ANTI-MONEY LAUNDERING AND COUNTERING FINANCING OF TERRORISM POLICY

1. INTRODUCTION

1.1. Context and Purpose of the Policy

Redline Solutions Limited, a company registered in the Autonomous Island of Anjouan, Union of Comoros registration No. 15884, registered address is at: Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros, who is a holder of Gaming License No. ALSI-202502005-FI1 (hereinafter also “We”, “Us”, “Our”, “Operator” or “Company”).

The Company carries out its operations in jurisdictions where gambling activity is allowed and complies with gaming and betting license and the law of Autonomous Island of Anjouan, Union of Comoros.

The Company is not classified as a financial institution under the applicable laws of Autonomous Island of Anjouan and it is therefore not directly subject to the statutes and regulations governing financial institutions, money transfer services or virtual asset service providers. Gaming services provided by the Company under the valid gambling license and are directed and provided to individuals (the “Customers” or “End Users”).

The Company’s cooperation with its service providers, agents, contractors, external consultants, third-party representatives, business partners, sponsors, etc. (the “Counterparties”) and provision of gaming services to the End Users is transparent, honest and impartial.

Nevertheless, We are fully committed to conducting business with the highest ethical standards and in strict compliance with all applicable to our activity laws, particularly those aimed at preventing money laundering and terrorist financing. Our Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CFT”) Policy sets out the internal policies, procedures, and controls designed to identify and prevent possible risks of money laundering and terrorist financing related to our operations.

The Company has a zero-tolerance approach to money laundering (“ML”) and terrorist financing (“TF”) and is dedicated to complying with all AML and CTF laws in every jurisdiction where Company operates. This Policy reinforces Our shared responsibility to follow global anti-money laundering and counter-terrorist financing regulations and ensures that Our Counterparties and End Users meet the same high standards. We are committed to preventing money laundering, terrorism financing, and any activities that facilitate these illegal actions by upholding all relevant legal requirements applicable to our activities.

Our business activity is conducted in full compliance with the laws of Autonomous Island of Anjouan, Union of Comoros (jurisdiction of Company registration) and other jurisdictions where the Company operates in accordance with the law, while avoiding restricted territories, including those that are blacklisted, high-risk or sanctioned, as outlined in Section 4 of this Policy and Section 6 of Our Terms and Conditions. This Policy and Terms and Conditions may be updated periodically in accordance with applicable legislation of Autonomous Island of Anjouan, Union of Comoros, FATF Recommendations and the laws of other jurisdictions that may include gambling as a prohibited activity in accordance with their domestic laws. The Company independently carries out its B2C activities, serving only the End Users who are not located in restricted territories.

All terms capitalized and not defined in this Policy have the corresponding meanings in the Terms and Conditions of the Company.

This Policy covers:

1. Key business principles of the Company;
2. Company’s compliance framework, based upon its “three lines of defense” operating model: the Customer identification, the Counterparties identification, risk assessment and other AML/CTF policies and procedures, which include the use of appropriate programs that ensure proper verification of the Customers and the Counterparties and ongoing monitoring measures aimed at preventing the Customers from engaging in illegal and unauthorized activities and termination of cooperation with the Customers and the Counterparties in case of detection of illegal and unauthorized activities;
3. An overview and revise of the AML/CTF processes and procedures from time to time depending on legislative requirements;
4. A description of the key programs and systems employed by the Company as part of its AML/CTF program;
5. Verification procedure of the Customers and the Counterparties;
6. Obligations of employees and third-party service providers who may be involved in business activity of the Company on how to recognize activities that may be related to ML and TF; and
7. Obligations of the Company director to observe and uphold AML/CTF measures.

1.2. Money Laundering and Terrorism Financing

Money laundering refers to the process of disguising the origins of illegally obtained funds to make them appear legitimate. It can occur at any stage of a partnership or business relationship. Crimes such as corruption, tax evasion, drug trafficking, organized crime, and embezzlement often generate large profits, which criminals attempt to legitimize by changing the form of the assets or transferring them to different countries to conceal their illicit origin.

AML refers to the legal and financial measures designed to prevent, detect, and report money laundering activities. Regulated entities are required to implement these controls, with a focus on understanding the source and destination of funds, especially in operations involving high-risk factors or regions prone to terrorist financing.

Money laundering occurs whenever assets derived from criminal activities are used or exchanged. The goal is to evade detection by authorities and ultimately convert the illegal proceeds into lawful assets.

Money laundering includes among others:

• Dealing in the proceeds of a crime.
• Dealing in funds to facilitate a crime.
• Concealing the source of illegally obtained money by subsequent transfers so that it appears to have originated from a legitimate source.
• Advising client on how to structure financial operations to avoid reporting and recordkeeping requirements.
• Willfully or recklessly disregarding the source of a Customer’s assets or the nature of a Customer’s or Counterparty’s financial operations.

Money laundering can involve proceeds from a wide range of criminal activities, such as drug trafficking, securities fraud, bank and wire fraud, tax evasion, racketeering, terrorism, export violations, and illegal payments to foreign officials, among others.

The money laundering process typically occurs in three stages:

• Placement: the initial introduction of illicit funds into the financial system, either through physical or financial transactions, by depositing criminal proceeds into financial institutions.
• Layering: this involves separating the illicit funds from their criminal origin by executing multiple transactions to obscure their source. This may include breaking the funds into smaller amounts or engaging in a series of complex transactions to disguise the original source.
• Integration: at this stage, the laundered funds are reintroduced into the economics, appearing as legitimate assets. This process makes the criminal proceeds seem lawful, allowing the launderer to use them fre

1.3. Some Examples of Suspicious Activities which may be ML

Here are some examples of behaviors that may raise suspicions of ML.

While these actions do not definitively indicate ML, they do warrant closer examination:

• A potential Customer or Counterparty is unwilling to provide necessary due diligence documentation.
• A potential Customer or Counterparty presents due diligence documentation that is unusual, inconsistent, or suspicious.
• A potential Customer or Counterparty does not want to undergo additional verification.
• A potential or current Сustomer or Counterparty is reluctant to share in the frame of additional verification the information about the source of wealth and source of funds.
• The Customer makes a deposit and immediately without using it requests a refund of deposit without reason.
• A potential Counterparty refuses to disclose the identity of its ultimate beneficial owner(s) and does not want to provide verification for the identity or residence of its directors or authorized representatives.
• The Counterparty’s ownership of the business often changes over extremely short periods of time without any clear business, economic or legal justification.

1.4. Terrorism Financing

Terrorist acts aim to influence or coerce governments into a specific course of action or to instill fear in the public or segments of it. To carry out these acts, terrorists need financial resources, which can come from both criminal activities (potentially involving elements of money laundering) and legitimate sources, such as donations from charities, lawful businesses, or self-funding by individuals.

TF may include activities such as:

• Handling funds to support terrorist activities.
• Concealing the origin and destination of money through multiple transfers to make it appear legitimate.
• Advising on structuring transactions to evade reporting and record-keeping requirements.
• Willfully or recklessly ignoring the destination of Customer’s assets or the nature of their transactions.
• Assisting in the movement of funds to support terrorism or terrorist organizations.

Money laundering and terrorist financing share several similarities, as both involve covert financial activities, often on a global scale. However, the key difference is that while money laundering seeks to obscure the origins of illicit funds, terrorist financing focuses on concealing the intended use or destination of the funds. Terrorists employ tactics similar to money launderers to avoid detection, protect the identities of their sponsors, and hide the ultimate recipients of the funds. Terrorist financing can involve money from legitimate sources, such as personal donations, business profits, and charitable contributions, as well as from illegal sources, like drug trafficking, arms smuggling, and fraud. To transfer their funds, terrorists may use formal banking systems, informal value transfer networks, and the physical movement of cash, gold, or other valuable assets through smuggling channels.

Detecting transactions related to terrorist financing can be just as difficult, if not more so, than identifying those linked to money laundering. Since acts of terrorism may not require significant funds to plan and execute, the amounts involved can be relatively small and may even come from legitimate sources. As a result, the Company regularly reminds its employees to stay vigilant. Employees are expected to ensure that our Customers and Counterparties are known and identifiable, and that reasonable efforts are made to verify that transactions between the Company, its Customers and Counterparties are legitimate and appropriately justified.

1.5. Some Examples of TF Risks

Terrorist organizations may exploit the online gambling industry to secure funds for planning and executing attacks, training militants, paying personnel, and spreading their ideologies.

Below are some examples of behaviors that may raise suspicion of TF:

• The Customers or the Counterparties are from countries known to support terrorist activities or organizations.
• The Counterparties are using false corporations, including shell companies.
• The Customers or the Counterparties are listed on sanctions lists.

1.6. Objectives

This Policy outlines a comprehensive policy and procedures for risk assessment and management. It details specific steps to evaluate and mitigate the risks related to money laundering and terrorist financing that the Company may face. The Company is fully committed to preventing any involvement in criminal activities or associations with criminal entities.

1.7. Purpose of this Policy

The purpose of this Policy is to present the Company’s AML/CTF policies, framework and controls as well as global AML/CTF policies and procedures in respect of compliance by the Company of AML and CFT requirements.

1.8. Application of this Policy

This Policy applies to all individuals working for or on behalf of the Company in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, and interns. It also extends to the Counterparties, including but not limited to agents, contractors, external consultants, third-party representatives, business partners, sponsors or anyone else associated with the Company, regardless of location.

In any country where the Company operates, local AML/CTF laws and regulations must be adhered to alongside the requirements of this Policy. If local laws are less strict than this Policy, the terms of this Policy should be followed to the extent allowed by local law.

Violations of this Policy may lead to disciplinary action against employees, termination of business relationship with the Counterparties or blocking of the Customers, as applicable. Additionally, breaches of AML/CTF laws may constitute criminal offenses under relevant laws, potentially leading to prosecution.

2. STANDARDS

2.1. KYC and DD Procedures

The Company has implemented Know Your Customer Procedure (“KYC”) for its Customers and Due Diligence Procedure (“DD”) for its Counterparties that are appropriate, proportionate to the nature and size of its business and tailored to its business activities.

The Company carries out KYC on all Customers to mitigate the risks of ML and TF and carries out DD on all Counterparties to mitigate the risks of ML and TF as well.

KYC and DD are the processes of obtaining information to Know Your Customer and Counterparty, as a partner (legal entity) and they may include enhanced KYC measures for the Customers and enhanced DD measures for the Counterparties for both procedures herein defined as “EDD”.

The Company applies EDD on a risk-sensitive basis, taking into account a non-exhaustive list of factors, including the general relationship, the regularity or duration of the business relationship and geography.

2.2. Requirements to Carry Out DD

DD must be carried out:

• Prior to establishing B2B relationship with the Counterparties.
• When there is any suspicion of ML or TF during cooperation with the Counterparties.
• For identifying the beneficial owners of the Counterparties and taking reasonable measures to verify their identity so that the Company knows who the beneficial owners of the Counterparties are.
• For verifying that any person purporting to act on behalf of the Counterparties is authorized to do so and identifying and verifying the identity of that person (authorized representative).
• For assessing and, as appropriate, obtaining information on the purpose and intended nature of the business relationship of the Counterparties.
• For conducting ongoing monitoring of the business relationship, including scrutiny of transactions undertaken throughout the course of the relationship to ensure that the transactions are consistent with the Company’s knowledge of the Counterparties, their business and risk profile and ensuring that the documents, data or information held are kept up-to-date.

2.3. DD Measures

DD Measures Include:

• Identifying the Counterparties, on the basis of provided by them corporate documents and personal documents of their management, official representatives and beneficial owners.

2.4. Accepted Documents within the DD

For the Counterparties:

• Certificate of Incorporation.
• Memorandum and Articles of Association.
• Certificate of Incumbency/Excerpt from Commercial Register.
• Certificate of Good Standing.
• Register of Directors.
• Register of Shareholders.
• Corporate Structure.
• Certificate of Registered Office Address and/or Rental Agreement.
• Personal documents (for each Director, Shareholder, Beneficial Owner, Authorized Representative): proof of ID (international passport/ID card) and proof of residential address (utility bill, bank statements, tax bill, rental agreement up to 3 months old).
• Source of Funds for UBO (bank statement, payslip, income tax return), if necessary.
• Source of Wealth for UBO (investment portfolio, copy of the contract of sale, inheritance contract), if necessary.
• Power of Attorney for Authorized Representative, if applicable.
• Nominee Service Agreement, if applicable.
• Indemnity Letter, if applicable.
• Declaration of Trust, if applicable.

2.5. Requirements to Carry Out KYC

KYC must be carried out:

• After registration by the Customer of their Player’s Account on the Company’s Website.

2.6. KYC Measures

KYC Measures Include:

• Identifying the Customer in accordance with the identification documents provided by them and verifying their identity using these documents and data.
• Monitoring the risk profile linked to the cryptocurrency wallet used by the Customer for their Player’s Account.

2.7. Enhanced Due Diligence

The Company may per its own discretion conduct an Enhanced Due Diligence for the Customers and/or Counterparties if it noticed something suspicious in the documents provided by them or if the Company notices any strange activity of the Customer while using the Services or of the Counterparty during their business relationship.

The Company performs ongoing monitoring of its Customers and Counterparties in order to detect any behaviors or indicators that might raise suspicions in regard to ML and TF activities. For this purpose, the Company has implemented a set of risk indicators that help it identify such behavior and require the Company to conduct an EDD to assess information about the Client and Counterparties.

Whenever one of those risk indicators is triggered, the Player’s Account will be suspended and business relationships with the Counterparties will be put on hold as well, and the Company will then initiate EDD procedures.

EDD measures for the Counterparties include:

• Checking additional independent, reliable sources to verify provided information.
• Gathering further information about the Counterparties to determine the Counterparties’ reputation from publicly available information.
• Examining the background and purpose of the transaction, as far as reasonably possible, and taking steps to be satisfied that the transaction is consistent with the purpose and intended nature of the business relationship between the Company and the Counterparties.
• Taking adequate measures to establish the source of wealth and source of funds that are involved in the business relationships or transactions with the Counterparties.
• Increasing the degree and nature of monitoring of the business relationship in which the transaction is made, to determine whether the transaction appear to be suspicious.
• Re-requesting corporate documents and personal documents of the management, shareholders and UBO(s).

EDD measures for the Customers include:

• Re-requesting identification data of the Customer (full name, place of birth, country of citizenship, country of residence, residential address, tax number, if necessary).
• Re-requesting identification documents (passport copy, ID).
• Receiving information about the Customer from reliable and independent publicly available sources.
• Obtaining information about the Customer’s source of funds and source of wealth, if necessary.

The Company may use the third-party services in order to verify any of the above information provided by the Customer or Counterparties.

The Company will immediately suspend business relationship with the Counterparties who:

• Failed to provide the requested documents and information.
• Submitted fraudulent documents and information.
• Carry out their business activity in restricted or prohibited jurisdictions.
• Have funds originating from restricted jurisdictions.
• Are sanctioned or placed on watch lists from the United States, European Union, or other global authorities.

The Company will immediately terminate the provision of the Services to the Customers and block their Player’s Accounts who:

• Failed to provide the requested identification documents and information.
• Submitted fraudulent identification documents.
• Attempted to deceive regarding their location (using various VPN means or other technical means).
• Are sanctioned or placed on watch lists from the United States, European Union or other global authorities.
• Reside in restricted or prohibited jurisdictions.
• Have funds originating from restricted jurisdictions.
• Have gambling addiction.

The Company reserves the right to block or suspend the Player’s Accounts of the Customers or terminate cooperation with the Counterparties for any other reason at its sole discretion.

2.8. Politically Exposed Persons

A politically exposed person (“PEP”) is an individual who is entrusted with prominent public functions, other than middle-ranking or more junior officials, including the following individuals:

• heads of state, heads of government, ministers, and deputy or assistant ministers.
• members of parliament or of similar legislative bodies.
• members of the governing bodies of political parties.
• members of supreme courts, constitutional courts or other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances.
• members of courts of auditors or of the boards of central banks.
• ambassadors, chargés d’affaires, and high-ranking officers in the armed forces.
• members of the administrative, management, or supervisory bodies of state-owned enterprises.
• directors, deputy directors, and members of the board or equivalent function of an international organization.

Family members of PEP include:

• spouse or a person considered to be equivalent to a spouse.
• children and their spouses or persons considered to be equivalent to a spouse.
• parents.

PEP known to be close associates mean:

• a natural person is known to have joint beneficial ownership of a body corporate or any other form of legal arrangement, or any other close business relations, with that politically exposed person.
• a natural person who has sole beneficial ownership of a body corporate or any other form of legal arrangement that is known to have been established for the benefit of that politically exposed person.

The following measures will apply to mitigate the risks associated with PEP Customers and Contractors:

• Assessment of the risk posed by PEP Customers and Contractors.
• Building the risk profile of the Customers and Contractor including the online and media search.
• EDD measures.
• Enhanced on-going monitoring of Contractors activity.

2.9. Transactions Monitoring

Company is fully committed to adhering to the economic and trade sanctions programs mandated by the jurisdictions where it operates. To support this commitment, the Company has implemented a transaction monitoring program equipped with controls and procedures designed to identify and detect any unusual activity in real-time, as well as during ongoing monitoring.

The Company conducts regular monitoring using both: internally developed rule-based systems and third-party solutions to analyze history of the Customers and Counterparties behavior. This approach aims to detect and report any suspicious activity and to establish any necessary additional controls or limits for the Customers or Counterparties.

The Company has put in place procedures focusing on two essential aspects of managing unusual or suspicious activity:

• Identification of unusual activity: this may occur through inquiries from law enforcement agencies or reports generated by transaction and surveillance monitoring systems.
• Alert management: this involves processes for investigating, assessing, and documenting any identified unusual or potentially suspicious activities.

The Company will implement the following strategies to meet its goals in the frame of transaction monitoring:

• Sanctions Screening: as part of its services, the Company will screen Customers’ wallet addresses against applicable sanctions lists using third-party blockchain forensic services. All cryptocurrency transactions, whether direct or indirect, will be assessed for potential fraudulent or suspicious activities through these partners. If any indication of illegal activity is detected, the Player’s account will be suspended for further investigation. For accounts identified as high-risk, Customers may be required to provide sufficient proof of funds as part of the EDD procedure. Withdrawals to high-risk addresses may be denied after consultation with our risk assessment partners.
• Monitoring for Unusual Activities: the Company will closely monitor account activities to detect any unusual transaction sizes, volumes, patterns, or types, while considering relevant risk factors and warning indicators. Regular reporting will help identify any high-risk or suspicious activity involving the Customers.
• Anti-Mixing Measures: the Company will use specialized software to identify and analyze suspicious transaction patterns related to deposits or withdrawals. Each case will be individually evaluated based on its risk level. Users may be asked to provide clarification regarding their methods and reasons for using the platform under these circumstances.
• KYC Check at Withdrawal Threshold: If the Player’s Account reaches a specific withdrawal threshold, the Customer will be required to pass KYC and/or EDD checks.

The Company also implemented additional monitoring measures as follows:

• Ban Evasion Detection: the Company will utilize specialized software from third-party providers designed to identify the Customers attempting to operate multiple accounts. This software detects connections between accounts accessed using the same devices. Each case will be evaluated individually, taking into account the perceived level of risk. Customers involved in such activities may be required to explain their approach and reasons for using the Website in this manner. The Player’s Accounts are funded by the Customers through either local (non-custodial) wallets or hosted (custodial) wallets. Alongside the third-party provider’s verification, the Company actively monitors Customers activity on the Website, ensuring that all findings align with its own verification processes and those of its third-party service providers.
• IP monitoring system: the Company has implemented a Player IP Monitoring System that detects information about the Customer’s devices in order to prevent the participation of the Customers from prohibited or sanctioned jurisdictions.
• Products and Services Review: the Company will put in place additional measures to prevent the Customers from attempting to misuse the Website for personal gain. It maintains a robust set of Terms and Conditions that all Customers must agree to in order to access the Website. To further reduce the risk of misuse of the Website by the Customers, the Company may introduce special policies or procedures. The use of anonymity-enhancing technologies, such as mixers, tumblers, or certain coins and tokens, is strictly prohibited. If the Company discovers that any Customer is using these technologies to increase the anonymity of access to the Website, they will be immediately blocked.
• Third-Party Service Providers: the Company collaborates with reputable third-party service providers as part of its compliance and verification processes. It will regularly evaluate the effectiveness of these key service providers to determine if additional services or enhancements are necessary. The Company also conducts DD process on its third-party service providers, treating them as the Counterparties under this Policy.

3. EMPLOYEES

3.1. Employees Training

A key element in the Company’s efforts to prevent and detect money laundering is to ensure that its employees are vigilant to the risks of money laundering and terrorist financing. They must be thoroughly trained to recognize unusual activities or transactions that could be considered suspicious.

3.2. Awareness & Expert Training

All employees are required to complete mandatory online AML training as part of their onboarding process. Furthermore, they must participate in refresher training sessions on an annual basis. This training covers relevant AML laws, regulations, as well as the Company’s internal policies and procedures.

4. RESTRICTED TERRITORY

The Company complies with and does not operate in sanctioned or black-listed/high risk jurisdictions as well as in those countries where gambling business is prohibited by law.

The list below is not exhaustive, the list of countries where the Company does not operate is also presented in Section 6 “Know Your Client Policy” of the Terms and Conditions.

• China,
• South Korea,
• Malaysia,
• Indonesia,
• Thailand,
• Vietnam,
• Philippines,
• Saudi Arabia,
• Kuwait,
• Bahrain,
• Oman,
• Jordan,
• Sri Lanka,
• Bangladesh,
• Uzbekistan,
• Turkmenistan,
• Kyrgyzstan,
• Tajikistan,
• Nepal,
• Maldives,
• Brunei,
• Laos,
• Mongolia,
• Armenia,
• Bhutan,
• The United States of America,
• Puerto Rico,
• Greece,
• The United Kingdom (including any overseas territories),
• Isle of Man,
• Jersey,
• Gibraltar,
• Spain,
• France and its overseas territories (Guadeloupe, Martinique, French Guiana, Réunion, Mayotte, St. Martin, French Polynesia, Wallis and Futuna, New Caledonia),
• The Netherlands,
• Curacao,
• Cyprus,
• Israel,
• Lithuania,
• Slovakia,
• Belgium,
• Dutch West Indies,
• Angola,
• Albania,
• Afghanistan,
• Iraq,
• Jamaica,
• Uganda,
• Pakistan,
• Islamic Republic of Iran,
• Panama,
• Lebanon,
• Zimbabwe,
• Mauritius,
• Nicaragua,
• Yemen,
• Central African Republic,
• Côte d'Ivoire,
• Sudan,
• Liberia,
• Syrian Arab Republic,
• Cayman Islands,
• Somalia,
• Congo,
• North Korea,
• Eritrea,
• Haiti,
• Sierra Leone,
• Ethiopia,
• Myanmar,
• South Sudan,
• South Africa,
• Burkina Faso,
• Libya,
• Mali,
• Barbados,
• Rwanda,
• Czech Republic,
• Serbia,
• Cuba,
• Portugal,
• Georgia,
• Hungary,
• Ukraine,
• Estonia,
• Bulgaria,
• Latvia,
• Liechtenstein,
• Poland,
• Romania,
• Turkey,
• Russia,
• Belarus,
• Kazakhstan,
• Australia,
• Bonaire,
• Aruba,
• Austria,
• The Union of the Comoros,
• Germany,
• State of Qatar,
• The United Arab Emirates,
• Japan,
• Singapore,
• St. Eustatius and Saba,
• St. Martin.

All FATF blacklist and all other countries where gambling is strictly prohibited by law.

Except for the above list, the Company constantly follows and adheres to the FATF recommendation list.

5. TERMINATION OF BUSINESS RELATIONSHIPS

To reduce the risk of potential unwitting complicity in money laundering or terrorist financing, We immediately terminate business relationships with our Customers and/or Counterparties if We become aware or suspect that they intend to use the Company’s Services for the purpose of laundering illegal funds or financing illegal activities.

6. REPORTING

The Company is required to report any unusual or suspicious transactions in compliance with the Computer Gaming Licensing Act 007 of 2005 and Anjouan Money Laundering (Prevention) Act 008 of 2005. If the Customer or the Counterparty is identified as being on a sanctions list or associated with money laundering, terrorist financing, or other criminal activities, these cases will be reported as suspicious activities to the Anjouan Gaming Control Board and/or Financial Intelligence Service (SFI) of the Union of the Comoros.

7. SUMMARY

The Company adheres to strict codes of conduct in order to protect the Company’s good standing, to instill trust in the Customers and the Contractors.

In order to comply with regulatory requirements and fulfil its ethical responsibility the Company warrants that it:

• Verifies the Customers and the Contractors prior to establishing a business relationship and providing Services.
• Deals only with the Customers who have registered Account with the Company (the procedure is additionally defined in the Company’s Terms and Conditions).
• Complies with regulatory requirements and industry best practice.
• Does its utmost to ensure that no funds are accepted which originate from illegal activities.
• Prevents all cases when its Services might be used as a tool in ML or TF.
• Ensures effective responsible gambling policies.

The Policy may be amended from time to time to ensure that it remains harmonized with amendments to legislation and other material developments originating from changes in international standards. The Company will notify about amendments to this Policy by posting them on the Website.