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MEASURES AGAINST MONEY LAUNDERING AND TERRORIST FINANCING OF THE COMPANY

EX ROCK S.R.O.

As a provider of services related to crypto assets in the Czech Republic, we are required to implement and enforce effective measures to prevent the misuse of our services for illegal activities such as money laundering and terrorist financing (AML/CFT measures). By implementing these AML/CFT measures, we help protect our business and our customers from potential financial crimes.

In particular, our AML/CFT measures take into account:

• Act No. 253/2008 Coll., on certain measures against money laundering and terrorist financing,
• Recommendations of the Financial Action Committee (www.fatf-gafi.org/en/home.html),
• opinions and methodological guidelines of the Financial Analysis Office (www.fau.gov.cz),
• Recognised and proven principles and practices in the area of prevention of money laundering, an overview of which is published by the Czech National Bank on its website (www.cnb.cz).

CUSTOMER IDENTIFICATION AND DUE DILIGENCE

An integral part of our AML/CFT measures is the implementation of customer identification and DUE DILIGENCE.

Identification

As part of the identification process, the customer's identity is established and verified. For this purpose, we collect the following information from customers:

• in the case of a natural person: all names and surnames, birth number and, if not assigned, date of birth and sex, place of birth, permanent or other residence, nationality and number and type of identity card, the State or, where applicable, the authority which issued the identity card and the period of validity;
• in the case of a natural person who is an entrepreneur: all names and surnames, birth number and, if not assigned, date of birth, sex, place of birth, permanent or other residence, nationality and number and type of identity card, the state or, if applicable, the authority that issued the identity card and the period of its validity, as well as its business name, distinctive supplement or other designation, registered office and personal identification number;
• for a legal entity:
  1. the basic identification data of the legal entity, which are the business name or name including a distinctive supplement or other designation, the registered office and the legal entity identification number or similar number assigned abroad,
  2. information to identify and verify the identity of the natural person who is a member of its statutory body, and
  3. basic identification data of the legal person who is a member of its statutory body and data to establish and verify the identity of the natural person who is a member of the statutory body of that legal person or who has been authorised by that legal person to represent it in the statutory body,
• of the trust: its designation and the identification details of its trustee, to the extent set out above, depending on whether it is a natural or legal person.

In order to verify the identity of the customer, we require proof of the existence of a bank account in the customer's name and copies of identity cards showing the above identification data.

We also determine and verify that the customer, or a person associated with the customer, is not a Politically Exposed Person (PEP).

PEP is considered to be:

• and a natural person who holds or has held a significant public office of national or regional importance (so-called. national PEP), such as, in particular, the head of state, the head of government, the head of a central government body and his deputy (deputy, state secretary), a member of parliament, a member of the governing body of a political party, the head of a local authority, a judge of the supreme court, constitutional court or other supreme judicial body, against whose decision, generally with exceptions, no appeal is available, a member of the board of a central bank, a high-ranking officer of the armed forces or corps, a member or representative of a member, if a legal person, of the statutory body of a state-controlled commercial corporation, an ambassador or head of a diplomatic mission, or a natural person who holds or has held a similar office in another state, in a body of the European Union or in an international organisation (so- called foreign PEP),
• and a natural person (so-called derivative PEP) who
  1. is a person close to the person referred to in point (a),
  2. is a partner or beneficial owner of the same legal entity or trust, as the case may be, as the person referred to in paragraph (a), or is known to have any other close business relationship with the person referred to in paragraph (a); or
  3. is the beneficial owner of a legal entity or trust, as the case may be, known to have been created for the benefit of a person referred to in paragraph (a).

Due diligence

As part of the customer review process, we collect additional information to better understand the customer's activities and their purpose for using our platform. This includes information about:

• the purpose and intended nature of the transaction, or long-term use of our platform;
• the nature of the customer's business;
• the ownership and management structure of the customer if the customer is a legal entity;
• the source of funds or other assets that are the subject of customer transactions;
• in the case of user account creation of a on our platform, we carry out a follow-up check consisting primarily in the continuous monitoring and examination of the transactions carried out by the customer in order to verify that these transactions are in accordance with the information provided by the customer.

Customers are required to provide us with all necessary information to enable identification and due diligence, including the submission of relevant documents.

At EX Rock s.r.o. we strive to provide a safe and comfortable environment for our customers. Our AML/CFT processes help us not only to meet our legal obligations but also to protect our customers from the risks associated with financial crime. Thus, we appreciate your understanding and cooperation in providing the information required to maintain the integrity of our services.