Anti-Money Laundering Policy

1. Guiding Laws and Regulations

One Net Group and its affiliate companies believes that in order to protect its reputation, customers and staff, as well as to meet its legal and regulatory obligations, it is of upmost importance to minimize the risk of being used to facilitate money laundering. For this reason the present Policy was elaborated and for the purposes set forth herein “money laundering” also includes “terrorist financing”. This Policy observes the guidelines offered by the, UK Anti-Laundering Regulation/2007, the Recommendations of the Financial Action Task Force on Money Laundering/1996-2003 (FATF-OECD), the European Directive 5th Anti‑Money Laundering Directive which amendments stemmed from the European Commission’s 2016 Action Plan to tackle the use of the financial system for the funding of criminal activities, terrorist financing and the large‑scale obfuscation of funds, as well as the local Law of the Republic of Cyprus in the Prevention and Suppression of Money Laundering Activities Law 188(1)/2007 and the Law 110(1)/2010 on the Suppression of Terrorism and any future enacted legislation on the matter, regardless the subsequent revision date of this Policy.

2. Objective

The Company’s policy on the prevention of money laundering applies to all countries where the Company operates and to all business activities within those countries. It is clear statement to our staff and regulators regarding the Company’s position on this critical issue.

3. Risk Assessment

Despite the “low risk” business classification, encountered in the comprehensive internal audit which the Company has undergone to establish the risk areas and its real potential, the Company decided to execute in writing this Policy to clarify our views and “Control Systems” implemented to mitigate the risk of the occurrence of criminal offenses, and in the unlikely event of that happening, the policy intents to offer sufficient guidance to tackle the problem on an immediate and effective manner.

4. Commitment and Control System

As an organization committed to the prevention of money laundering, we will:

• Establish clear lines of internal accountability, responsibility and reporting. All business areas must ensure that appropriate internal controls are in place and operating effectively, with regular reporting to Mrs. Stephanie Mogharbel, the “Control Officer”, duly appointed by the Board of Directors.
• Document, implement and maintain procedures and controls which interpret the Group Policy and Group Standards compatible with the line of business, in the context of local law and regulations.
• Due to the nature of our business we shall proceed with any financial transactions as, but not limited to, paying or receiving payments only by means of an internationally recognized sound and reputable banking institution. NO CASH PAYMENTS shall be carried out on our commercial transactions unless in exceptional cases with the express approval of the management and with the production and retention of supporting documents which can adequately elucidate the characteristic of such transactions. Despite the characteristic of a “low risk” business, the Company shall make mandatory to apply customer identification procedures and customer due diligence measures in the event that such exceptional transactions amount to EURO 15,000 or more, whether the transaction is carried out in a single operation or in several operations which appear to be linked as described in the CY LAW 188(1)/2007 article 60(b).
• To know our customers and suppliers is of upmost importance to establish a safe business environment. The Company through its local managers shall take all reasonable steps to verify the identity of our customers and suppliers and where appropriate, their respective beneficial owners (e.g. those owning corporate entities or controlling trusts). We will obtain additional “Know Your Customer” (KYC) information according to a risk based approach.
• Establish procedures to retain adequate records of identification, and transactions for a minimum of five years, period also applicable for records relating to staff training, internal compliance monitoring, and suspicious activity reporting.
• Monitor customer/supplier activity to keep our records up to date and to report any activity that may involve or presuppose money laundering. This includes using any sort of attained information, documented or not.
• Suspend any transaction where reasonable grounds exist to suspect that the operation relates to the proceeds of crime or is to be used for an illegal activity such as terrorism.
• Make prompt reports of suspicious activity through the appropriate internal channels and where required, to the relevant regulatory and law enforcement authorities.
• Raise awareness on money laundering prevention and train our staff how to recognize and report suspicious activity without putting their selves in risk and/or jeopardizing an eventual further investigation by the relevant authorities.

5. Reporting the Suspicious Activities

In principle any doubt regarding a specific situation must be immediately reported to the local manager, who shall bring the issue to the Control Officer, but if/ when necessary the report can also be addressed directly to the Control Officer then in charge, who shall carefully assess the situation and collect further information if/when possible to then contact the relevant regulatory and law enforcement authorities if required. Our Company is committed to and shall co-operate with any lawful request for information made by government or law enforcement agencies during their investigations into money laundering.

Declaration

For avoidance of any doubt in regard to the above-mentioned procedures,

I confirm that I have read and understood the present “Anti-Money Laundering Policy”.

Name: / Date:

Limassol, August 2020