AML & KYC Policy

1. Policy Statement

GENURES Technologies OÜ is committed to operating with the highest standards of integrity and to preventing its business from being used for money laundering, terrorist financing, sanctions evasion or other financial crime.

This policy sets out the counterparty-control framework applied by GENURES in connection with its technology trading, brokerage, distribution and procurement activities. GENURES reserves the right to decline, suspend or terminate any transaction or business relationship where satisfactory compliance information cannot be obtained.

2. Counterparty Verification

Prior to entering into a transaction, GENURES may conduct the following verification procedures:

• —Corporate KYC — verification of legal entity, registration and corporate structure
• —Beneficial ownership verification — identification of ultimate beneficial owners
• —Business activity verification — confirmation of legitimate commercial purpose
• —Capacity verification — confirmation of the counterparty's ability to perform
• —Contractual authority verification — confirmation of authorised signatories
• —Sanctions screening — screening against applicable EU, UN, OFAC and other sanctions lists
• —PEP screening — identification of politically exposed persons where applicable
• —Adverse-media screening — review of publicly available negative information
• —Source-of-funds and source-of-wealth checks where legally applicable
• —Transaction screening — review of transaction purpose and structure
• —Enhanced due diligence for high-risk jurisdictions or counterparties

3. Provider Verification

Where GENURES refers to "verified technology providers," verification may include one or more of the following:

• —Corporate registration verification
• —Beneficial ownership verification
• —Business activity verification
• —Capacity and technical specification verification
• —Contractual authority verification
• —Sanctions screening
• —Counterparty risk assessment

Verification does not constitute a guarantee of performance, financial standing or regulatory compliance of any provider. All transactions remain subject to independent verification by the counterparty.

4. Right to Decline

GENURES Technologies OÜ reserves the right to decline, suspend or terminate any transaction, relationship or inquiry where:

• —Satisfactory compliance information cannot be obtained
• —A counterparty is identified on a sanctions or watchlist
• —The transaction structure raises concerns regarding financial crime
• —The source of funds or purpose of the transaction cannot be adequately verified
• —The counterparty fails to provide required documentation within a reasonable timeframe

5. Regulatory Framework

GENURES Technologies OÜ operates in compliance with applicable Estonian and European Union anti-money-laundering legislation, including the EU Anti-Money Laundering Directives as transposed into Estonian law.

Compliance inquiries may be directed to: [email protected]