Bilenex AML POLICY

1. OBJECTIVES

This Anti-Money Laundering and Know Your Customer Policy (AML/KYC Policy) aims to reduce the risks related to money laundering and other illegal activities at Bilenex Sp. z.o.o. This document does not offer a comprehensive summary; rather, it emphasizes the internal policy's main ideas. To access the complete material, kindly get in touch with our customer service.

Bilenex is required by both national and international rules to set up efficient internal processes and methods to stop money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Additionally, the Bilenex company is required to take appropriate action in response to any suspicious activities conducted by its customers. The following areas are covered by the AML/KYC Policy:

• Assigning a Anti Money Laundering Officer (AMLO) and making sure staff members understand their responsibility to notify the AMLO of any questionable conduct.
• Top managers' roles should be clearly defined, and they should get regular updates on the dangers associated with money laundering.
• Keeping records of and upgrading anti-money laundering policies, procedures, and controls on a regular basis.
• Sending any suspicions of money laundering to the relevant authorities and reporting them.
• Putting policies in place to ensure that money laundering concerns are taken into account in the company's daily activities.
• Giving pertinent staff members thorough training on their duties related to combating money laundering.
• Promptly replying to any correspondence from the appropriate authority.

2. ANTI MONEY LAUNDERING OFFICER

The final decision on fulfilling Anti-Money Laundering (AML) regulations rests with the AMLO. The words "Anti Money Laundering Officer" and "AMLO" refer to the same person for purposes of clarity in this publication. As stated before, the AMLO has the power and access to all relevant data needed to carry out their responsibilities in an efficient manner.

To reach our compliance department, please contact us via email at: [email protected].

3. GENERAL PRINCIPLES

Prior to executing any transaction for a new Customer, the company must establish and implement several procedures:

• AML procedures include confirming the identification of the customer, keeping records, spotting and keeping an eye on odd or suspicious transactions, reporting and managing them internally as needed.
• Delivering suitable training to the required staff.
• Sending any pertinent requests to the Anti Money Laundering Officer (AMLO) directly from outside sources.
• Ensuring that staff members understand their roles and the policies of the organization.

4. TRANSACTION MONITORING

Effectively addressing the risk of money laundering and terrorist financing depends on ongoing oversight of customer accounts and transactions. Establishing and improving the company's continuing monitoring methods falls under the purview of the AMLO in this regard.

Our company's transaction monitoring is based on the tenets of high precision and promptness in order to guarantee the security and dependability of our clients' payment operations.

5. IDENTITY VERIFICATION (KYC)

Any supporting documents the business receives in relation to a new customer's identity must be able to credibly confirm the customer's claimed identity and prove they are a real person or legal organization. During the Customer onboarding process, the company may ask for outside assistance with fact-checking, but it is still legally responsible for ensuring that the verification process conforms with all regulations.

We shall carefully adhere to the company's privacy policy and any applicable legislation that supports the General Data Protection Regulation (GDPR) in the collection, storage, sharing, and protection of the identified customer information.

6. SANCTION LISTS

International regulations are strictly followed by the company Bilenex Sp. z.o.o. It is forbidden to do business with people, organizations, or nations that are the target of international sanctions. These sanctions, which are imposed by a number of international organizations, including the European Union, the United Nations, and other pertinent authorities, are intended to limit financial and commercial exchanges with organizations engaged in illicit activity or that pose a risk to global peace and security.

In order to ensure compliance with sanctions obligations, Bilenex Sp. z.o.o. has robust systems and procedures to verify transactions, counterparties, and clients against relevant sanction lists and watchlists. These lists include individuals, groups, and countries that are subject to sanctions due to their involvement in illicit activities such as money laundering, terrorism, violations of human rights, or the proliferation of weapons of mass destruction.

If a customer, counterparty, or transaction is found to be in violation of international sanctions, the company will take prompt steps to halt it and notify the appropriate regulatory organizations. Compliance with sanctions is a high priority for the Company's risk management system, and all employees are trained to obey these policies.

The Company actively participates in international efforts to prevent illicit activity and uphold the integrity of the financial system by strictly enforcing sanctions legislation.

7. PROHIBITED COUNTRIES

Regarding the risks of money laundering and the rendering of its services, Bilenex Sp. z.o.o. closely complies with all applicable laws and international legislation. In order to fulfil these duties, the Company has taken steps to make sure that it doesn't offer services to people living in specific nations where there is a higher risk of money laundering or where doing business is forbidden or illegal.

These nations are chosen based on a number of variables, such as the evaluation of global organizations that specialize in combating money laundering and the identification of regions in which the Company's services may be abused or misused for illegal reasons.

The comprehensive Anti-Money Laundering Policy, which can be requested from the Company, has a detailed list of jurisdictions that are prohibited. It's important to keep in mind that this list may be amended or changed depending on the decisions made by the authorities designated by the company, including the Anti Money Laundering Officer (AMLO). When the policy is amended, any changes made to the list of countries that are restricted will become effective.

The Company restricts services to residents of these restricted jurisdictions in order to lessen the likelihood of money laundering and to ensure compliance with applicable laws and regulations.

8. RISK ASSESSMENT

The company will use appropriate protocols and guidelines through a risk-based strategy in order to focus its attention on regions where there is a relatively greater chance of money laundering and terrorist financing.

In addition, the AMLO will keep a close eye on and evaluate the efficiency of the policies and processes described above.

The following essential components of the company's risk-based strategy are covered in the Policy:

• Gives the board the ability to alter rules, practices, and controls to fit the particular needs of the business.
• Gives the board of directors the ability to distinguish between clients according to the unique business risks that each poses.
• Increases systemic cost-effectiveness.
• Helps to prioritize actions and efforts in response to the possibility that using the company's services could result in money laundering and terrorist financing.
• Acknowledges that different clients, nations, services, and financial instruments pose different risks of money laundering or financing terrorism.

The company has implemented a risk-based approach, as defined in the Policy, which encompasses particular measures and procedures to detect and handle risks related to money laundering and terrorist financing in a cost-effective and effective manner.

9. CONTACTS

Please do not hesitate to get in touch with our committed compliance department if you have any queries or worries about the Anti-Money Laundering and Know Your Customer Policy, or if you require any additional information or support. Contacting our team can be done via the email [email protected].

Our compliance team is here to help with any questions you may have about the policy, offer advice on compliance-related concerns, and support you with any problems or questionable activity that comes up. Please don't hesitate to contact us if you have any questions or need more information on any part of the policy.

Additionally, we strongly advise you to notify our compliance department right once if you become aware of any questionable transactions or activity pertaining to our services. The integrity of our operations and the fight against money laundering depend heavily on your cooperation and attentiveness in keeping a safe and legal environment.

We are grateful for your faith in our business and will continue to respect the latest anti-money laundering and compliance guidelines.