ANTI-MONEY LAUNDERING POLICY AND PROCEDURES

These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by “TEK Group LTD” registered at Suite 305, Griffith Corporate Centre, P.O.Box 1510, Beachmont Kingstown, Saint Vincent and the Grenadines (The Company) in compliance with:

Domestic law of St. Vincent and the Grenadines’ The Proceeds of Crime Act, No. 38 of 2015; The Financial intelligence Unit Act, Cap 174 of the Revised Laws of 2009, as amended by Act No. 7 of 2013; The Drug Trafficking Offenses Act, Cap 173 of the Revised laws of 2009; The Exchange of Information Act, cap 146 of the Revised Laws of 2009; The Proceeds of Crime and Money Laundering (Prevention) Act, 2001 The Proceeds of Crime and Money Laundering Regulations, 2002 The Financial Intelligence Unit Act, 2001 The Mutual Assistance in Criminal Matters Act, cap 177 of the Revised Laws of 2009; The Anti- Money laundering and Terrorist Financing Regulations, No. 20 of 2014; 4 The Confiscation in the Magistrates’ Court Regulations, No. 22 of 2015.

EU law EU Directive – 2015/849 – IV Anti‐ money laundering

FAFT Recommendations

Recommendations of FATF - FATF IX Special Recommendations, FATF 40 Recommendations

This policy applies to all Company officers, employees, appointed producers and products and services offered by the Company. All business units and locations within the Company will cooperate to create a cohesive effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions. All efforts exerted will be documented and retained.

OBJECTIVES

The purpose of this policy is to set the high-level principles and standards of management of financial crime risks, including money laundering, and terrorist financing, for the Company. The Company will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

  • The identities of all new and existing clients will be verified to a reasonable level of certainty

  • A risk-based approach will be taken to the monitoring of client tax and accounting affairs

  • Any suspicious activity will be reported, and all AML activities recorded

  • All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.

DEFINITIONS

For the purpose of this Policy, the act of Money Laundering shall have the same meaning as provided in Article 1(3) of the EU AMLD, which provides that it, when committed intentionally, encompasses:

(a) the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;

(b) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

(c) the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;

(d) participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c).

Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.”

For the purpose of this Policy, the act of Terrorist Financing shall have the same meaning as provided in Article 1(5) of the EU AMLD, which provides that it encompasses: “the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA”.

For the purpose of this Policy the act of Terrorist financing refers to the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to carry out an act of terror, or that the funds will be used to support any terrorist group, persons or association.

CUSTOMER DUE DILIGENCE

The Company has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty. This will include all individual clients. Identities will be verified either by email address confirmation or recognized by online identity verification agencies. These commercial agencies must have processes that allow the enquirer to capture and store the information they use to check and verify an identity.

The following documentation may be presented by the individual:

• Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.

If the Company fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.

RISK ASSESSMENT AND ONGOING MONITORING

The Company shall take a risk-based approach in monitoring the financial activities of its clients. This will be carried out whilst preparing the accounts, KYC stage or conducting any other business with the client.

The Company will actively not accept high-risk clients that are identified as follows:

• Clients with large one-off transactions, or a number of transactions carried out by the same customer within a short space of time.

• Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organised crime or drug production/distribution.

• Unusual patterns of transactions that have no apparent economic or visible lawful purpose.

• Money received from areas known to have high levels of criminality or terrorist activity.

• The following are examples of changes in a client’s situation that may be considered suspicious:

• A sudden increase of purchases from an existing customer;

• Uncharacteristic transactions which are not in keeping with the customer’s known activities;

• Peaks of activity at particular locations or at particular times;

Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

No action need to be taken if there is no cause for suspicion.

SUSPICIOUS ACTIVITY REPORTING

A Suspicious Activity Report (SAR) will be made to the Competent authorities as soon as the knowledge or suspicion that criminal proceeds exist arises.

Where we know that the funds in an account derive from criminal activity, or that they arise from fraudulent instructions, the account must be frozen. Where it is believed that the account holder may be involved in the fraudulent activity that is being reported, then the account may need to be frozen.

RECORD-KEEPING

Records of all identity checks will be maintained for up to 2 years after the termination of the business relationship or 2 years from the date when the payment has been completed.

Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of tiling the SAR.

All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

TRAINING

All affected employees are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering.

The training and awareness programme is reflected in its usage by:

a) mandatory AML learning training programme in accordance with the latest regulatory evolutions;

b) brief academic AML learning sessions for all new employees.

REVIEW

This Policy must be reviewed by the Company at least annually. Any changes to the Policy must be approved by the key stakeholders.