The Company determines the identity of the beneficial ownership of all its clients’ accounts and does not open or maintain such accounts, unless it is satisfied with this requirement, as stipulated in the Prevention and Suppression of Money Laundering and Terrorist Financing Law and International AML Legislations. It has established procedures to obtain appropriate evidence of client identity and maintains adequate records of client identity and transactions involved in such a manner as to assist, if necessary, in the investigation of criminal offences.

The Company has in place policies and procedures to identify and avoid money laundering transactions and to ensure compliance with the requirements of any relevant legislation issued by its regulator.

The Company is vigilant in ensuring the prevention of its involvement or misuse in money laundering activities and is not knowingly accepting assets or entering into business relationships where there is reasonable cause to believe that such assets may have been acquired illegally or that they represent the proceeds of criminal activity.

The Company shall promptly report suspicious transactions relating to any account to the Supervisory Authority.

Where there is suspicion that the source of funds may be criminal or that a client may be involved in criminal activity, the Company shall follow established procedures for assessing the evidence and determining what course of action should be pursued.

The Company shall keep records of reports made by their staff and of reports made to the Supervisory Authority.

In accordance with the AML Act, the Company establishes the identity and verifies the identity of any customer of the Company by requiring the customer to produce an identification record or such other reliable, independent source document.