KYC AML Policy

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2.           Introduction

This Policy is provided to you to help you understand, as a potentialor actual clientof Pure North Markets Ltd (the “Company” or “us”) the basic principles that the Company’s employs to discharge its regulatory dutiesrelating to customeridentification and verification and the measures that the Companytakes regarding prevention of money laundering and terroristfinancing on its trading platforms.

This Policy forms an integral part ofthe client agreement between you andthe Company (the “Client Agreement”) and other termsand policies that govern your relationship with us. As aprerequisite of openingand maintaining a trading accountwith us, you must agreeto and accept and consent to the terms of the Client Agreement. By doing so, you also agree to theterms of this Policy.

You must ensurethat you have read and understood the contents of this Policybefore you commence anyoperations on your Trading Account.

This Policylays down the Company’s frameworkand procedures for:

(i)                         preventing theCompany from being used, intentionally orunintentionally, by criminal elementsfor money laundering or financing of terrorist activities;

(ii)                       enabling theCompany toknow/understand theClients andtheir background and sourceof funds;

(iii)                    properly identify and verify the identity of Clients.

This Policy canbe modified or altered by theCompany atany time, with orwithout notice.

3.            Legal Framework

The Company is required to comply with the provisions of the followinganti-money laundering laws and regulations of Mauritius, as may be amended from time to time:

•       The Financial Intelligence andAnti-Money Laundering Act 2002 (FIAMLA)

•       ThePrevention of CorruptionAct 2002

•       ThePrevention ofTerrorism Act2002

In accordance with the Laws, we areobliged toset outpolicies andprocedures forpreventing money laundering activities. Those procedures, which are implemented by the Company include, inter alia:

(i)                         identification anddue diligence procedures ofthe Clients through the implementation ofa risk-based approach;

(ii)                       record keeping procedures inrelation tothe Clients’ identity andtheir transactions at ourtrading platforms;

(iii)                    internal reporting procedures to the Company’s MoneyLaundering Reporting Officer, appointedto receive and consider information or suspicion that a Client is engagedin money laundering activities;

(iv)                     appropriate procedures of internal control, risk management, with the purpose of preventing money laundering activities; and

(v)                        examination oftransactions that due totheir nature are considered vulnerable to money laundering, especially for complicated or unusually large transactions and transactions that take place withoutan obvious financialor legal purpose.

4.           Risk-Based Approach

4.1.        Risk-Based Approach in Client Verification

The Company appliesappropriate measures and procedures, on a risk-based approach, so as tofocus its effortin those areaswhere the risk of moneylaundering and terrorist financing appears to be higher. A risk-based approachis adopted by the Companyduring the verification of the Client’s identity, the collection of information for the construction of their economic profile and the monitoring of their transactions and activities at their Trading Accounts. Taking into consideration the assessed risk,the Company determines the type and extent of measures it adopts, to manage and mitigate the identified risks.

Client acceptance procedure is prepared following a detailed assessment of the risksfaced by the Company from the Clients and/or their transactions and/or their countries of origin or operations and/or any other factors the Company may identify as significant from the time. TheCompany identifies the Clients priorto or during the commencing of a business relationship.

The Company, in accordance with the Law, conducts the verification of the identityof the Clients and the beneficialowners (if the Client is a body corporate) during the establishmentof the business relationship. The verification of Clients’ information may be made via the submission of documents or electronically, or by othermeans in the Company’s sole discretion.

4.2.        Timing ofClient Identification

The Company performsidentification of the Clients prior to the establishment of the business relationship and proceedswith verification of the potential Clients’ identity prior to or during the establishment of a businessrelationship to preventinterruption of the normal conductof business and wherethere is limitedrisk of moneylaundering or terrorist financing occurring.In case of the latter,the due diligence procedure shall be completed as soon as practicableafter the initial contact. Where, in the Company’s opinion, the risk of money laundering and terrorist financingcannot be determined as low, enhancedClient due diligenceshall be completed prior to the establishment of a businessrelationship. Each Client is requiredto complete the Company’sKYC procedures by submitting the relevant KYC documentation or passing electronic verification.

4.3.        Operation of Trading Account Priorto Completion of Verification

The Company, in its sole and absolutediscretion, may enablea Client to operate its TradingAccount during the establishment of the businessrelationship when the Client is deemed as beingof low risk of moneylaundering and terrorism financing and according and further subject to a maximumdeposit limit not exceeding 500,000Mauritius Rupees or equivalent in othercurrencies. Such Clientsmust complete theirKYC onboarding and provide all relevantverification documents to the Companywithin 14 days after the date of opening of theTrading Account.

Clients who are permitted to use their Trading Accountunder this Section3.3 are given 14 days from the day of openingthereof to completethe Company’s KYC and verification procedure. In case where a Client is unable to comply with the Company’s KYC andverification requirements within the aforesaid time frame, the Company shall return the funds

as part of the termination process and close the account.In this case, the relationship is to be considered void and the funds have to be returned to a bank account in the name of the depositor. Where the Companyis unable to return the funds to its sourceof deposit, it mustretain the funds in a separate bank account until the Client completes the KYC and duediligence procedure to the Company’s satisfaction in order to be able to withdraw the funds.

5.  Client Identification

For ascertaining thetrue identity of theClient, each Client whois anatural person shall be required to provide the Company with at least the following information:

(i)                         True name as stated on theofficial identity card orpassport;

(ii)                       Full residential address, including postal code;

(iii)                    Telephone;

(iv)                     Email address;

(v)                        Date ofbirth;

(vi)                     Nationality; and

(vii)                  Details ofoccupation ofthe Client.

Each Client who is a natural person shall provideto the Company at least the following documents during the onboardingprocedure to verify the above information of the Client:

(i)                         a valid proof ofidentity;

(ii)                       recent proof of residence, in theform ofa utility bill, local tax authority bill ora bank statement (not older than 3 months);

(iii)                    such otherdocuments as the Company may reasonably requireverifying the Client’s sourceof wealth and occupation.

Where a Client is abody corporate or acompany orany other type oflegal entity, the Company shall requirethe following documents and information:

(i)                         full name of thelegal entity;

(ii)                       legal entity’s address (place of operations);

(iii)                    certificate ofincorporation;

(iv)                     certified copy of licence;

(v)                        copy ofthe latest audited accounts/latest management accounts;

(vi)                     certificate orregister ofdirectors;

(vii)                  certificate orregister ofshareholders;

(viii)                copy ofthe structure chart toidentify thecompany's UBO;

(ix)                     certified copy of the passport and certified copy of the latest proof of address (less than 3 months old) of 2directors of the company;

(x)                       certified copy of the passport and certified copy of the latest proof of address (less than 3 months old) of theshareholders of the company

(xi)                     list ofauthorized signatories or mandates with specimen signatures

(xii)                  full KYCdocuments forthe ultimate beneficial owner of thelegal entity, including evidence of beneficial ownership.

The Company reserves the right to demand, when itdeems appropriate, notarized and/or apostilled copiesof the above documents alongwith an Englishtranslation thereof.

The Company reservesthe right to take such additional measuresas it deems fit when conducting Client due diligence in cases where, in the Company’s opinion, there is an elevatedrisk of money laundering. When entering into the ClientAgreement with the Company, the

Client authorizes the Company to carry out such searchesand to transfer the Client’s information to such externaldatabases and verification service providers (such as World Check) as the Company might deemnecessary to complete its KYC and verification procedures.

The Company retainsfull and absolutediscretion as to the precisetype and form of the KYCdocuments collected from the Clients.You shall be advised on what you are requiredto provide by the relevant Client onboarding officer of the Company.

6. Politically Exposed Persons

It’s the Companypolicy not to establish a business relationship nor accept as Client persons who are classified as Politically ExposedPersons (“PEPs”) or the immediatefamily members of PEPs due tothe same presenting additional risks to the Company.

The Company has the right to performchecks concerning the Clients in external databases (such as World Check)in order to identify if the respective potential Client is considered a PEP or is included in any sanctionslist.

The meaning of PEP includesthe following naturalpersons who are or have been entrusted with prominent public functions in any country:

(i)                         heads ofstate, heads of government, ministers anddeputy orassistant ministers;

(ii)                       members of parliaments;

(iii)                    members of supreme courts,constitutional courts or other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptionalcircumstances;

(iv)                     members of courts of auditors or the boardsof central banks;

(v)                        ambassadors and high-ranking officers in the armed forces;

(vi)                     members of the administrative, management or supervisory bodies of state-ownedenterprises.

7. Record Keeping

The Company documentsour verification process,including all KYC information providedby the Clients, the methods used and resultsof verification, and the resolution of any discrepancies identifiedin the verification process. We keep recordscontaining a description of any documentthat we relied on to verify your identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuanceand expiration date. With respect to non-documentary verification, we retaindocuments that describethe methods and the resultsof any measures we took to verify theidentity of Clients. We also keep recordscontaining a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We shall keep the Clients’KYC documents and information, as well as information aboutthe transactions posted on the Platformthrough the Clients’Trading Accounts, for 5 (five) yearsafter the date of termination of the relationship with the relevant Client.

8. Unacceptable Jurisdictions

The Company does not acceptClients from the following jurisdictions: Mauritius, United States of America, Afghanistan, American Samoa, Anguilla, Dominica, Fiji, Guam, Palau, Panama,

Trinidad and Tobago,Virgin Islands (U.S.),Vanuatu, Central AfricanRepublic, Congo (Democratic Republic of the), North Korea, Ukraine, Russia, Iran, Iraq, Indonesia, Libya, Mali, Somalia, Sudan,Yemen, State of Palestine.

However, this list issubject toupdating from time totime. Youmust follow the updates within this Policy before you commence registering a ClientLogin.

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