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AML and KYC Policy

ANTI-MONEY LAUNDERING AND KNOW YOUR CUSTOMER POLICY

Version 1.0 of 04.09.2018

London, England

AGGREGION LTD, a company registered under the laws of England and Wales, date of incorporation: February, 13, 2015, England and Wales company number: 9437805, having its registered address at 1 Berkeley Street, Mayfair, London, W1J 8DJ, United Kingdom, hereinafter referred to as the Company, hereby approves the following AML and KYC Policy.

1. The Company will adhere to the following business principles:

1.1 All buyers, suppliers and other contractors (hereinafter, the “Contractors”) of the Company shall have proper legal capacity in the country or countries where they operate. Individual Contractors shall be at least 18 years old. Contractors that are legal entities shall be duly organized, validly existing and in good standing under the laws of their domiciliary jurisdiction and each jurisdiction where they conduct business.

1.2 Contractors and their activities shall comply with all local laws in effect in the country that has jurisdiction over the Contractor or where the Contractor operates.

1.3 Any interactions between the Company and the Contractor, including any transfers of funds from the Contractor to the Company, shall be lawful and conducted in good faith under applicable law and shall not pursue any criminal or unlawful objectives.

1.4 Any funds transferred or goods, work or services supplied by the Contractor shall be lawful and shall not have originated from any criminal enterprise.

1.5 When registering at app.aggregion.com or interacting with the Company directly, the Contractor shall not provide any inaccurate information about self, nor register an account for a nominee or a fictitious person.

2. The purpose of this AML and KYC Policy shall be to:

2.1 Verify that the Contractor has not been listed as a terrorist or terrorist organization, is not subject to sanctions by any country or countries and/or international organizations, nor serves as an agent for any such persons or acts in any other manner whatsoever in the interests of any such persons;

2.2 Prevent the Company from getting involved in unlawful activities or creating conditions or fertile grounds for getting involved in any such activities;

2.3 Inform the Contractors of any action taken by the Company under this Policy, require, at its sole discretion, additional information as may be necessary for identifying the Contractor and notify said Contractor of the consequences of the Company refusing to do business therewith as part of any such action.

3. Taking AML and KYC action.

3.1 The Company shall appoint a dedicated employee or employees in charge of AML and KYC.

3.2 AML and KYC action shall include:

3.2.1 Monitoring and analysis.

3.2.1.1 The Company shall conduct independent monitoring and analysis of the identifying information about the Contractors it collects, of information about the specific actions they take when interacting directly with the Company, and of other information about the Contractors it may have obtained by lawful means.

3.2.1.2 Comprehensive monitoring and analysis may involve the use of analytical software and specific actions by authorized persons.

3.2.1.3 Monitoring and analysis may include interactions with authorized personnel in charge of AML and KYC at such organizations as banks and financial institutions and receipt of information, notifications and instructions from competent government authorities.

3.2.2 Verification.

3.2.2.1 Verification presumes a detailed review of the information about the Contractor for any signs that it may not be in compliance with one or several requirements set forth in Article 1 of this Policy, as identified by the monitoring and analysis effort.

3.2.2.2 During the verification procedure, the person in charge of KYC shall forward to the Contractor a request for additional information and corroborating documents, as may be necessary for Contractor verification. Such information or documents may include the following: name (company name), date of birth or incorporation, home address (address where incorporated), tax ID, personal identification number (if applicable in the country of domicile), information about the individual’s identification document, citizenship (country of incorporation) and contact telephone number. Where the information requested is related to a specific document issued, a (scanned) electronic copy of such document may be requested.

3.2.2.3 A Contractor receiving a request for information as part of the KYC procedure shall make such information available within 3 calendar days of receiving said request. If facing difficulties providing documents or information requested within the time allowed, the Contractor shall advise the Company of same, indicating the reasons and stating when it may be able to do so.

3.2.2.4 Failure to submit information as requested within the time allowed may constitute grounds for terminating the relationship with the Contractor for failure to pass KYC verification.

3.2.2.5 Once all the information and documents requested are submitted, the employee in charge of KYC shall review same within 3 business days. Following the review, the employee in charge of KYC may make one of the following decisions:

3.2.2.5.1 Approve the Contractor as having passed KYC verification;

3.2.2.5.2 Request and review additional documents as set forth in paragraphs 3.2.2.2, 3.2.2.3, 3.2.2.4 of this Policy;

3.2.2.5.3 Find that the Contractor has failed to pass KYC verification.

3.2.2.6 The employee in charge of KYC shall inform the Contractor of the results of the verification no later than on the next business day following the date of verification.

3.2.2.7 The finding of the employee in charge of KYC that the Contractor has failed to pass verification may be contested with said KYC employee’s immediate superior at nukri.basharuli@aggregion.com.

4. Terminating the relationship with the Contractor that has failed to pass KYC verification.

4.1 Where it is found that the Contractor has failed to pass KYC verification, the Company shall terminate the relationship with said Contractor in the manner provided in the contract (agreement) therewith and, where necessary, inform competent authorities of same.

4.2 The relationship with the Contractor may be resumed if the Contractor that has failed to provide information or documents (as per paragraph 3.2.2.4 herein) provides same and is found to have passed the KYC procedure.

4.3 The relationship with the Contractor may be resumed if the reasons for which the Contractor was found to have failed to pass the KYC verification procedure is no longer valid and the Contractor has provided information and documents confirming same.