Know Your Client / Anti-Money Laundering

KYC/AML Policy

The purpose of the Anti-Money Laundering and Know Your Customer Policy ("AML/KYC

Policy") is to prevent money laundering and terrorist financing activities on the Service by

complying with the requirements of international and domestic laws and implementing a user

identification procedure.

Through the business of WMW Trade Kft we have already a database of existing

companies in international trade of goods and services businesses. On top of it, we have used

3rd party data and developed a KYC scoring model, which maps the customers into 3 zones:

Green, Yellow and Red.

We consider following risk categories: AML Risk, Sanction risk, Performance risk.

The model consists of several functions and weights of the function which target different risk

areas.

We focus on the following factors in our model:

A = market check. We check if the company is known on the market and what is the

reputation in the market. [Performance/AML]

B = financial check. We check the financial soundness of the company (3-5 years).

[Performance]

C = UBO declaration / UBO – check. We check if the UBO of the company is the real

economical beneficiary of the company and do a market check. [AML/Sanctions]

D = authenticity of cargo origin and pricing. We check the origins of the goods to bring

transparency and avoid any sanctions. [AML]

E = sanctions. We check if the company/goods/UBO/production sites fall under any sanctions.

The value is binary. [Sanctions]

F = political exposure / government relation. We check if the company/UBO/management

has any government exposure (i.e. not PEP but working with PEPs, GOs, etc.). [Sanctions/AML]

G = management qualification. We check if the management is qualified enough to perform

the declared transactions. [Performance]

H = affiliation check. We check other companies in the group if they have any negative kind

of information. [AML/Sanctions/Performance]

General Provisions

1.1. The Company must comply with the requirements of the domestic and international laws

on the prevention of money laundering and terrorist financing, as well as the requirements

of other laws and regulations, to the extent that they are related to the activities of the

Company.

1.2. The company distributing the AML/KYC Policy may make changes and additions to it at

its own discretion and will monitor compliance with its provisions and requirements.

2. Trade Services department employee

2.1. To control and implement the procedures reflected in the Policy, the Company appoints

an employee of the trade services department.

2.2. The Trade Services department employee is responsible for collecting, analyzing, and

investigating information about any suspicious activity as well as training the company's

employees in the relevant procedures; The Trade Services department employee shall define

procedures and rules for identifying Clients, verifying and monitoring unusual transactions.

3. Identification policy

3.1. In order to identify Clients, the Company requests the following documents:

- statement from the State/court registry of legal entities

- a document confirming the rights and powers of a person authorized to act on behalf of

the company

- identity confirmation (passport, driver's license)

3.2. The KYC (Know Your Customer) procedure applies to users suspected of making illegal

transactions. We may ask you for the following documents to prove your identity:

Identity proof documents:

- internal and / or foreign passport;

- identity card, ID card.

Address verification:

- Bank statement

- a receipt confirming the payment of a utility bill

4. Declaration of Conformity

4.1. The Corporate Client (an authorized employee of the Corporate Client) confirms that they

have read and understood the current Policy and that they (or their company) must act in full

compliance with the requirements and standards set out in the Policy and comply with all

applicable laws and other rules and requirements, governing its activities as a Corporate

Client.

4.2. The Corporate Client (an authorized employee of the Corporate Client) acknowledges

that it is responsible for its actions in accordance with applicable laws in the area discussed

in this Policy, and is responsible for non-compliance with such laws.