AML & Compliance Policy

Growth Market is committed to conducting its business with integrity, transparency and in full compliance with all applicable laws and regulations.

Although Growth Market is not a regulated financial institution, the Company voluntarily adopts internal compliance standards designed to reduce financial crime risks and protect its customers, employees, suppliers, payment partners and business reputation.

This Policy establishes the principles applied by Growth Market to identify, assess, manage and mitigate compliance risks associated with its business activities.

Growth Market is committed to maintaining an effective compliance framework based upon the following principles:

• integrity;
• transparency;
• accountability;
• proportionality;
• confidentiality;
• risk-based decision making;
• continuous improvement.

Compliance forms an integral part of the Company's governance and commercial decision-making.

Growth Market seeks to operate in accordance with all Applicable Laws, including, where relevant:

• Proceeds of Crime Act 2002;
• Money Laundering Regulations 2017 (where applicable);
• UK Sanctions and Anti-Money Laundering Act 2018;
• UK Bribery Act 2010;
• Fraud Act 2006;
• Companies Act 2006;
• Data Protection Act 2018;
• UK GDPR;
• Computer Misuse Act 1990;
• applicable consumer protection legislation;
• international sanctions legislation where relevant to the Company's operations.

Growth Market applies a risk-based approach when assessing customers, projects and commercial relationships. Risk assessments may take into account:

• geographical exposure;
• business sector;
• ownership structure;
• payment methods;
• transaction profile;
• reputational factors;
• public information;
• regulatory exposure;
• sanctions exposure;
• fraud indicators.

The level of due diligence applied shall be proportionate to the level of identified risk.

Where reasonably necessary, Growth Market may perform customer due diligence before accepting or continuing a commercial relationship. Depending upon the circumstances, verification may include:

• legal entity verification;
• identity verification;
• beneficial ownership information;
• corporate registration documents;
• VAT registration;
• business activities;
• source of funds where appropriate;
• proof of authority of authorised representatives.

Growth Market reserves the right to decline or terminate relationships where satisfactory due diligence cannot be completed.

Where Growth Market contracts with corporate entities, it may request reasonable information regarding the individuals who ultimately own or control the organisation.

The Company may refuse to establish or continue relationships where ownership structures are intentionally concealed or cannot reasonably be verified.

Growth Market seeks to avoid conducting business with persons or organisations subject to applicable economic or trade sanctions. Where appropriate, screening may include publicly available sanctions lists issued by:

• HM Treasury;
• OFAC;
• the European Union;
• the United Nations;
• other competent authorities.

Positive matches shall be reviewed before any commercial relationship proceeds.

Growth Market maintains a zero-tolerance approach towards bribery and corruption. No employee, contractor or representative may:

• offer;
• promise;
• authorise;
• request;
• receive; or
• accept

any improper financial or other advantage intended to influence business decisions unlawfully.

Reasonable hospitality and legitimate business gifts may be accepted only where lawful, proportionate and transparent.

Growth Market maintains internal procedures designed to detect and prevent fraud. Examples include:

• identity verification;
• payment verification;
• unusual transaction monitoring;
• invoice verification;
• access controls;
• segregation of duties where appropriate;
• audit logging.

Suspected fraud shall be investigated promptly.

Growth Market reserves the right to refuse Services connected with activities presenting unacceptable legal, regulatory or reputational risks. Such activities may include, without limitation:

• sanctioned persons or jurisdictions;
• fraudulent schemes;
• illegal gambling;
• counterfeit goods;
• deceptive marketing;
• money laundering;
• ransomware operations;
• organised cybercrime;
• terrorist financing;
• any activity prohibited by Applicable Law.

Commercial decisions shall be made on a case-by-case basis following appropriate risk assessment.

Growth Market maintains appropriate records relating to compliance activities for periods required by Applicable Law or internal business needs. Records may include:

• customer due diligence;
• contractual documentation;
• compliance assessments;
• sanctions screening results;
• fraud investigations;
• internal approvals;
• communications relevant to compliance matters.

Records shall be protected against unauthorised access, alteration or destruction.

Employees, contractors and business partners are encouraged to report any suspected unlawful, unethical or suspicious activity without delay. Reports shall be reviewed confidentially and investigated appropriately.

Retaliation against individuals reporting concerns in good faith is strictly prohibited.

Where legally required, Growth Market shall cooperate with:

• courts;
• law enforcement agencies;
• regulatory authorities;
• payment service providers;
• financial institutions; and
• competent governmental bodies.

Any disclosure of confidential information shall be limited to what is required by Applicable Law or lawful request.

Growth Market is committed to maintaining appropriate compliance awareness within the organisation. This Policy shall be reviewed periodically to reflect:

• legislative developments;
• regulatory expectations;
• business evolution;
• emerging financial crime risks;
• technological developments.

Compliance procedures shall evolve on an ongoing basis in line with the Company's risk profile.

Ultimate responsibility for the implementation and oversight of this Policy rests with the Company's management. Management shall ensure that appropriate resources, procedures and internal controls are maintained to support an effective compliance framework.

This Policy shall be governed by the laws of England and Wales. Any dispute arising in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of England and Wales, subject to any mandatory rights under Applicable Law.