1. POLICY OBJECTIVES

• To verify the identity of all prospective investors prior to approval of any share subscription.
• To assess and manage the risk of financial crime associated with each subscription.
• To ensure compliance with applicable legal and regulatory obligations.
• To maintain appropriate records to support audit and regulatory review.

2. CUSTOMER DUE DILIGENCE (CDD)

The Company shall conduct Customer Due Diligence prior to approving any share subscription. CDD may include:

• Verification of full legal name and date of birth
• Verification of residential address
• Collection of government-issued identification documents
• Biometric or photographic verification
• Screening against sanctions and politically exposed person (PEP) lists
• Source of funds information where appropriate

The Company reserves the right to request additional documentation or clarification at any time.

No subscription shall be approved until required CDD procedures have been satisfactorily completed.

3. ENHANCED DUE DILIGENCE (EDD)

Enhanced Due Diligence may be conducted where higher risk factors are identified, including but not limited to:

• Politically Exposed Persons (PEPs)
• High-risk jurisdictions
• Unusual transaction patterns
• Complex ownership structures

The Company may require additional documentation, declarations, or verification before proceeding.

4. ONGOING MONITORING

• The Company may conduct ongoing monitoring of investor activity to identify suspicious behaviour.
• The Company may re-verify identity or request updated documentation where appropriate.

5. REFUSAL OR TERMINATION

• Refuse any subscription;
• Suspend or terminate Portal access;
• Delay issuance of shares;
• Withhold dividend payments where legally required;
• Where concerns arise regarding compliance, legality, or financial crime risk.

The Company is not obliged to provide reasons for refusal where disclosure may prejudice investigations or legal obligations.

6. REPORTING OBLIGATIONS

• Where the Company knows or suspects, or has reasonable grounds to know or suspect, that funds are the proceeds of crime or related to terrorist financing, it may submit a Suspicious Activity Report (SAR) to the appropriate authorities.
• The Company shall not disclose the existence of any SAR or related investigation where prohibited by law.

7. RECORD KEEPING

• The Company shall retain CDD and transaction records for the period required by applicable law.
• Records may be retained in electronic form.
• Records shall be stored securely with restricted access.

8. DATA PROTECTION

Personal data collected under this Policy shall be processed in accordance with the Company’s Privacy Policy.

9. GOVERNANCE AND REVIEW

• Responsibility for oversight of this Policy rests with the Company’s directors.
• This Policy may be reviewed and updated periodically to reflect changes in law or risk profile.

10. GOVERNING LAW

This Policy shall be governed by and construed in accordance with the laws of England and Wales.