order to determine that a country and customers from that country pose a higher risk. Customers that are associated with higher risk countries, as a result of their citizenship, country of business or country of residence may present a higher money laundering and terrorist financing risk, taking into account all other relevant factors. We check customer location because of the additional risks which arise from cross-border operations. The country or geographic risk can also be considered in conjunction with the customer risk). We also assess customer risk (determining the potential money laundering and terrorist financing risks posed by a customer, or category of customers, is critical to the development and implementation of an overall risk-based framework. We seek to determine whether a particular customer poses a higher risk and the potential impact of any mitigating factors on that assessment. Application of risk variables may mitigate or exacerbate the risk assessment. Categories of customers whose activities may indicate a higher risk include: customers who are PEPs, family members of PEPs or known close associates of PEPs, high spenders – the level of spending which will be considered to be high for an individual customer will vary among casino operators, and among casinos managed by the same operator, disproportionate spenders – we obtain information about customers’ financial resources so that they can determine whether customers’ spending is proportionate to their income or wealth, casual customers – this includes tourists, participants in junkets and local customers who are infrequent visitors, regular customers with changing or unusual spending patterns, improper use of third parties – criminals may use third parties or agents to avoid CDD undertaken at the threshold or to buy chips, or they may be used to gamble so as to break up large amounts of cash, junkets – junkets can pose several higher risks, including criminal control of the junket operator or participants, the movement of funds across borders which obscures the source and ownership of the money gambled by participants and their identities, and structuring, refining and currency exchange risks, multiple player accounts – some customers will open multiple player accounts under different names to hide their spending levels or to avoid breaching the CDD threshold, unknown or anonymous customers – these customers may purchase large amounts of chips with cash at casino tables, and then redeem the chips for large denomination notes after minimal or no play). Transaction risk is a very important risk factor assessed by the Company as well as a product risk. Many customers carry a lower money laundering or terrorist financing risk. These might include customers who are regularly employed or who have a regular source of income from a known source which supports the activity being undertaken. This applies equally to pensioners, benefit recipients, or to those whose income originates from their partner’s employment or income. Conversely, many customers carry a higher risk of money laundering. These may include known criminals, customers who are not regularly employed or who do not have a regular source of income from a known source which supports the level of activity being undertaken, or problem gamblers.

7. ONGOING CUSTOMER DUE DILIGENCE AND TRANSACTION MONITORING

The Company applies enhanced customer due diligence measures and enhanced ongoing monitoring, in addition to the required CDD measures, to manage and mitigate the money laundering or terrorist financing risks arising in the following cases:

- in any case identified by the Company or in information provided to the Company as one where there is a high risk of money laundering or terrorist financing;

- in any business relationship with a customer situated in a high-risk third country;

- if the Company has determined that a customer or potential customer is a PEP, or a family member or known close associate of a PEP;

- in any case where the Company discovers that a customer has provided false or stolen identification documentation or information and the operator proposes to continue to deal with the customer;

- in any case where a transaction is complex or unusually large, or there is an unusual pattern of transactions, or the transaction or transactions have no apparent economic or legal purpose;

- in any other case which, by its nature, can present a higher risk of money laundering or terrorist financing;

In the case of business relationships with customers situated in high-risk third countries or transactions where either of the parties to the transaction are resident in a high-risk third country, the enhanced measures undertaken shall include: obtaining additional information on the customer and on the customer’s beneficial owner, obtaining additional information on the intended nature of the business relationship, obtaining information on the source of funds and source of wealth of the customer and of the customer’s beneficial owner, obtaining information on the reasons for the transactions, obtaining approval of senior management for establishing or continuing the business relationship, conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination.

In the case of transactions that are complex or unusually large, or where there is an unusual pattern of transactions, or the transaction or transactions have no apparent economic or legal purpose, the enhanced measures undertaken shall include: as far as reasonably possible, examining the background and purpose of the transaction, increasing the degree and nature of monitoring of the business relationship in which the transaction is made, to determine whether the transaction or relationship appear to be suspicious.

Depending on the requirements of the case, the enhanced measures undertaken in any case listed in enhanced customer due diligence and enhanced ongoing monitoring may also include, among other things: seeking additional independent, reliable sources to verify information provided or made available to the casino operator, taking additional measures to understand better the background, ownership and financial situation of the customer, and other parties to the transaction, taking further steps to be satisfied that the transaction is consistent with the purpose and intended nature of the business relationship, increasing the monitoring of the business relationship, including greater scrutiny of the transactions.

When assessing whether there is a high risk of money laundering or terrorist financing in a particular situation, and the extent of the measures which should be taken to manage and mitigate the risk.

The Company takes account of the following risk factors, among other things whether: the business relationship is conducted in unusual circumstances, the customer is resident in a geographical area of high risk, the customer is the beneficiary of a life insurance policy, the customer is a third country national who is applying for residence rights in or citizenship of an EEA state in exchange for transfers of capital, purchase of a property, government bonds or investment in corporate entities in that EEA state, the product or transaction might favour anonymity, the situation involves non-face-to-face business relationships or transactions without certain safeguards such as an electronic identification process which meets the verification requirements, payments will be received from unknown or unassociated third parties of the customer, new products and new business practices are involved, including new delivery mechanisms, and the use of new or developing technologies (such as virtual currencies) for both existing and new products.

In addition whether the business relationship or transaction involves countries: identified by credible sources, such as mutual evaluations, detailed assessment reports or published follow-up reports, as not having effective systems to counter money laundering or terrorist financing, identified by credible sources as having significant levels of corruption or other criminal activity, such as money laundering, terrorism, and the production and supply of illicit drugs, subject to sanctions, embargoes or similar measures issued by, for example, the European Union or the United Nations, providing funding or support for terrorism that have organisations operating within their territory which have been designated, by the government of the UK, as proscribed organisations under the Terrorism Act (opens in a new tab) or, by other countries, international organisations or the European Union as terrorist organisations, identified by credible sources (such as evaluations, detailed assessment reports or follow-up reports published by FATF, the International Monetary Fund, the World Bank, the organisation for Economic Cooperation and Development or other international bodies or non-governmental organisations) as not implementing requirements to counter money laundering and terrorist financing that are consistent with the FATF recommendations.

8. CUSTOMER RISK CLASSIFICATION. RISK SCORING SYSTEM

There are four risk levels, and these are:

- Low: Customers whose identity is easily identified.

- Medium: Customers who pose a higher risk than an average customer.

- High: Customers whose financial activities are monitored with Customer Due Diligence.

- Prohibited: Customers who are banned from financial activities due to their involvement in financial crimes.

Risk scoring is part of the KYC pillar of an AML framework of the Company. Risk scoring is a step in the due diligence process that entails looking at a customer's background and behavior to determine their score.

The risk score is calculated using the following factors:

- Customer vetting: it helps the Company to ensure that each customer's commercial transaction is legal within their jurisdiction.

- Demographic check: checking variables such as nationality, occupation, date of birth, length of stay with the Company, residence and mailing addresses, credit score, etc.

- Transactions: the Company examines its customers' sources of income and determine whether they make sense in terms of their occupation or location. This involves determining whether transactions are appropriate in light of the customer's risk profile.

- Operational trends: the Company reviews any fraud notices, suspicious activity reports (SARs), suspicious transaction reports (STRs), or other red flags relating to a customer's behavior.

9. EDD PROCEDURE

The Company follows the following EDD rules’ recommendations:

- The Company scrutinizes customers’ risk profile;

- The Company obtains additional information where necessary;

- The Company conducts extensive background checks and monitors transactions;

- The Company organizes and secures its data in line with compliance standards;

- The Company keeps the data available for regulators.

The Company obtains additional identifying information from a wider variety or more robust sources and using the information to inform the individual customer risk assessment:

- Carrying out additional searches (for example, verifiable adverse media searches) to inform the individual customer risk assessment;

- Commissioning an intelligence report on the customer or beneficial owner to understand better the risk that the customer or beneficial owner may be involved in criminal activity;

- Verifying the source of funds or wealth involved in the business relationship to be satisfied that they do not constitute the proceeds from crime;

- Seeking additional information from the customer about the purpose and intended nature of the business relationship.

10. SANCTIONS SCREENING

The Company has implemented due diligence and sanctions screening procedures. The Company shall screen and identify persons and transactions subject to and/or prohibited by the following: US OFAC SDN List; UK HMT Consolidated List of Persons and Ukraine List of Persons; UN restrictive measures; and the EU Consolidated List. The Company utilizes Thomas Reuters World-Check (World-Check) and Refinitiv to conduct sanctions screening, which allows the Company to screen all relevant sanctions lists using a single search function. The following internal documents should be cross-referenced to effectively carry out sanctions screening: 1) Screening Request Form; 2) Partnership Appraisal Form; 3) Screening Procedures Matrix; 4) Due Diligence and Partnership Appraisal Map; and 5) Thomson Reuters World-Check User Guide.

10.1 Due Diligence and Partnership Appraisal Screening Process

The first phase of sanctions screening requires fact gathering due diligence and partnership appraisal process. This requires completion of Screening Request Form and/or Partnership Appraisal Form (depending on the type of transaction). Staff should cross-reference the Screening Procedures Matrix to determine which form(s) require completion. In accordance with the Due Diligence and Partnership Appraisal Map, Programmes/POC carries out the fact gathering process in conjunction with new and potential partners. These forms are intended to capture information necessary to conduct effective screening utilizing World-Check. Essential information to be captured includes names and aliases, addresses, date of birth (individuals), and ownership structure and identification (trustees, directors, decision-makers, and shareholders). Pertinent data fields are noted in the Screening Request Form and Partnership Appraisal Form, respectively. Once the fact gathering process is complete, the information is forwarded to internal audit staff (Finance). Internal audit staff screens persons and organisations utilizing World-Check.

10.2. Risk Rating

The next phase of sanctions screening requires the Company to assign a risk rating. A risk rating is assigned by internal audit staff and is documented on the Screening Request Form and/or Partnership Appraisal Form. A risk rating will be assigned to any person or organisation subject to sanctions screening procedures. Persons and entities subject to sanctions in the US, UK, UN or EU are automatically assigned a high-risk rating. Persons and entities identified as Politically Exposed Persons (PEPs) on World-Check will automatically be rated as medium or high-risk depending on the level of exposure. High-risk is defined as a transaction that poses or allows for a significant reputational risk to the organisation. It is Company’s policy not to engage with any person, entity or financial institution deemed high-risk. Medium-risk is defined as transaction that poses or allows for a greater than average reputations risk to the organisation. This may include persons and entities identified as PEPs. Company’s general policy is to not engage with parties deemed medium-risk unless a dispensation is received from the Director. Parties deemed medium-risk are subject to rescreening annually. Low-risk is defined as a transaction that poses or allows for an average reputational risk to the organisation. This may include persons or entities with exposure to PEPs but may still be deemed acceptable to work with once all due diligence steps have been carried out. Parties deemed low-risk are subject to rescreening every two years. No-risk is defined as a transaction that does not pose any reputational risk to the organisation. Parties with no identified risks are subject to rescreening every five years.

10.3. Decision Making and Escalation

The final phase of sanctions screening requires the Company to decide whether to move forward with an engagement, contract, or transaction. The decision is documented on the Screening Request Form and/or Partnership Appraisal Form and retained in the person or organisation’s file.

All transactions where a sanctions risk is deemed present (low, medium or high) are automatically forwarded to the Director for review and potential investigation. The Director and compliance specialist will review the transaction before the party and/or services can be approved. After performing necessary due diligence, and where it is determined that a person, partner, or transaction implicates a potential sanctions risk, the Director must compile a complete packet of all relevant documents and information, and note the decision made whether to proceed.

The Director and compliance officer are the authorities on sanctions compliance for the Company.

The Company reviews the sanctions list stipulated herein above every day.

The Company shall inform in accordance with the applicable rules and regulations on the suspected criminal activities and on any information on the transactions with the persons/organizations in the one of the sanction lists discovered during the stipulated procedures.

11. MONITORING RED FLAGS ON THE SUSPICIOUS ACTIVITY

When risk assessing a client, there are some red flag behaviours that would cause further research by the Company within the AML procedure. The Company fully relies on the ML/TF indicators developed by the Financial Action Task Force (FATF). These ML/TF indicators do not cover every possible situation but were developed to provide with a general understanding of what is or could be unusual or suspicious. On its own, a single ML/TF indicator may not appear suspicious. However, observing an ML/TF indicator could lead a Company to conduct an assessment of the transaction(s) to determine whether there are further facts, contextual elements or additional ML/TF indicators that assist in establishing reasonable grounds to suspect the commission or attempted commission of an ML/TF offence, which requires the submission of an STR.

If the Company detects unusual or suspicious behavior or a transaction that prompts the need for an assessment, ML/TF indicators combined with facts and context will help the Company to determine if there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence. These ML/TF indicators may also be used to explain or articulate the rationale for the Company reasonable grounds to suspect in the narrative portion of an STR, as they provide valuable information from a financial intelligence perspective.

12. INTERNAL SUSPICIOUS ACTIVITY REPORT

A suspicious activity report (SAR) is an essential tool in the fight against financial crimes such as money laundering. The Financial Action Task Force (FATF), a global AML watchdog, recommends that all financial institutions implement a suspicious activity detection and reporting system. The Company implemented the internal system of sending the SAR.

The compliance officer of the Company shall begin the SAR reporting requirement. If the compliance officer or any officer of the financial department notices a suspicious transaction, such as a large, anonymous off-shore money transfer into a usually “quiet” account, he/they would report that activity to the Director. Then the Director of the Company would decide if a suspicious activity report was necessary.

The process for filing a SAR is completely digital.

The SAR should contain the names, addresses, social security numbers, birth dates, driver’s license numbers and other contact and personal information about the potential perpetrators. The SAR forms ask for in-depth information on the incident or incidents as well as a written description of the financial activity. There should be identified the type of suspicious activity and provided any other supporting documentation.

13. ANTI-BRIBERY AND CORRUPTION

The Company confirms that offering, promising and authorising the giving of money, or anything else of value, to a government official in order to secure an improper advantage is strictly prohibited. No employee may offer, give, promise or receive money, or anything else of value, to or from an individual or entity in the private sector in order to obtain an improper advantage. Even the mere act of offering is prohibited, regardless of whether or not the item of value is actually accepted by the intended recipient. The prohibition covers cash payments, benefits and favours. In certain circumstances, it also covers otherwise legitimate business expenditures such as gifts, entertainment, travel, donations, sponsorships or training.

The above-mentioned payments are prohibited regardless of whether or not they are made directly or indirectly through third party intermediaries. Reasonable steps must be taken to verify that any contribution does not constitute an illegal payment to a government body or official or any individual in violation of this policy.

The Company must never enter into any relationship with a third-party intermediary who will have substantive interaction with government officials on behalf of the Company without first inquiring into the third party’s background, qualifications and reputation.

The most important steps the Company can take to protect itself from liability for improper payments made by a third party are to carefully choose its business partners, including agents and consultants, and to be aware of “red flags”, to fulfill all the necessary KYC checks and procedures as per the present AML Policy.

The Company does not allow the use of facilitating payments. Such payments may be considered a customary way of doing business in some countries, but it is important to understand that the anti-bribery laws of many countries prohibit such payments.

14. INTRODUCING CHANGES TO THE AML POLICY

The Company reserves the right to review and/or amend the AML Policy, at its sole discretion. All the Clients / Counterparties are automatically introduced to the new policies, if any changes are made. The AML Policy is reviewed every three months. The present AML Policy is drafted and approved by the AML specialist and finally approved and signed by the Director of the Company.