Everdust OÜ (“the Company”)

AML Compliance Policy

I. GENERAL ASPECTS

Throughout their activity, companies similar to EVERDUST OÜ (the “Company” or “EVERDUST OÜ”) are exposed to the risk of their services being used in transactions with funds from illicit activities, facts which are incriminated by the laws in force.

A major risk for such companies is the reputational risk that may arise as a consequence of their involvement in money laundering or financing terrorist acts.

The Company is not providers of a service of exchanging a virtual currency against a fiat currency or providers of a virtual currency wallet service or other authorization person under Money Laundering and Terrorist Financing Prevention Act. At the same time the Company would like to implement best practice of the laws concerning the prevention and fighting against money laundering.

This policy is hereby created in view of implementing it at the level of EVERDUST OÜ as an efficient means of defense in the fight against money laundering and financing terrorist prevention acts.

II. SCOPE

This policy applies to all third parties the Company might do business with (the “Third-Party Entities”) and to all individuals working for the Company, including employees, directors, and anyone providing services to the Company such as consultants, or contractors or other persons acting under or on behalf of the Company (collectively referred to as the “Associates”).

The purpose of the KYC & AML Policy is to ensure that the activity of the Company is carried-out in accordance with the applicable legislation, including with the laws concerning the prevention and fighting against money laundering. The KYC & AML Policy is applied by the Company with respect to the relevant operations conducted through it and also with respect to the transactions in which the Company is directly involved and which may generate a material exposure to a reputational risk or to other risks arising out of the relationship between the Company and its Associates and Third-Party Entities.

III. STAGES THAT MUST BE PASSED THROUGH IN ORDER TO PREVENT AND FIGHT MONEY LAUNDERING AND THE FINANCING OF TERRORISM ACTS

1. KYC & AML Policy

1. Accepting and identifying Third-Party Entities

   This is the stage that precedes the establishment of any legal relation between the Company and a potential Third-Party Entity.

   Any Third-Party Entity will be accepted only after having applied the customer identification provisions adopted by the Company. The Company shall not enter into relationships with Third-Party Entities that cannot provide the information required by the Company, which is considered material for starting a relationship with the Third-Party Entity.

2. Third-Party Entities categories

   The categories of Third-Party Entities are the following:

   • Depending on the country of origin or the country where the its headquarter is situated:

     • Estonia registered Third-Party Entity;
     • Third-Party Entities from EU Member States; or
     • Third-Party Entities from third countries.

   • Depending on the type of activity carried-out by the Third-Party Entities:

     • persons with regular activities, without political implications – are persons who carry-out any type of activity permitted by the law, which does not involve holding an important public office at national and/or international level; and
     • persons with political exposure (PEP) - are natural persons who currently hold or who have held important political offices at national and/or international level, as well as the members of their families and the persons associated with them. PEP family members are the spouses, the children and their spouses, their parents. A Third-Party Entity ceases to be qualified as a PEP Third-Party Entity one year after it stops holding that public office.

   • From the risk category perspective, Third-Party Entities are classified as follows:

     • low risk Third-Party Entities, such as for example credit institutions or other financial institutions based in a EU Member State or another third country which apply and observe similar KYC/AML requirements;
     • potentially higher risk Third-Party Entities, such as for example PEP Third-Party Entities;

     • inacceptable Third-Party Entities who are:

       1. esignated as such by the laws on international sanctions;
       2. who refuse to identify themselves; and
       3. who were convicted for money laundering and terrorist financing.

3. KYC & AML measures

   Throughout its activity, the Company applies standard and supplementary KYC measures in accordance with the applicable laws and regulations regarding money laundering, the financing of terrorism and proliferation financing.

   • Standard KYC & AML measures

     The Company will apply the standard KYC & AML measures in the situations where these measures are required, which include when:

     • establishes a business relationship;
     • suspects money laundering or terrorist financing, proliferation financing, regardless of any derogation, exemption or threshold;
     • doubts the veracity or adequacy of documents, data or information previously obtained for the purposes of identification or verification; and/or
     • carries out an occasional transaction of 1000 euros, whether the transaction is carried out in a single operation or in several operations which appear to be linked.

     The standard measures include:

     • identifying the Third-Party Entities and verifying their identity. This will be made based on documents and, as the case may be, based on the information obtained from independent reliable sources.

       When a Third-Party Entity is represented, in its relationship with the Company, by another person, who acts as its authorized representative, the relevant information and documents regarding the identity of such representative and also, as the case may be, those referring to the nature and the limits of its power of attorney must be obtained and verified.

     • identification, if necessary, of the real beneficiary of the Third-Party Entity, so that the information held is satisfactory and allows, including, the understanding of the ownership and control structure of the legal entity Third-Party Entity;
     • obtaining information about the purpose and nature of the business relationship;
     • the continuous monitoring of the business relationship, including by analyzing the transactions concluded during it, to ensure that these transactions correspond to the information held about the Third-Party Entity, his risk profile and the profile of the activity, including, as the case may be, about the source of the funds, and by ensuring the update documents, data and information held.

   • Additional KYC & AML measures

     For Third-Party Entities with a potentially higher risk, in addition to the standard measures, the Company will apply additional measures, including, without being limited to:

     • if deemed necessary, request additional documents and information to determine the identity of the Third-Party Entity;
     • take additional measures for verifying and certifying the documents presented by such Third-Party Entity;
     • the person empowered to coordinate the activity in relation to those Third-Party Entity will request detailed information with respect to the personal circumstances of such Third-Party Entity and must pay a particular attention to the information received from Third-Party Entity in relation to such persons;
     • in respect of PEP Third-Party Entities, apply the additional KYC/AML measures provided under Money Laundering and Terrorist Financing Prevention Act.

   • Simplified KYC & AML measures

     The Company can apply simplified measures with respect to low risk profile Third-Party Entities, including (without limitation):

     • credit or financial institutions from an EU member state or the European Economic Area or, as the case may be, from a third state that imposes similar requirements and supervises them accordingly;
     • companies whose securities are admitted to trading on a regulated market, in one or more EU member states and companies listed on a market in third countries and which are subject to reporting and transparency requirements equivalent to Estonia legislation;
     • national public authorities.

     If it applies simplified KYC & AML measures, the Company will ensure that it has obtained sufficient information about the Third-Party Entities and will continue to permanently monitor their activity in order to establish that they fall into the category of Third-Party Entities in connection with which the applicable legislation allows the application of simplified KYC & AML measures.

4. KYC & AML stages

   Knowing your Third-Party Entities represents a continuous process of analysis and prudential evaluation with respect to the Third-Party Entities, their economic status and financial needs. The volume of information and the type of documents required during the KYC process depends on the Third-Party Entities’ profile, the transactions performed and on the risk degree associated with the Third-Party Entities.

   The KYC & AML stages observed by the Company during its activity are:

   1. identification of the Third-Party Entities when establishing a business relationship;
   2. monitoring the Third-Party Entities during the business relationship, with a purpose to identify suspicious transactions; and
   3. analyzing and reporting suspicious transactions.

5. Third-Party Entities identification

   The Company must make sure that it knows its Third-Party Entities, by applying an identification procedure. The identification of the Third-Party Entities is made based on official documents or other type of documents that are difficult to falsify and obtain illicitly, such as official identity documents issued by the authorities, containing the photo of the holder, or identity cards/passports, in case of natural persons or a registration certificate for a legal person.

   All relevant information obtained by the Company regarding the Third-Party Entities in the KYC process will be filled in by the relevant Third-Party Entity and submitted to the Company in any relevant form, which should include information below.

   • Identification of natural persons

     The information for the identification of natural persons must refer to:

     • name and surname;
     • type of national identity document, series/number, date of issue;
     • registered address and current address/telephone number; and
     • the nature of its activity.

   • Identification of legal persons

     The information for the identification of legal persons must refer to:

     • company name, type of company, headquarters;
     • address and telephone number;
     • Trade Registry number and fiscal registration number;
     • legal representatives or special mandate of the authorized representatives;
     • ultimate beneficial owner.

     In all cases, the Company will request copies of the documents regarding the identity of the Third-Party Entities. To the extent necessary, the Company may request additional information regarding the Third-Party Entities’s country of origin, its public position, source of funds and other facts.

   • Identifying the ultimate beneficial owner (UBO)

     The Company will take all reasonable measures to identify the real beneficiary and verify its identity on a risk basis. In order to verify the identity of the real beneficiary, the Company will request, in addition to a copy of the respective person's identity documents, any other documents it deems necessary to ensure the accuracy of the information received from the Third-Party Entities.

6. Information verification

   Verifying the information about the Third-Party Entities is mandatory and is made by confronting the information provided by the Third-Party Entities with the information obtained by the Company from other third parties and/or public records, to the extent such information is available.

   The Company can use any services and KYC/KYB software for the verification of the identity of the Third-Party Entities such as https://sumsub.com/ and https://www.chainalysis.com/ or any other relevant software.

   These services and software should allow:

   • identity verification of Third-Party Entities for screening and monitoring of these Third-Party Entities in global AML watchlists, PEP lists and sanction lists;
   • ID document verification that allows for authenticating ID documents effectively and verifying Third-Party Entities. This should ensure the verification of forged, expired, and stolen IDs before such documents can be used to commit fraud;
   • verification of legal entities that should ensure that the companies are legitimate ventures and not false fronts for corruption, fraud, and money laundering.

7. How to approach transactions and Third-Party Entities in and/or from jurisdictions that do not require KYC procedures and records in relation thereto

   Third-Party Entities that are part of jurisdictions that do not require the application of KYC procedures and the maintenance of records in relation to the Third-Party Entities, may be classified as higher risk Third-Party Entities. If, following the application of the standard KYC & AML measures, it is discovered that a Third-Party Entity is part of the aforementioned risk category, the additional KYC & AML measures will be applied which are applicable to higher risk Third-Party Entities.

   Furthermore, as a safety measure for the prevention and fighting against money laundering and terrorist financing, the Company may decide to refuse persons that do not observe these rules by refusing the standard and additional measures that the Company intends to apply.

2. Maintaining records with respect to Third-Party Entities identity

The Company will keep copies of the documents used as proof of identity or identity reference for a period of at least 5 years from the date on which the relationship with the Third-Party Entity ends. This is consistent with data protection legislation and AML/CFT requirements.

If necessary and the business relationship continues long term, the Third-party Entities risk profile will be reviewed at least annually (where applicable) and/or where there is a trigger event which prompts the review.

If the process of ongoing monitoring of Third-party Entities, the Company identifies suspicious activities, the Company is to take action accordingly for further analysis of Third-Party Entities.

Suspicious activities within ongoing monitoring of Third-party Entities will include but are not limited to:

• often change of payment methods;
• whether the transactions or activity are unusual patterns for the Third-party Entities;
• whether the transactions are unusually large;
• any alerts from third parties and/or public records of sanctions lists, watchlists;
• whether the transactions present a higher risk of money laundering, financing of terrorism, or proliferation financing by the subjective decision of the Company.

3. Prevention of money laundering

In order to prevent and sanction money laundering, the Company will request additional data from the Third-Party Entities regarding the source and destination of the funds as well as the purpose of the transaction and the real beneficiary’s identity, as soon as any elements appear which might legitimately give rise to suspicions.

In accordance the applicable laws, a suspicious transaction is deemed to be the transaction which, by the nature and unusual character of the Third-Party Entities’s activity, raises suspicions of money laundering and/or terrorism financing. The following can be considered suspicious transaction generated by the Third-Party Entity’s behavior:

• the Third-Party Entity who refuses to provide or conceals personal information requested by the Company, or provides false information which does not enable the Company to apply the standard KYC measures;
• the Third-Party Entity who provides doubtful or false information in relation when requested by the Company;
• the Third-Party Entity who is reluctant to provide the information required for drawing up a mandatory report, for completing the report or to initiate a transaction after being informed that the report must be completed; or
• the Third-Party Entity totally avoids the direct contact with the Company, the communication being exclusively made by e-mail, fax etc.

When the documents presented and the explanations given by the Third-Party Entity are not sufficient or give rise to suspicions, the management of the Company will analyze the explanations and decide if the matter needs to be reported to the relevant authorities.

4. Fight against terrorism financing

The Company must pay increased attention when initiating business relationships with any Third-Party Entities e.g., clients, intermediaries, insurers for the purpose of preventing the risk of financing terrorism through the Company. The Company will request and verify documentation presented by the Third-Party Entities upon the initiation of the business in order to determine if the persons concerned are mentioned in the lists disseminated by the EU authorities that contain the name of persons or organizations suspected of terrorism, the United Nations Organization (UNO), the European Commission and other relevant public authorities, so as to avoid entering into business relations with these persons.

5. Anti-Bribery And Corruption

The Company is committed to implementing and enforcing effective systems to counter bribery and corruption.

The Company will not:

• make contributions of any kind with the purpose of gaining any commercial advantage;
• provide gifts or hospitality with the intention of persuading anyone to act improperly, or to influence a public official in the performance of their duties;
• make, or accept, “kickbacks” of any kind.

The Company will:

• keep appropriate internal records that will evidence the business reason for making any payments to third parties;
• encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage;
• see that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.

Associates must not:

• accept any financial or other reward from any person in return for providing a certain favor;
• offer any person any financial or other reward in return for providing a certain favor.

6. Organization and responsibilities

This chapter refers to the organization and duties of the Responsibility of the persons from the Company’s management.

Responsibility of the persons from the Company’s management

• to prepare and implement an efficient KYC & AML Program;
• to ensure the periodic adequate training of the Associates of the Company, by including the presentation of this document in the initial training program of the new Associates and by communicating whenever necessary the amendments occurred to this procedure; and
• to ensure the control on the compliance with the programs established and the efficiency of policies, procedures and systems implemented.

Obligations of the Company’s Associates, irrespective of their position and of the place where they carry out their activity

• to know and apply the legal provisions for the prevention and fight against money laundering and of internal regulatory documents;
• to be vigilant in relation to the transactions carried out by the Third-Party Entities and to inform the Company’s management regarding any suspicious transactions;
• to keep the confidentiality of the operations and Third-Party Entities which were the subject of controls by the authorities; and
• to keep all the documents in relation to the identification of the Third-Party Entities.