1. The purpose of this Procedure in NETINNOVATE is to set out the principles and procedure of NETINNOVATE in preventing the introduction into financial circulation of Funds originating from illegal or undisclosed sources and countering the Financing of Terrorism, and in particular:

   1. to lay down rules regarding compliance with applicable anti-money laundering and counter-terrorist financing legislation;

   2. define the obligations of the Employees in the areas referred to in point a. above;

   3. defining the principles for identification and verification of Clients and Transactions;

   4. to lay down rules on notifications to the relevant authorities, including notifications of Transactions.

2. NETINNOVATE ’s internal procedure on countering Money Laundering and Financing of Terrorism applies to all NETINNOVATE Employees.

The phrases used in this Procedure shall mean:

1. AML Officer – An Employee or board member of NETINNOVATE, responsible for ensuring that the activities of NETINNOVATE and its Employees and other persons performing activities for NETINNOVATE comply with anti-money laundering and counter-terrorist financing regulations. The AML Officer is also responsible for, among other things, submitting on behalf of NETINNOVATE the notifications referred to in sections XII - XVI of the Procedure.

2. NETINNOVATE – NETINNOVATE sp. z o.o. with its registered office in Warszawa.

3. Beneficial Owner – any natural person who directly or indirectly controls the Client through the powers he or she possesses as a result of legal or factual circumstances, enabling him or her to exercise decisive influence on the actions or activities undertaken by the Client, or any natural person on whose behalf a business relationship is established or an occasional transaction is carried out, including:

   1. in the case of a legal entity other than a company whose securities are admitted to trading on a regulated market that is subject to disclosure requirements under European Union law or equivalent third-country law:

      1. a natural person who is a shareholder holding more than 25% of the total number of shares in that legal person,

      2. a natural person holding more than 25% of the total voting rights in the governing body of a legal person, also as a pledgee or usufructuary or under agreements with others holders entitled to vote,

      3. a natural person controlling the legal person or legal persons, who together hold more than 25% of the total number of shares in that legal person, or who together hold more than 25% of the total number of votes in the governing body of that legal person, including as a pledgee or usufructuary or under agreements with other holders entitled to vote,

      4. a natural person controlling a legal person through holding powers referred to in Art. 3.1.37 of the Accounting Act of 29 September 1994 (Journal of Laws of 2021, item 217), or

      5. a natural person in a senior position where there is documented impossibility to establish, or doubt as to the identity of the natural persons referred to in the first, second, third and fourth indents, and where there is no suspicion of money laundering or terrorist financing;

   2. in the case of a trust:

      1. founder (settlor), including the founder within the meaning of the Family Foundations Act of January 26, 2023,

      2. trustee, including the member of the management board within the meaning of the Family Foundations Act of January 26, 2023,

      3. a supervisor, if any, including the member of the supervisory board within the meaning of the Family Foundations Act of January 26, 2023,

      4. the beneficiary, including the beneficiary within the meaning of the Family Foundations Act of January 26, 2023, and/or, where the natural persons benefiting from the given trust have not yet been identified, the group of persons in whose main interest the trust was created or operates,

      5. other natural person exercising control over the trust or family foundation,

      6. other natural person having powers or performing duties equivalent to those referred to in indents i. to v. above;

   3. in the case of a natural person acting in the course of his business activity, in respect of whom no indication or circumstances have been found that may indicate control by another natural person or persons, such natural person shall be assumed to be the beneficial owner at the same time.

4. PEP Family Members – it is understood:

   1. a spouse or a person cohabiting with a politically exposed person;

   2. a child of the politically exposed person and his spouse or cohabitant;

   3. parents of a politically exposed person.

5. Directive 2015/849 – Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.

6. Terrorist Financing – means the act defined in Article 165a of the Act of 6 June 1997. - Penal Code.

7. GIIF – General Inspector of Financial Information.

8. Client – a natural person, legal person or organisational unit without legal personality, who intends to conclude or has concluded an agreement with NETINNOVATE concerning the provision of services in the scope:

   1. exchanges between virtual currencies and means of payment,

   2. exchanges between virtual currencies,

   3. brokering the exchange referred to in point (a) or (b),

   4. keeping in electronic form a set of identification data ensuring that authorised persons can use virtual currency units, including carrying out their exchange transactions.

9. MICA – Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets.

10. Monitoring – observation of business relations with the Client, collection or supplementation of information and documentation on the Client, analysis of the Client's Transactions, inter alia: the scale, frequency, types of operations performed on the Account, directions of cash flow, titles of payments, for possible occurrence of suspicious Transactions.

11. Member State – a Member State of the European Union or a Member State of the European Free Trade Association (EFTA) - party to the Contract on the European Economic Area.

12. Persons known to be close associates of PEP – these are:

    1. natural persons who are the Beneficial Owner of a legal person, organizational units having no legal personality or trust together with a PEP or having other close business relations with such a person;

    2. natural persons who are the sole Beneficial Owner of a legal person, organizational units having no legal personality or trust known to have been created for the purpose of obtaining an effective benefit for a PEP.

13. PEP – (Politically Exposed Person) – a natural person occupying prominent public posts or fulfilling prominent public functions, excluding group of middle-ranking or more junior posts, including:

    1. heads of state, heads of government, ministers, deputy ministers, secretaries of state, including the President of the Republic of Poland, the Prime Minister and the Deputy Prime Minister;

    2. members of parliament or similar legislative bodies, including deputies and senators,

    3. members of the governing bodies of political parties;

    4. members of supreme courts, constitutional courts and other high-level judicial bodies, whose decisions are not subject to appeal, except in extraordinary procedures;

    5. members of courts of auditors or of the boards of directors of central banks;

    6. ambassadors, chargés d'affaires and senior officers of the armed forces;

    7. members of administrative, management or supervisory bodies of state enterprises, companies with State Treasury shareholding, in which more than half of the shares belong to the State Treasury or other state legal persons;

    8. directors, deputy directors and members of the organs of international organisations or persons performing equivalent functions in such organisations;

    9. managing directors of supreme and central offices of state authorities and managing directors of voivodeship offices;

    10. other persons holding public office or performing public functions in State bodies or central government administration bodies.

    The list of Polish prominent public posts or fulfilling prominent public functions referred to in points a.-g., i. and j. above, is included in the Regulation of the Minister of Finance, Funds and Regional Policy of July 27, 2021 on the list of national public positions and functions that are politically exposed positions, issued pursuant to Art. 46c of the Act and updated in the Regulation of the Minister of Finance of June 21, 2022 amending the regulation on the list of national public positions and functions that are politically exposed positions and the Regulation of the Minister of Finance of November 20, 2023 amending the regulation on the list of national public positions and functions that are politically exposed positions. Links to the aforementioned Regulations are provided in Annex 3 to the Procedure.

    The list of public positions and functions that are politically exposed positions in other European Union Member States and at the level of international organizations and European Union institutions and bodies is included in the document "Prominent public functions at national level, at the level of International Organisations and at the level of the European Union Institutions and Bodies” (C/2023/724) of 10/11/2023. The link to the aforementioned document is provided in Annex 3 to the Procedure.

14. Financial services provider – an institution which has its registered office outside the territory of the Republic of Poland and conducts on its own behalf and for its own account, on the basis of a permit of a competent state supervisory authority over such an entity, specified activities;

15. Employee – person employed by NETINNOVATE on the basis of an employment contract or a civil law contract, including a B2B contract. A Member Management Board of the NETINNOVATE is also considered an Employee.

16. Money Laundering (ML) – an offence referred to in Article 299 of the Criminal Code Act.

17. Execution of Transactions – the execution by NETINNOVATE of an order or instruction of the Client or a person acting on its behalf.

18. Procedure – this Internal anti-money laundering and counter-terrorist financing procedure at NETINNOVATE.

19. Account – the account referred to in point II.8.d of this Procedure.

20. Regulation 2023/1113 – Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849.

21. Regulation 765/2006 – Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine.

22. Regulation 269/2014 – Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

23. Legal Tender or Funds – legal tender issued by the National Bank of Poland, foreign central banks or other public administration authorities or electronic money.

24. Register – the Central Register of Beneficial Beneficiaries referred to in the Act or the register referred to in Article 30 or Article 31 of Directive 2015/849 kept in the relevant Member State. Polish Central Register of Beneficial Beneficiaries is provided on the website https://www.podatki.gov.pl/crbr/

25. Regulation 910/2014 – Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC.

26. Regulation 833/2014 – Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine.

27. Electronic Identification Mean - an electronic identification mean as referred to in Regulation (EU) No 910/2014.

28. Transaction – shall be understood as a legal or factual act on the basis of which the transfer of ownership or possession of property values is carried out, or a legal or factual act carried out in order to transfer ownership or possession of property values. Aa Transaction should also be understood an Occasional Transaction.

29. Occasional Transaction – means a Transaction that is not carried out within the framework of the Contract (business relationship).

30. Contract – the contract for the provision of services referred to in point II.8.a – d of this Procedure, which NETINNOVATE has concluded with the Client.

31. Act – The Act of 1 March 2018 on Prevention of Money Laundering and Financing of Terrorism (i.e. Journal of Laws 2018, item 723 as amended).

32. Virtual Currency - a digital representation of value that is not:

    1. legal tender issued by the NBP, foreign central banks or other public administration authorities,

    2. an international unit of account established by an international organisation and accepted by individual countries belonging to or cooperating with that organisation,

    3. electronic money within the meaning of the Act of 19 August 2011 on payment services, excluding an electronic money token within the meaning of MICA,

    4. a financial instrument within the meaning of the Act on Trading in Financial Instruments of 29 July 2005,

    5. a bill of exchange, a promissory note or a cheque,

    and it may be exchanged for legal tender and accepted as a medium of exchange in economic transactions, and may be stored or transferred electronically or traded electronically. As a Virtual Currency we also consider crypto-assets within the meaning of MICA.

33. Property Values – property rights or other movable or immovable property, means of payment, financial instruments within the meaning of the Act of 29 July 2005 on trading in financial instruments, other securities, foreign exchange values, crypto-assets and Virtual Currencies;

34. Suspension of Transactions – a temporary restriction on the ability to use of Property Balues by preventing NETINNOVATE from carrying out a specific Transaction or more specific Transactions.

1. Designated Member of Management Board of the NETINNOVATE overseeing anti-money laundering and counter-terrorist financing area:

   1. is responsible for the implementation and performance by NETINNOVATE of the obligations set out in the Act;

   2. supervises the implementation of obligations under the Act;

   3. accepts, after obtaining the opinion of the AML Officer, Clients: PEP, Persons known to be close associates of PEP, PEP Family Members and Clients associated with a high-risk third country as identified in Annex 1 to the Procedure;

   4. approves NETINNOVATE ’s action projects necessary for the proper implementation of NETINNOVATE obligations under the Act;

   5. prepare at least once a year a report on the performance of its own tasks, which it shall submit to the Management Board (if the Management Board consists of more than one person) and the Supervisory Board, by the end of the first quarter following the year to which the report relates;

   6. ensure that the AML Officer prepares and submits the report referred to in point III.2.q of the Procedure;

   7. informs the Management Board (if the Management Board consists of more than one person) immediately of any serious or significant anti-money laundering or/and counter-terrorist financing incidents and violations and of the recommended corrective actions;

   8. ensures that the AML Officer has direct access to all information necessary to perform his/her tasks, has sufficient human and technical resources and tools to adequately perform his/her tasks, is well informed of incidents and NETINNOVATE misconducts;

   9. ensures that the AML Officer is able to contact him (Designated Member of Management Board) directly;

   10. considers and, where appropriate, takes appropriate action on comments made to him by the AML Officer on relevant anti-money laundering and/or counter-terrorist financing issues at NETINNOVATE.

2. AML Officer:

   1. ensures compliance of the activities of NETINNOVATE and its employees and other persons performing activities on behalf of NETINNOVATE with the legal provisions on anti-money laundering and counter-terrorist financing;

   2. review and sign all correspondence sent to supervisory authorities, in particular notifications of suspicious transactions and circumstances that may indicate the suspicion of money laundering or terrorist financing;

   3. draw up periodic reports in the area of Anti-Money Laundering and Terrorist Financing and submit them for approval to the NETINNOVATE Management Board;

   4. give its opinion on training programmes and carry out the training of Employees;

   5. analyses Transactions and monitors business relations with Clients;

   6. typifies circumstances that may indicate a suspicion of Money Laundering or Terrorist Financing offences or Transactions that should be reported to the GIIF or the Prosecutor's Office;

   7. draw up the information and notifications to the authorities, in particular those referred to in points XII to XVI of the Procedure;

   8. reviews and signs all correspondence addressed to the supervisory authorities, including in particular notifications of Transactions (in accordance with the power of attorney to make such declarations granted by NETINNOVATE);

   9. prepares replies to letters/inquiries received from the GIIF or the Prosecutor's Office and other authorities;

   10. accepts Clients: PEP, persons known to be close associates of PEP, family members of PEP and Clients affiliated with a high-risk third country indicated in Annex 1 to the Procedure (if such authority is granted to it by the NETINNOVATE Management Board) and other high-risk Clients;

   11. cooperates with NETINNOVATE anti-money laundering staff;

   12. prepare and deliver anti-money laundering or counter-terrorist financing training programmes;

   13. coordinates the implementation of the mandatory AML and CFT training by Employees;

   14. reviews NETINNOVATE products, services and internal regulations for compliance with generally applicable anti-money laundering and counter-terrorist financing legislation;

   15. verifies the correctness and supervises the completeness of the data collected by the Employees for the identification, verification and acceptance of the Client;

   16. shall be responsible for the Sniuspension of Transactions, freezing of the Property Values, non-provision of the Property Values and execution of orders and demands of competent authorities, in particular GIIF and prosecutor's office

   17. prepare at least once a year a report on the performance of its own tasks, which it shall submit to the Management Board and the Supervisory Board by the end of the first quarter following the year to which the report relates;

   18. be immediately available for a meeting with the GIIF, a public prosecutor or other law enforcement authority;

   19. reports on any material incident to the Supervisory Board and the Management Board;

   20. recommends to the Management Board the corrective measures to be taken in NETINNOVATE in order to eliminate the identified misconduct in the performance of anti-money laundering and/or counter-terrorist financing obligations;

   21. report the need for human or technical resources or the need to implement new measures or solutions to the designated Member of Management Board of the NETINNOVATE overseeing anti-money laundering and counter-terrorist financing area;

   22. regularly reviews the reasons why warnings of unusual activity or Transactions have not been communicated to him/her to determine whether there are issues that need to be addressed to ensure effective detection of suspicious activity or Transactions.

3. Supervisory Board of NETINNOVATE:

   1. shall review the performance reports received from the AML Officer and designated Member of Management Board of the NETINNOVATE overseeing anti-money laundering and counter-terrorist financing area;

   2. may request any information, reports, audits, results of audits, correspondence with government authorities and other data held by NETINNOVATE and relating to the performance of its anti-money laundering and counter-terrorist financing obligations;

   3. shall evaluate at least once a year the effectiveness of NETINNOVATE ’s performance in complying with its anti-money laundering and counter-terrorist financing obligations.

4. Management Board of NETINNOVATE shall:

   1. review and, where appropriate, respond to the performance reports received from the AML Officer;

   2. ensure that the Supervisory Board has access to all information, reports, statements, audit results, correspondence with governmental authorities and other data held by NETINNOVATE and relating to the performance of its anti-money laundering and counter-terrorist financing obligations;

   3. consider and respond to information received about incidents or misconduct at NETINNOVATE.

1. NETINNOVATE:

   1. does not provide payment services or hold Client’s Funds;

   2. does not carry out a transfer of Funds;

   3. does not accept cash deposits or disburse funds in cash;

   4. does not provide correspondent relationship services.

2. NETINNOVATE employees who conduct Clients service must establish the true and current details of Clients intending to enter into an Contract (establish a relationship) with NETINNOVATE and of Clients already using NETINNOVATE services and products.

3. NETINNOVATE employees, in the event that it is found that information about a Client, in particular its Transactions, is not consistent with NETINNOVATE ’s knowledge of the Client in question, its business profile, risks and sources of funds, are obliged to report such transactions to the AML Officer.

4. NETINNOVATE does not offer products or services that allow to remain anonymous by Client.

5. The provisions of the Procedure relating to the Supervisory Board shall only apply if there is a Supervisory Board in NETINNOVATE.

6. Each NETINNOVATE Employee shall promptly make available to the AML Officer any information and documents that the AML Officer requests for the purpose of performing his/her duties under the Procedure. The decision as to what information and documents the AML Officer must have access to rests solely with the AML Officer.

7. The rules for reporting by Employees of actual or potential violations of AML and terrorist financing regulations are described in "Procedure on Reporting Persons at NETINNOVATE sp. z o.o.". The requirements for fulfilling the obligations under Regulation 2023/1113 and the requirements of the Act regarding the risk associated with transfers of Crypto-Assets from a self-hosted address or to a self-hosted address are described in the “Procedure for the implementation of obligations under Regulation 2023/1113 (Travel Rule)”.

1. NETINNOVATE applies the financial security measures (called in Directive 2015/849 as due diligence measures) indicated in this section.

2. Financial security measures include:

   1. identification of the Client and verification of his identity;

   2. identifying the Beneficial Owner and taking reasonable steps to:

      1. verification of his identity,

      2. determine the ownership and control structure in the case of a Client that is a legal person, an organizational unit having no legal personality or a Trust;

   3. assessing the business relationship with Client and, as appropriate, obtaining information on its purpose and intended nature;

   4. ongoing monitoring of the Client's business relationships including:

      1. an analysis of transactions undertaken throughout the course of business relationships to ensure that the transactions are consistent with NETINNOVATE ’s knowledge of the Client, the nature and scope of its business and consistent with the Money Laundering and Terrorist Financing risks related to that Client;

      2. investigation of the source of origin of Property Values at the disposal of the Client - where justified by the circumstances;

      3. ensuring that the documents, data or information in its possession relating to the business relationship with the Clients are kept up to date.

3. Financial security measures shall be applied in particular in the following cases:

   1. establishment of business relationships (conclusion of the Contract);

   2. carrying out Occasional Transactions:

      1. with a value of EUR 15 000 or more, irrespective of whether the transaction is carried out in a single operation or in several operations which appear to be linked (Related Transactions), or

      2. which is a Transfer of Funds for an amount exceeding the equivalent of €1,000;

      3. with the use of a Virtual Currency equivalent to the amount of EUR 1,000 or higher, regardless of whether the Transaction is carried out as a single operation or several operations that appear to be linked;

   3. a suspicion of Money Laundering or Terrorist Financing;

   4. doubts about the accuracy or completeness of the Client's identification data obtained so far;

   5. in relation to Clients with whom NETINNOVATE has a Contract, taking into account the identified risks of Money Laundering and Terrorist Financing, in particular when:

      1. there has been a change in the previously determined nature or circumstances of the business relationship;

      2. there has been a change in the previously determined details concerning the Client or the Beneficial Owner;

      3. NETINNOVATE was obliged by law during the calendar year in question to contact the Client in order to verify the information concerning the Beneficial Owners.

4. Where one of the measures referred to in section V.3 of this Procedure cannot be applied, NETINNOVATE:

   1. does not establish business relationship (does not conclude a Contract);

   2. not carry out a Transaction, including an Occasional Transaction;

   3. dissolves business relationship (terminates the Contract).

5. NETINNOVATE assesses whether the inability to apply financial security measures, constitutes grounds for a notification to the GIIF about:

   1. of circumstances that may indicate the suspected commission of Money Laundering or Terrorist Financing offences; or

   2. the case of a reasonable suspicion that a specific Transaction or specific Property Value may be connected with Money Laundering or Terrorist Financing.

6. The financial security measures applied to the Client depend on the risk class assigned to the Client. The risk classes are described in section VIII ot this Procedure.

7. Whenever the Procedure refers to the investigation of the source of Property Values, this investigation shall be carried out, inter alia, on the basis of the Client's statements, the AML Officer's own analysis (e.g. based on publicly available sources, press articles), documents provided by the Client and originating from a reliable and independent source (e.g., bank statements, financial statements, tax returns, notarial deeds, etc.).

8. NETINNOVATE documents electronically or in writing the financial security measures applied and the results of the ongoing analysis of the Transactions carried out, including by archiving copies or scans of documents, including identity documents, provided or received from the Client.

1. The identification of the Client's identity is carried out in particular:

   1. prior to the establishment of a business relationship with the Client (prior to the conclusion of the Contract);

   2. before the execution of the Occasional Transaction;

   3. in case of suspicion of Money Laundering or Terrorist Financing;

   4. doubts about the accuracy or completeness of the Client's identification data obtained so far.

2. Identification of the Client's identity consists in determining the following:

   1. in the case of a natural person:

      1. forename and surname,

      2. citizenship,

      3. the number entered in the Universal Electronic System for Civil Registration (PESEL) or the date of birth - in the case where no PESEL number has been assigned and the country of birth,

      4. the series and number of the person's identity-proving document,

      5. the address of residence - if NETINNOVATE has this information,

      6. name (business name), tax identification number (NIP) and address of the main place of business - in the case of a natural person concluding the Contract in connection with its business activity;

   2. in the case of a legal person or an organisational unit without legal personality:

      1. name (company),

      2. organisational form,

      3. the address of the registered office or the address of conducting business,

      4. tax identification number (NIP) or, failing that, the country of registration, the name of the competent register and the number and date of registration,

      5. the name, surname, the number entered in the Universal Electronic System for Civil Registration (PESEL) or the date of birth - in the case where no PESEL number has been assigned and the country of birth, of the person representing that legal person or organisational unit without legal personality.

3. Identification of the person authorised to act on behalf of the Client includes establishing the data referred to in section VI.1.a.i – iv. of the Procedure.

4. Verification of the identity of the Client and the person authorised to act on his behalf consists in confirmation of the established identification data on the basis of an identity-proving document, a document containing valid data from an extract from the relevant register or other documents, data or information from a reliable and independent source including, where available, Electronic Identification Means or relevant trust services as defined in Regulation 910/2014. Verification is performed by the AML Officer reading a copy of the identity document or other documents, data or information from a reliable and independent source. In cases where an Contract is concluded or an Occasional Transaction is ordered without the physical presence of the Client and a person authorised to act on his behalf, their verification shall be based on the Electronic Identification Means referred to in Regulation (EU) No 910/2014. If it is not possible to use these Electronic Identification Means, the verification of the identity of the Client and the person authorised to act on his behalf consists in confirming the established identification data on the basis of an identity-proving document stating the identity of that person and additionally on the basis of a second identity-proving document or other documents, data or information from a reliable and independent source (e.g. on the basis of a driving licence, utility bills from reliable suppliers, information from the Register of Personal Documents, CEiDG, KRS).

5. In the event that the Client refuses to provide an identity-proving document or other documents necessary to complete the identification and verification process or refuses to provide or make copies of these documents - the conclusion of the Contract or any other instruction of the Client cannot be carried out.

6. In the event of the mutual physical presence of an Employee and a Client who is a Polish citizen, identification and verification of the Client may take place using the mObywatel document, i.e. a mobile document confirming the identity and Polish citizenship of the user of the mObywatel application on the territory of the Republic of Poland in relations of mutual physical presence of the parties. Identification and verification using the mObywatel document takes place at the Client's request and should be performed in this way, unless there are contraindications or doubts regarding this document or the Client. The Employee shall verify the mObywatel document by verifying at least the data of this document visually and, if possible, also through a qualified certificate attached to this document or using the mWeryfikator application.

7. NETINNOVATE does not accept the conclusion of Contracts with Clients of unknown identity or the execution of Occasional Transactions commissioned by such persons - the establishment of cooperation with an anonymous Client or a person providing fictitious data is prohibited.

1. The Employee is obliged to identify and verify the Real Beneficiary.

2. Identification and verification of the Beneficial Owner involves establishing and verifying the following data:

   1. forename and surname;

   2. in addition, where possible, other identifying data such as:

      1. nationality, the series and number of the person's identity-proving document, address, country of birth, PESEL and if no PESEL, date of birth and country of birth

      2. determining the structure of ownership and control - in the case of a Client which is a legal person or organisational unit without legal personality or a trust. In the case of Clients classified as higher risk, determination of the ownership and control structure is mandatory.

3. The verification of the Beneficial Owner consists in checking and confirming his/her data collected for identification purposes and takes place prior to the conclusion of the Contract with the Client or prior to the execution by NETINNOVATE of an Occasional Transaction or during the term of the Contract, in particular in the event of changes in ownership on the part of the Client.

4. If it is established, during the identification and verification process, that the Client is controlled by a legal person or an organisational unit, the search shall continue until the natural person or persons who are the Beneficial Owner have been identified.

5. If after conducting an investigation it turns out that it is not possible to identify the Beneficial Owner e.g. due to dispersed ownership structure (e.g. there are 5 shareholders, who are natural persons, each holding 20% of shares), NETINNOVATE shall only identify as Beneficial Owner natural persons holding managerial positions at the Client (usually members of the Management Board). In the event that only natural persons holding managerial positions at the Client are identified as the Beneficial Owners, the AML Officer shall document and file:

   1. all impediments causing lack of possibility of determining or doubts as to the identity of the natural persons specified in point II.3.a.i. – iv of this Procedure, including what steps NETINNOVATE has taken to establish the Beneficial Beneficiary and what information and sources indicate that there is no Beneficial Owner other than a natural person in a managerial position;

   2. all impediments related to justified activities undertaken to verify the identity of the Beneficial Owner, including those activities taken.

6. The determination of the Beneficial Owner in the manner described in Section VII.5 of the Procedure may only take place if NETINNOVATE does not identify any suspicion of Money Laundering or Terrorist Financing. In particular the determination of the Beneficial Owner in this manner may not take place if the Client has been assigned a higher risk rating by NETINNOVATE.

7. With regard to Clients who are natural persons, if no indication or circumstances have been established that may indicate that another natural person or natural persons controls the Client, such Client shall be deemed to be the Beneficial Owner. This also applies to natural persons carrying out business activities. It does not apply to incapacitated persons and minors, where the all impediments related to justified activities undertaken to verify the identity of the beneficial owner is their legal guardian, as well as to cases where circumstances indicate that the natural person is not acting on his/her own behalf - in such case the identification of the person on whose behalf the Client is acting should be done.

8. Verification of Beneficiary Owners of the legal persons, organisational units without legal personality, civil partnerships and natural persons conducting economic activity shall be carried out on the basis of at least one of the following documents or sources of information:

   1. the articles of association;

   2. an extract from the national court register or a certificate of entry in the business register, including those made available on external websites;

   3. an extract of information from an official database which is generally accepted and used in business and which is a reliable and independent source of information;

   4. identity-proving documents;

   5. notarised documents;

   6. Electronic Identification Means or using the relevant trust services as defined in Regulation 910/2014;

   7. information from the Registry, subject to Section VII.9 of the Procedure.

9. If NETINNOVATE enters into a business relationship (conclusion of an Contract) or carry out an Occasional Transaction with an entity that is:

   1. a general partnership;

   2. a limited partnership;

   3. a limited joint-stock partnership;

   4. a limited liability company;

   5. a simple joint stock company;

   6. joint-stock companies, exclusive of public companies within the meaning of the Act of 29 July 2005 on Public Offer and the Conditions of Introducing Financial Instruments to the Organized Trading System and on Public Companies;

   7. the trusts whose trustees or persons holding equivalent positions have their place or residence or seat within the territory of the Republic of Poland or establish business relationships or acquire immovable property within the territory of the Republic of Poland in the name or on behalf of the trust;

   8. professional partnerships;

   9. a European Economic Interest Grouping;

   10. a European company;

   11. a cooperative society or a European cooperative society;

   12. an association subject to registration in the National Court Register;

   13. foundation;

   14. another entity which is subject to the obligation to register information on Beneficial Beneficiaries in the Register pursuant to the provisions of a Member State issued on the basis of Article 30 or Article 31 of Directive 2015/849.

   NETINNOVATE shall obtain confirmation of the registration of that entity in the Register or an extract from the Register itself or through the Client. The identification and verification of the Beneficial Owner as well as the determination of the ownership structure of the Client cannot be carried out solely on the basis of information from the Register.

10. If the Employee identifies a discrepancy between the information collected in the Register and the established information about the Client's Beneficial Owner, the Employee shall inform the AML Officer. The AML Officer in such a situation must record the discrepancy found (e.g. in a special register or file kept by the AML Officer for this purpose) and contact the Client to explain the reasons for the discrepancy. In the event that the information or documents obtained from the Client confirm the discrepancies or NETINNOVATE does not obtain from the Client information or documents enabling it to conclude that the data entered in the Register are correct, the AML Officer must immediately provide the Minister competent for public finance with verified information about the discrepancies, together with justification and documentation of the discrepancies noted. If possible, the information referred to in the previous sentence shall be transmitted through the relevant functions of the Registry on its webpage.

1. NETINNOVATE ensures that financial security measures are applied to Clients by analysing and identifying the risks of Money Laundering and Terrorist Financing associated with the business relationship or Occasional Transaction concerned, taking into account, in particular, factors relating to:

   1. type of Client;

   2. geographical area, including the country of origin of the Client;

   3. the nature of the product and services offered and how the Contract is concluded;

   4. the value of the Transactions carried out;

   5. purpose, regularity or duration of the business relationship (Contract).

   NETINNOVATE also takes into account the risk factors identified in the "EBA Guideliens on client due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions (‘The ML/TF Risk Factors Guidelines’) under Articles 17 and 18(4) of Directive (EU) 2015/849", and in particular in Guideline XXI of the above-mentioned Guidelines.

2. Based on its assessment, NETINNOVATE assigns risk ratings - reduced, normal, increased, unacceptable - and applies financial security measures, simplified, normal or enhanced, as appropriate.

3. NETINNOVATE qualifies as an unacceptable the Client:

   1. which is located at (or its Beneficiary or an authorised representative of the Client):

      1. European Union sanctions list or is otherwise covered by the sanctions of the European Union (e.g. under Regulation 833/2014, Regulation 269/2014 and/or Regulation 765/2006),

      2. least at one list announced by the GIIF (among those indicated in Article 118 of the Act),

      3. list of persons and entities subject to sanctions kept by the minister responsible for internal affairs under the Act on special solutions in the field of counteracting supporting aggression against Ukraine and serving to protect national security;

   2. with whom the business relationship (Contract) has been terminated for reasons of Money Laundering or Terrorist Financing,

   3. to which financial security measures cannot be applied;

   4. being a resident or having its nationality, domicile or seat in a non-acceptable third country, as indicated in Annex 1 to the Procedure.

4. In the event of an unacceptable Client, NETINNOVATE shall not establish business relations, terminate existing ones or not carry out Transactions, including the Occasional Transaction.

5. NETINNOVATE considers the following to be higher risk Clients:

   1. Client in relation to which an enquiry has been received from a regulator or law enforcement agency;

   2. a Client against whom a notification has been submitted to the GIIF or a public prosecutor's office;

   3. a Client who is a PEP, a person known to be a close associate of the PEP or PEP family members;

   4. Clients behaving in a suspicious manner, e.g. taking economically incomprehensible actions;

   5. Clients who are resident or have their nationality or domicile in a high-risk third country as listed in Annex 1 to the Procedure or where the person authorised to act on behalf of the Client or Beneficiary Owner of the Client is a national or resident of such country, as well as Clients who primarily carry out their commercial or professional activities in such country;

   6. Client with whom the Contract has been concluded by means of distance communication, unless the identity and data of the Client and persons authorised to act on behalf of the Client have been verified on the basis of an identity-proving document and additionally on the basis of other documents, data or information from a reliable and independent source or on the basis of an Electronic Identification Mean;

   7. Client that, in NETINNOVATE ’s assessment (based on separate analyses carried out by the AML Officer), generates an increased risk of Money Laundering or Terrorist Financig;

   8. Client conducting business in at least one of the sectors indicated in Annex 2 to the Procedure;

   9. Client who is a national of a third country and who and applies for a right to stay or citizenship in a Member State in exchange for capital transfers, immovable property acquisition or Treasury bonds or, as the case may be, investments in corporate entities in a given Member State;

   10. Client who, to the best of NETINNOVATE 's knowledge, has been subject to penalties in connection with Money Laundering, Terrorist Financing or corruption, or is subject to proceedings that may result in such penalties.

6. NETINNOVATE applies enhanced financial security measures to Clients classified as increased (higher) risk, in particular by:

   1. obtaining additional information on the Client, including from external institutions, information available in the media and public databases. Examples of the type of information NETINNOVATE may seek include:

      1. the nature of the Client’s business or employment;

      2. the source of the Client’s Property Value and the source of the Client’s funds that are exchanged for Virtual Currency to be reasonably satisfied that these are legitimate;

      3. the source of the Client’s Virtual Currency that are being exchanged for Legal Tender, including when and where they were purchased;

      4. the purpose of the Transaction, including, where appropriate, the destination of the Virtual Currency Transaction;

      5. information on any associations the Client might have with other jurisdictions (headquarters, operating facilities, branches, etc.) or individuals who are known to exercise a significant influence on the Client’s operations;

      6. to request or obtain data about the client’s Virtual Currency Transactions;

   2. obtaining regular information from the Client as to whether his/her identification data, the data of the Beneficiaries in Kind and the submitted documents are up-to-date;

   3. an enhanced assessment of the business relationship with that Client and obtain information on its purpose and intended nature;

   4. verify periodically, and at least every 6 months, the identification data held on the Client and Beneficial Owner, in particular on the basis of publicly available sources;

   5. enhanced monitoring of the Transactions carried out by the Client through periodic reviews, at least every 6 months;

   6. obtain evidence about the source of funds, the source of Propery Value or the source of Virtual Currency in respect of those Transactions that present a higher risk;

   7. where a Client has multiple distributed ledger addresses or blockchain networks, the NETINNOVATE should link these addresses to the Client;

   8. increase the frequency of monitoring of the Clients’s IP addresses and checking them against the IP addresses used by other Clients;

   9. obtain confirmation about the Client’s level of knowledge and understanding of Virtual Currency to achieve a level of assurance that the Client is not used as a money mule;

   10. increased day-to-day monitoring of business relationship, including;

       1. analysing the Transactions carried out in the course of the business relationship in order to ensure that the Transactions are in accordance with NETINNOVATE ’s knowledge of the Client, the type and scope of its business and consistent with the Money Laundering and Terrorist Financing risks associated with that Client;

       2. obtain information on the sources of the Client's funds and Property Value in order to verify that they do not come from an illegal source;

       3. more frequent review and updating of documents, data and information relating to its business relationship with the Client, to keep them up to date;

       4. conducting periodic reviews of Client information with increased frequency.

7. The conclusion of an Contract with a Client classified as a increased-risk group requires the approval of the Member of the Management Board supervising the AML and CFT area or an AML Officer.

8. A Client who does not meet the criteria for increased or unacceptable risk qualifies for the normal risk group.

9. In the event that the Client is:

   1. a resident of a European Union Member State, a member state of the European Free Trade Association (EFTA) - party to the Contract on the European Economic Area;

   2. a resident of a third country which has been identified by reliable sources as a country with a low level of corruption or other criminal activity;

   3. a resident of a third country where there is, according to reliable sources, anti-money laundering and counter-terrorist financing legislation in force that is equivalent to that resulting from the European Union's anti-money laundering and counter-terrorist financing legislation;

   and other circumstances do not indicate a higher risk associated with the Client in question, NETINNOVATE may assign such Client a reduced risk class and apply simplified financial security measures taking into account the assessment of the risk of Money Laundering or Terrorist Financing, consisting, inter alia, of less frequent actions as part of the ongoing Monitoring of the Client's business relations.

10. NETINNOVATE does not apply simplified financial security measures in case of suspicion of Money Laundering or Terrorist Financing and doubts about the accuracy or completeness of the Client's identification data obtained so far.

11. The decision to grant a reduced risk level is made solely by the AML Officer on the basis of the documentation gathered during the verification of the Client.

12. The risk rating assigned at the acceptance stage may be modified by the AML Officer's decision in the course of verifying the Client or the nature of the Transactions executed by the Client.

13. On an ongoing basis, all NETINNOVATE Clients, persons authorised to act on behalf of the Client and their Beneficiary Owners, are checked against the sanction lists referred to in Section VIII.3.a of the Procedures. The current websites containing sanction lists are contained in Annex 3 to the Procedure.

14. The risk rating of a Client assigned at the Client's acceptance stage may be modified by the AML Officer's decision in the course of verifying the Client or the nature of the Transactions executed by the Client. The AML Officer shall re-verify the Client no less frequently than:

    1. once every 3 years in the case of a normal or reduced risk Client;

    2. once every 2 years in the case of a increased-risk Client.

15. In the event that the AML Officer becomes aware of a material change on the part of the Client that may alter the risk group assigned to the Client, the AML Officer shall immediately reassess the Client's risk.

16. NETINNOVATE documents the identified Money Laundering and Terrorist Financing risks associated with the business relationship and its assessment.

1. In order to determine whether the Client, or its Beneficiary Owner, is a PEP, a Person known to be a close associate of the PEP or a PEP Family Member, NETINNOVATE collects a statement from the Client obtained during the process of concluding the Contract. The statement is collected in written or electronic form. NETINNOVATE may establish the above information also on the basis of other sources, in particular if it suspects the accuracy of the Client's statement. The declaration must contain the following clause: “I am aware of the penalty of perjury”. This clause replaces a notice of penalty of perjury. The AML analyst is responsible for verifying the above statement.

2. In the event that NETINNOVATE determines that the Client is a PEP, a Person known to be a close associate of the PEP or a PEP Family Member, then the consent to enter into an Contract with that Client or the consent to execute an Occasional Transaction of such Client must be given by the Board Member overseeing the AML and Terrorist Financing area or the AML Officer. Until such consent is obtained, the process of concluding the above mentioned Contract or executing the Occasional Transaction shall be suspended. The aforementioned consent shall be granted via e-mail or in writing.

3. Once a year a review of Clients is carried out to investigate whether they are or have become a PEP, a Person known to be a close associate of a PEP or a PEP Family Member.

4. With respect to a Client who is a PEP, a Person known to be a close associate of the PEP or a PEP Family Member, in addition to the usual financial security measures, NETINNOVATE:

   1. apply adequate measures in order to establish the source of the Clients's funds and source of origin of the Property Values at the Client's disposal as part of business relationships or Transactions;

   2. apply enhanced financial security measures.

5. NETINNOVATE shall apply the above measures within 12 months after the Client ceases to be a PEP, a Person known to be a close associate of a PEP or a PEP Family Member. After this period, NETINNOVATE, depending on the individual risk assessment of the Client concerned, may continue to apply these measures.

1. As part of the ongoing Monitoring of the Client's business relationships, NETINNOVATE:

   1. carries out an analysis of the Transactions carried out in the course of the business relationship to ensure that the Transactions are consistent with NETINNOVATE ’s knowledge of the Client, the type and scope of its business and consistent with the Money Laundering and Terrorist Financing risks associated with that Client,

   2. undertakes investigation of the source of origin of the Property Values held by the Client - if justified by the circumstances,

   3. ensures that the documents, data or information held concerning the business relationship with Client are kept up to date.

2. Transactions of which the NETINNOVATE Employee becomes aware about and about which he has doubts shall be reported to the AML Officer. The AML Officer reviews them and, if he/she has doubts, decides whether to inform the GIIF or the Prosecutor's Office about them in accordance with further sections of the Procedure.

3. In the case of Transactions:

   1. complex or

   2. of high amounts which are not justified by the circumstances of the Transaction; or

   3. carried out in an unusual manner, or

   4. which seem not to have legal or business grounds,

   these Transactions should be immediately reported to the AML Officer. The AML Officer shall take action in order to explain the circumstances in which these Transactions were conducted and, in the event of Transactions conducted as part of business relationships, the NETINNOVATE shall intensify the monitoring of the ongoing business relationship with the Client, including its Transactions. Where a pattern of withdrawals or redemptions is not in line with the Client’s profile or the nature and purpose of the business relationship, the NETINNOVATE should add additional measures to ensure that a withdrawal or redemption is requested by the Client and not by a third party.

4. In terms of Monitoring Transactions AML Officer:

   1. collect information useful for identifying Transactions potentially used for Money Laundering or Terrorist Financing;

   2. shall conduct ongoing analysis of the executed Transactions. The results of the analysis are documented on paper or electronically. This analysis consists of the ongoing monitoring of the business relationship with the Client, including the examination of the performed Transactions to ensure that the performed Transactions are consistent with NETINNOVATE ’s knowledge of the Client and its profile.

5. Examples of criteria used by the AML Officer in analysing Transactions:

   1. the frequency of Transactions;

   2. the number of Transactions;

   3. the titles of the Transactions, the type of Transaction;

   4. the parties to the Transaction, the directions of transfer;

   5. the value of the Transaction;

   6. the date the Transaction takes place;

   7. the period during which the Transactions were executed;

   8. the existence of an economic justification for the Transaction;

   9. the duration of the business relationship with the Client.

6. When analysing and selecting suspicious Transactions, Employees shall look for signs of Money Laundering or Terrorist Financing, such as

   1. ambiguous transactions - Transactions whose circumstances are ambiguous in an economic and financial context;

   2. unusual Transactions - Transactions which are not similar to other Transactions carried out by a given Client, e.g. not related to the scope of its activity, not in line with the Client's profile;

   3. extraordinary Transactions - Transactions ordered by the Client, carried out in an expensive manner, economically not justified;

   4. suspicious Transactions - transactions which usually involve activity that is inconsistent with the known and documented nature of the Client's business.

7. If it is necessary to update documents, data or information regarding the business relationship with the Client (e.g. as a result of changes in the Client 's ownership, changes in the Client 's data, changes affecting risk factors), the AML Officer shall request the Client to provide them. If the Client fails to provide them within the required timeframe the AML Officer shall decide whether to continue the business relationship (Contract) with the Client. If necessary, after receiving the documents, data or information, the AML Officer shall reapply the appropriate financial security measures to that Client.

8. The results of the analyses shall be kept for a period of 5 years from the date on which they are carried out.

1. If it is determined that the business relationship (Contract) with a given Client or a Transaction (Transactions in or out, including an Occasional Transaction) of that Client, is related to a high-risk third country, as indicated in Annex 1 to the Procedure, the AML Officer:

   1. obtains additional information about the Client, the Client's Beneficiaries and the intended nature of the business relationship (Contract);

   2. obtains information on the source of the funds of the Client and the Beneficial Owner and the source of the Property Value at the disposal of the Client and the Beneficial Owner within the framework of a business relationship or a Transaction;

   3. obtain information on the reasons for and circumstances of intended or executed Transactions;

   4. intensifies the use of ongoing Monitoring of the business relationship (Contract) with the Client, by increasing the number and frequency of monitoring of the business relationship and by increasing the number of Transactions selected for further analysis.

2. Business relationship or Transaction always involves a high-risk third country, as indicated in Annex 1 to the Procedure, if:

   1. the Funds or Virtual Currency were generated in a high-risk third country;

   2. the Funds or Virtual Currency are received from a high-risk third country;

   3. the destination of Funds or Virtual Currency is a high-risk third country;

   4. the Client is resident or is established in a high-risk third country; or

   5. Trustee of the Client is established in a high-risk third country or Client is a trust governed under the law of a hig- risk third country.

   The AML Officer should also consider whether the Business Relationship or Transaction is linked to a high-risk third country, as indicated in Annex 1 to the Procedure, where it is known that the Client or its Beneficial Owner has close personal or professional ties to a high-risk third country.

3. The information referred to in section XI.1 of the Procedures, the AML Officer shall obtain prior to the conclusion of the Contract or executing the Transacion, and if NETINNOVATE becomes aware of the aforementioned fact of being associated with a high-risk third country after the conclusion of the Contract or executing the Transaction, then immediately after becoming aware of this information.

4. If it is determined that the business relationship (Contract) with a given Client, or the Transactions of that Client, are related to a high-risk third country, as indicated in Annex 1 to the Procedure, the establishment of a business relationship (Contract) or the continuation of a business relationship (Contract) requires the approval of the Member of the Management Board overseeing the AML and CFT area or the AML Officer.

5. In the event that it is determined that a Transaction of this Client, is related to a high-risk third country, indicated in Annex 1 to the Procedure, the AML Officer, in addition to the actions indicated in point XI.4 of the Procedure, must:

   1. take additional action under the enhanced financial security measures referred to in Section VIII.7 of the Procedure;

   2. implement intensified obligations relating to the provision of information or reporting of Transactions. In particular, the AML Officer should request information on more Transactions of a given Client to be provided to him and examine the necessity of providing information on these Transactions to the GIIF or the Prosecutor's Office in accordance with points XIII, XV and XVI of the Procedure.

   In the aforementioned case, NETINNOVATE also restricts the business relationship or Transactions with given Client.

6. NETINNOVATE does not conclude the Agreement and/or provide Accounts for Russian citizens or natural persons residing in Russia or legal persons, entities or bodies established in Russia. NETINNOVATE also does not cooperate in the performance of its services with legal persons, entities or bodies providing the service of maintaining Accounts;

   1. directly or indirectly owned by Russian nationals or natural persons residing in Russia;

   2. directly or indirectly controled by Russian nationals or natural persons residing in Russia controlled by Russian citizens or natural persons residing in Russia;

   3. in which governing bodies Russian citizens or natural persons residing in Russia hold any posts.

7. Points XI.6 of the Procedure shall not apply to:

   1. a Client and/or natural person who is a national of a Member State, a member state of the European Economic Area or Switzerland;

   2. a Client and/or natural who has a temporary or permanent residence permit in a Member State, a country that is a member of the European Economic Area or in Switzerland.

8. NETINNOVATE shall not execute or participate in any Transaction (outgoing or incoming, and if they occur, including the receipt of an incoming transaction, special restrictive measures shall be applied to them in accordance with point XVIII of the Procedure):

   1. with a legal person, entity or body established in Russia, which is publically controlled or with over 50 % public ownership or in which Russia, its Government or Central Bank has the right to participate in profits or with which Russia, its Government or Central Bank has other substantial economic relationship, as listed in Annex XIX to the Regulation 833/2014;

   2. with a legal person, entity or body established outside the European Union whose proprietary rights are directly or indirectly owned for more than 50 % by an entity listed in Annex XIX to the Regulation 833/2014;

   3. with a legal person, entity or body acting on behalf or at the direction of the entity referred to in point XI.8.a and point XI.8.b of the Procedure;

   4. related to the management of reserves as well as of assets of the Central Bank of Belarus, including Transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Belarus;

   5. related to the management of reserves as well as of assets of the Central Bank of Russia, including Transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia, such as the Russian National Wealth Fund;

   6. with a legal person, entity or body established outside of the Union that is a credit or financial institution or an entity providing crypto assets service as listed in Annex XLV to the Regulation 833/2014, and/or a legal person, entity or body acting on behalf or at the direction of an aforementioned legal person, entity or body;

   7. directly or indirectly relating to provision of financing or financial assistance related to the goods, services and/or technology referred to in regulations, provisions and/or decisions issued by the authorities of the European Union in connection with sanctions and restrictive measures imposed on Russia and/or Belarus and/or other countries (including those imposed on the body, person, legal person or entity associated with any of those countries) for the purpose of sale, supply, transfer, import, export of those goods, services and/or technology or for the provision of related technical assistance, brokering services or other services;

   8. other than the above-mentioned bodies, persons and/or entities subject to sanctions, e.g. persons and entities indicated in Annex No. 4 to COUNCIL Regulation (EU) 2024/1485 of 27 May 2024 concerning restrictive measures in view of the situation in Russia.

1. NETINNOVATE shall provide information to the GIIF on an accepted deposit in cash or performed withdrawal of funds (only in the form of cash) of the equivalent of more than EUR 15,000 (including as part of the purchase or sale of Virtual Currencies). NETINNOVATE shall provide the above information within 7 days from the date of acceptance of the deposit in cash or withdrawal of cash (in the form of cash only). NETINNOVATE shall provide the above information in accordance with the Act and regulations implementing the Act.

2. When determining the EUR equivalent referred to in point XII.1 of the Procedure, NETINNOVATE shall apply the average exchange rate of the National Bank of Poland for the currency in question in force on the day the Transaction is executed or on the day the Transaction is ordered to be executed.

3. The notification obligation referred to in point XII.1 of the Procedure does not apply to Transactions related to own economy of NETINNOVATE.

4. Information submitted to the GIIF includes:

   1. the unique identifier of the Transaction in the NETINNOVATE records;

   2. the date or the date and time of the execution of the Transaction;

   3. identification data of the Client, referred to in point VI.2 of the Procedure, giving the instruction or order to execute the Transaction;

   4. identification data in possession of NETINNOVATE, referred to in VI.2 of the Procedure, of the other parties to the Transaction;

   5. the amount and currency of the Transaction;

   6. type of the Transaction;

   7. the title of the Transaction;

   8. the manner of giving an instruction or order to execute the Transaction;

   9. the numbers of the accounts used to carry out the Transaction marked with the International Bank Account Number (IBAN) identifier or the identifier containing the country code and the account number in case of accounts not marked with IBAN.

5. Information on Transactions shall be transmitted in accordance with the corresponding electronic document templates, made available by the Minister competent for public finance in the form of an electronic document, published in the central repository of electronic document templates.

6. Information on Transactions shall be transmitted via:

   1. website https://www.giif.mofnet.gov.pl; and/or

   2. the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl.

7. Information on Transactions provided in accordance with point XII.6.a. or b. of the Procedure shall bear:

   1. a qualified electronic signature of the AML Officer or other Employee authorised to make reports; or

   2. NETINNOVATE qualified electronic seal.

8. In the case referred to in Section XII.6.a. of the Procedure, NETINNOVATE may provide information on Transactions not bearing the signature or seal referred to in Section XII.7 of the Procedure, if it provides the GIIF with a paper copy of the Transaction information printed via the website referred to in clause XII.6.a. of the Procedure and signed by an AML Officer or other Employee authorised to make notifications.

9. The paper copy referred to in point XII.8 of the Procedure, shall be served:

   1. by an NETINNOVATE ’s Employee or

   2. via a postal operator within the meaning of art. 3 item 12 of the Act of 23 November 2012 - Postal Law by registered mail with return receipt requested - in a closed package marked in a visible place with the words " w kancelarii nie otwierać" (not to be opened at the registry).

10. If NETINNOVATE finds an error in the information provided about the Transactions it is NETINNOVATE that provides the correction.

11. In case the GIIF finds that:

    1. the provided document containing information on the Transactions is damaged or

    2. the Transaction information or identification form was provided in breach of the Act, or

    3. the Transaction Information contains errors,

    NETINNOVATE shall either provide again or correct the information on the Transactions accordingly,

    within three working days from the date on which the request for provision or correction was received or made available to it.

12. The request referred to in point XII.11 of the Procedure, shall be provided in written form in paper form or in electronic form using electronic means of communication in the form of information available on the website referred to in point XII.6.a of the Procedure or via the interface software referred to in point XII.6.b of the Procedure.

13. If the request referred to in point XII.11 of the Procedure, in electronic form, the tele-information system, the administrator of which is the GIIF, sends a notification to the electronic mail addresses indicated to the GIIF by NETINNOVATE in the identification form. The date on which the notification is sent to the e-mail addresses shall be deemed to be the date on which this request is made available.

14. For the correction and re-provision of information on Transactions under points XII.11-13 of the Procedure, points XII.6-10 of the Procedure shall apply.

15. Where Transactions are carried out by means of more than one operation, the circumstances of which indicate that they are related to each other (Related Transactions) and have been split into operations of smaller value with the intention of avoiding the registration and reporting obligations referred to in this section, such Transactions may be reported to the GIIF in accordance with sections XIII or XV of the Procedure.

1. In the event of discovering circumstances that may indicate a suspicion of the commission of a Money Laundering or Terrorist Financing offence, NETINNOVATE shall notify the GIIF. NETINNOVATE shall make the notification immediately, no later than within 2 working days from the confirmation of the suspicion. NETINNOVATE shall establish the suspicion, in particular as a result of financial security measures. Employees who establish the aforementioned circumstances should immediately provide them to the AML Officer.

2. The notification on behalf of NETINNOVATE is made by the AML Officer. The notifications shall be submitted to the GIIF:

   1. via the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl, in accordance with the instructions available on this website, and/or

   2. in writing to the address of the GIIF, but no longer than until the date of entry into force of the regulation referred to in in writing until the date of entry into force of the regulation referred to in in Article 79(3) of the Act.

3. The notification shall contain the following information (if NETINNOVATE has it):

   1. Client’s data referred to in section VI.2 of the Procedure;

   2. identification data held on natural persons, legal persons and organisational entities without legal personality that are not Clients of NETINNOVATE. This data should be provided to the same extent as the Client's data;

   3. the type and size of the Property Value and where they are stored;

   4. the number of the account kept for the Client, marked with the IBAN identifier or the identifier containing the country code and the account number in the case of accounts not marked with IBAN;

   5. information in possession of NETINNOVATE referred to in Section XII.5 of the Procedure, in relation to Transactions or attempts to do so;

   6. an indication of the Member State to which the Transaction is connected, if Transaction has been executed in the course of cross-border activity;

   7. information in possession of NETINNOVATE about an identified risk of Money Laundering or Terrorist Financing and the criminal act from which the Property Value may originate;

   8. justification for the provision of the notification, including, among other things:

      1. a description of the financial security measures applied, including an assessment of the business relations, information on their purpose and intended nature,

      2. information on the source of the Property Value at the Customer's disposal,

      3. a description of the analysis of the Transaction within the business relationship, enabling a determination of whether it is consistent with the knowledge of the Client, the nature and scope of its business, and the identified risk,

      4. a detailed description of the circumstances indicating a suspicion of Money Laundering or Terrorist Financing,

      5. information on the place and manner of opening the Account (including Accounts opened online),

      6. data collected by NETINNOVATE justifying the suspicion, including any documents from external sources (e.g., requests from law enforcement authorities, SWIFT messages, OGNIVO),

      7. copies of relevant agreements, identification documents, notifications to the public prosecutor, decisions of the public prosecutor, etc.

      8. If the notification is based on information obtained from external sources (e.g. law enforcement authorities) or if NETINNOVATE has referred the matter to the public prosecutor, a copy of the relevant documents must be attached.

1. At the request of the GIIF, NETINNOVATE shall immediately provide or make available the information or documents in its possession, necessary for the performance of the tasks of the GIIF specified in the Act, including those relating to:

   1. Clients;

   2. the Transactions carried out;

   3. the type and size of the Property Value and where they are stored;

   4. applying ongoing monitoring of the Client's business relationships;

   5. the IP addresses used to connect to the NETINNOVATE IT system and the connection times to this system.

2. The GIIF in its request may indicate:

   1. the date and form in which the information or documents are to be provided or made available;

   2. the scope of the information and the timeframe for NETINNOVATE to obtain it.

3. Information and documents shall be provided and made available to the GIIF free of charge.

4. Information and documents shall be provided to the GIIF

   1. via the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl, in accordance with the instructions available on this website, and/or

   2. in writing to the address of the GIIF, but no longer than until the date of entry into force of the regulation referred to in in writing until the date of entry into force of the regulation referred to in Article 79(3) of the Act.

5. NEXJOR shall provide quarterly statistics to the GIIF for each calendar quarter, i.e. for the period from January 1 to March 31, from April 1 to June 30, from July 1 to September 30 and from October 1 to December 31.

6. Quarterly statistics for a given quarter should be submitted:

   1. within 18 days from the end of the quarter to which the statistics refer;

   2. via the system on the website https://www.giif.mofnet.gov.pl/#/glowna. After logging in to this system, select the "I want to send quarterly statistics" tab in the "What do you want to do?" section. Then select the "Quarterly statistics form - obligated institutions operating in the field of virtual currencies" tab. A correctly completed quarterly statistics form shall be signed by a member of the management board or an AML Officer using a qualified electronic signature.

1. NETINNOVATE shall immediately notify the GIIF if it has a reasonable suspicion that a certain Transaction or certain Property Values may be related to Money Laundering or Terrorist Financing.

2. In the notification, NETINNOVATE shall provide the information in its possession relating to the suspicion and information on the expected date of the Transaction referred to in point XV.1 of the Procedure. The notification shall include the information indicated in point XIII.3 of the Procedure.

3. Upon receipt of a notification the GIIF shall immediately confirm its receipt, in the form of an official confirmation of receipt, containing in particular the date and time of receipt of the notification.

4. Until the receipt of the GIIF request referred to in point XV.5 of the Procedure, or the exemption referred to in point XV.8 of the Procedure, however for no longer than 24 hours, counting from the confirmation of receipt of the notification referred to in point XV.3 of the Procedure, NETINNOVATE shall not carry out the notified Transaction or other Transactions related to the notified Property Values or Client’s Account.

5. The GIIF, in the event that it considers that the reported Transaction may be related to Money Laundering or Terrorist Financing, shall provide to NETINNOVATE a request to Suspend Transaction or blocking the Client’s Account for a period not exceeding 96 hours, counting from the date and time indicated in the confirmation referred to in point XV.3 of the Procedure. Immediately upon receipt of this request, NETINNOVATE shall Suspend the Transaction and/or block the Account. In the request the GIIF shall specify the Property Values covered by the request. The GIIF may forward such a request to NETINNOVATE also in the case where it has not previously received from NETINNOVATE the notification referred to in point XV.1 of the Procedures. The following points of this section shall apply mutatis mutandis to such a request.

6. The GIIF may exempt the NETINNOVATE from the obligation not to carry out the Transaction or from Account blocking referred to in point XV. 4 of the Procedure.

7. The GIIF shall transmit to NETINNOVATE the request referred to in point XV.5 of the Procedure, or the exemption referred to in point XV.6 of the Procedure, by means of electronic communication.

8. Immediately after submitting the request to NETINNOVATE, referred to in point XV.5 of the Procedure, the GIIF notifies the prosecutor’s office on suspicion of Money Laundering or Terrorist Financing. Having received the notification, the Prosecutor may by decision Suspend the Transaction or block the Account for a specified period of time, not longer than 6 months, counting from the date of receipt of the notification. The Prosecutor may by further order extend the Suspension of Transaction or blockade of the Account for a further specified period of time, not exceeding a further 6 months. Such orders shall specify the extent, manner and term of the Suspension of Transactions or blockade of the Account. The Prosecutor may also issue such an order in spite of not receiving from the GIIF the notification referred to in the first sentence.

9. The Suspension of Transactions or blockade of the Account on the basis of the Prosecutor's order referred to in point XV.8 of the Procedures shall expire if, before the expiry of its duration, a decision on securing property or a decision on material evidence has not been issued.

10. NETINNOVATE, upon the Client's request, may inform the Client that the GIIF has forwarded the request referred to in point XV.5 of the Procedure.

11. NETINNOVATE shall immediately notify the GIIF of the execution of a Transaction, which it has obtained a reasonable suspicion that may be related to Money Laundering or Terrorist Financing (i.e. referred to in point XV.1 of the Procedure), in the event that it was not possible to provide the notification prior to its execution. In the notice, NETINNOVATE shall justify the reasons for the earlier failure to provide the notice and shall provide the information in its possession supporting the suspicion. The notice shall contain the information indicated in point XIII.3 of the Procedure.

12. Saturdays and public holidays shall not be included in the time limits referred to in this point.

13. The notifications, confirmations, requests, exemptions, as well as the notification information referred to in this section XV of the Procedure shall be provided

    1. via the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl, in accordance with the instructions available on this website, and/or

    2. in writing to the address of the GIIF, but no longer than until the date of entry into force of the regulation referred to in in writing until the date of entry into force of the regulation referred to in Article 94 of the Act.

1. NETINNOVATE shall immediately notify the competent Public Prosecutor if it has a reasonable suspicion that the Property Values involved in the Transaction or held in Account originate from or are connected with a crime other than the crime of Money Laundering or Terrorist Financing or a fiscal crime. The notifications, confirmations, requests, exemptions, as well as the notification information referred to in this section shall be provided in writing until the date of entry into force of the regulation referred to in section 94 of the Act.

2. In the notice, NETINNOVATE shall provide the information in its possession relating to the suspicion and information on the expected timing of the Transaction.

3. Until receipt of the order referred to in point XVI.4 of the Procedures, for no longer than 96 hours, counting from the moment the notification is forwarded to the Public Prosecutor, NETINNOVATE shall not carry out this Transaction or any other Transactions related to the Property Values or Accounts concerned.

4. Within the time limit specified in point XVI.3 of the Procedures, the Public Prosecutor shall issue a decision to initiate or refuse to initiate proceedings, of which he shall immediately notify NETINNOVATE. In the event that proceedings are initiated, the public prosecutor shall, by order, Suspend the Transaction or block Account, for a period not exceeding 6 months, counting from the date of receipt of the notification referred to in point XVI. 1 of the Procedure. The decision on Suspension of Transactions or blocking the Account may be issued also despite the failure of NETINNOVATE to submit the notification referred to in point XVI.1 of the Procedure. The Public Prosecutor may by a subsequent decision extend the Suspension of Transactions or blockade of the Account for a further specified period of time, not longer than another 6 months.

5. In the orders referred to in point XVI.4 of the Procedure, the Public Prosecutor shall specify the scope, manner and timing of the Suspension of Transactions or blockade of the Account.

6. The suspension of the Transactions or blockade of the Account shall lapse if, prior to the expiry of their term, a freezing order or a decision on material evidence has not been issued.

7. Immediately upon receipt of the prosecutor's order referred to in section XVI.4 of the Procedure, NETINNOVATE shall provide the GIIF with information on the notifications referred to in point XVI. 1 of the Procedure, and copies of these decisions. Notifications shall be provided to GIIF:

   1. via the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl, in accordance with the instructions available on this website, and/or

   2. in writing to the address of the GIIF, but no longer than until the date of entry into force of the regulation referred to in in writing until the date of entry into force of the regulation referred to in Article 94 of the Act.

8. NETINNOVATE shall immediately notify the competent Public Prosecutor of the execution of the Transaction referred to in point XVI.1 of the Procedures, in the event that it was not possible to give notice of that Transaction before it was carried out. In the notice, NETINNOVATE shall justify the reasons for the earlier failure to give notice and shall provide the information in its possession confirming that it has become suspicious of that Transaction. Immediately after making this notification, NETINNOVATE shall provide to the GIIF information about this notification.

9. Saturdays and public holidays shall not be included in the time limits referred to in this point

1. In order to perform for the first time the obligations referred to in points XII - XIV of the Procedure, NETINNOVATE shall provide to the GIIF an NETINNOVATE identification form.

2. The NETINNOVATE identification form includes:

   1. the name (business name) together with the organisational form of NETINNOVATE;

   2. NIP of the NETINNOVATE;

   3. specifying the type of activity carried out by NETINNOVATE;

   4. registered or business address;

   5. the name, position, telephone number and electronic mailbox address of the AML Officer;

   6. the names, positions, telephone numbers and electronic mailbox addresses of other Employees responsible for the implementation of the provisions of the Act whom NETINNOVATE wishes to designate for contact with the GIIF.

3. In the event of a change in the data referred to in point XVII.2, NETINNOVATE shall update them without delay.

4. Points XII.6 - 15 of the Procedure apply mutatis mutandis to the provision of the identification form, including its update or correction.

1. NETINNOVATE applies specific restrictive measures to persons and entities that rely on:

   1. freezing of Property Values owned, held or controlled, directly or indirectly, by persons or entities (including Clients or Beneficial Owners) and benefits derived therefrom, which means preventing their transfer, alteration or use, as well as any operation involving them in any manner that may result in a change in their volume, value, location, ownership, possession, character, misrepresentation or any other change that may prevent them from being beneficial;

   2. not to make the Property Value available directly or indirectly to or for the benefit of any person or entity;

   3. other restrictive measures indicated by law.

2. NETINNOVATE is obliged to apply specific restrictive measures to the persons and entities indicated on:

   1. European Union lists introducing specific restrictive measures against certain persons, groups or entities European Union or European Union legislation imposing specific restrictive measures against certain persons, groups or entities;

   2. the lists promulgated by the GIIF pursuant to United Nations Security Council resolutions under Chapter VII of the Charter of the United Nations concerning threats to international peace and security caused by terrorist acts, in particular those referred to in paragraph 3 of United Nations Security Council Resolution 2253 (2015) or paragraph 1 of United Nations Security Council Resolution 1988 (2001);

   3. list of persons and entities subject to sanctions kept by the minister responsible for internal affairs under the Act on special solutions in the field of counteracting supporting aggression against Ukraine and serving to protect national security; and

   4. list of persons and entities maintained by the GIIF referred to in Article 120(1) of the Act.

   The lists are published in the Public Information Bulletin on the website of the minister responsible for public finance, on the website of the minister responsible for internal affairs or on the websites of the relevant European Union bodies or agencies. Links to the relevant websites can also be found in Annex No. 3 to the Procedure

3. All information held in relation to freezing or withholding of the Property Values as well as other information that may facilitate compliance with the provisions of law (including EU regulations) concerning the application of specific restrictive measures against individuals, groups or entities, shall be provided by AML Officer to the GIIF, and in the case of information related to at least one of the Regulations indicated in Art. 143a(1) of the National Revenue Administration Act - also to the Head of the National Revenue Administration, immediately, but no later than within 2 working days from the date of freezing or withholding of the Property Values or from the date of the obtaining information that may facilitate compliance with the provisions of law. At NETINNOVATE, we also cooperate with the competent authority in verifying the information provided and any we provide other information requested by that authority.

4. Upon becoming aware of an obligation to apply a restrictive measure, in particular the execution of a freeze by NETINNOVATE, the AML Officer shall:

   1. take steps to establish which restrictive measure should be applied and to what extent;

   2. take steps to identify the Property Values to be frozen;

   3. instruct the relevant NETINNOVATE Employees or associates to cease all Transactions involving the frozen Property Values.

5. At the moment of obtaining information which may facilitate compliance with the provisions of the law (including EU Regulations) concerning the application of specific restrictive measures against individuals, groups or entities, the AML Officer prepares an appropriate letter containing this information and provide the letter to the GIIF, and if the information is related to at least one of the Regulations indicated in Article 143a(1) of the National Revenue Administration Act then to the Head of the National Revenue Administration. The letter with the information should be sent immediately, no later than within 2 working days from the date on which the information in question was obtained. At NETINNOVATE, we also cooperate with the competent authority in verifying the information provided and any we provide other information requested by that authority.

6. The AML Officer is responsible for examining changes in the lists referred to in point XVIII.2 of the Procedure and for providing information to the GIIF and/or Head of the National Revenue Administration. The AML Officer performs the examination on an ongoing basis and, in addition, each time during the process of concluding the Contract with a Client, before carrying out an Occasional Transaction and after changes in the lists. The AML Officer monitors changes in the lists on an ongoing basis.

7. The GIIF and/or Head of the National Revenue Administration (to the extent specified by the National Revenue Administration Act) may issue a decision to release or partially release from freezing the Property Values or to make them available or partially available to the Client, as well as a decision on other deviations from the applied restrictive measures, to the extent permitted by law.

8. We shall provide to the GIIF all documents and information referred to in point XVIII of the Procedure:

   1. via the SI*GIIF interface software available on the website https://www.giif.mofnet.gov.pl, in accordance with the instructions available on this website, and/or

   2. in writing to the address of the GIIF

   3. in any other manner indicated by the GIIF.

9. We shall provide to the Head of the National Revenue Administration all documents and information referred to in point XVIII of the Procedure:

   1. via e-PUAP to the following mailbox: /0q43bppj24/SkrytkaESP, or

   2. to the electronic delivery address: AE:PL-54278-51168-IGTWV-15, or

   3. by traditional mail to the following address:

      Lower Silesian Customs and Tax Office in Wrocław

      ul. Stacyjna 10,

      53-613 Wrocław

   4. or in another manner indicated by the Head of the National Revenue Administration.

10. It is prohibited for NETINNOVATE Employees to participate, knowingly and intentionally, in activities the object or effect of which is, directly or indirectly, to circumvent the restrictive measures, in particular those measures indicated under Regulation 833/2014, Regulation 269/2014 or Regulation 765/2006.

1. For a period of 5 years, counting from the date on which the business relationship with the Client is terminated, NETINNOVATE shall keep copies of documents and information obtained as a result of the application of financial security measures, including information obtained by means of electronic identification means and electronically identifiable trust services within the meaning of Regulation 910/2014.

2. NETINNOVATE shall keep the results of the analyses carried out in the course of carrying out financial security measures (including risk assessments and information on Transactions) for a period of 5 years, starting from the date on which they were carried out.

3. Before the expiry of the deadlines indicated in point XIX.1 and 2. of the Procedure, the GIIF may require NETINNOVATE to keep the documents referred to above for a further period, not exceeding 5 years, starting from the expiry of these deadlines.

4. Documents, information, and analyses are stored in written or electronic form. Where information about Clients and Transactions is available in a distributed ledger, NETINNOVATE does not rely solely on the distributed ledger for the storage of such information.

5. In the event of liquidation, merger, division or transformation of NETINNOVATE, the provisions of Article 76(1) of the Accounting Act of 29 September 1994 shall apply to the retention of records.

1. NETINNOVATE, its Employees and other persons acting for and on behalf of NETINNOVATE shall keep secret the fact that any information has been communicated to the GIIF or other competent authorities, and shall keep secret information about the planned initiation of, and the ongoing analysis of, Money Laundering or Terrorist Financing. The obligation of secrecy does not include:

   1. the transfer of information between NETINNOVATE and other obliged institutions and their branches and subsidiaries which are part of a group and apply the rules of conduct set out in the group procedure, in accordance with Article 54 section 2 point (1) of the Act;

   2. the transfer of information between NETINNOVATE and obliged institutions referred to in Article 2 section 1 points (1)(5), from (7) to (15a), (17), (24) and (25) of the Act, and between those obliged institutions and their counterparts established in a Member State or in a third country which are subject to the requirements of Directive 2015/849 or equivalent and which apply appropriate rules on professional secrecy and personal data protection, in cases involving the same Client and the same Transaction.

1. All Employees performing duties related to the prevention of Money Laundering and/or Terrorist Financing are required to complete training on these duties, including training on issues related to personal data protection, before commencing their duties. Training that Employees have completed at their previous place of employment may be considered valid at NETINNOVATE after completing supplementary training that takes into account the nature, type, and size of NETINNOVATE 's business.

2. NETINNOVATE shall ensure that Employees, performing their duties under the provisions of this Procedure and the Act, participate in training on these duties, including with regard to personal data protection issues, at least once every year. The Employee shall, upon completion of the training, provide the Personnel Officer with a copy of the certificate/diploma/certificate confirming participation in the training received.

3. Trainings for all NETINNOVATE Employees take place at least once every two years and are organised by the AML Officer or an external entity (the AML Officer should only attend in external trainings). Additional training should also be organized in the event of a significant change in the law/regulations on Money Laundering and Terrorist Financing, as well as in the event of changes in the nature or type of business conducted by NETINNOVATE. Upon completion of the internal training, each Employee, submits to the AML Officer a statement of familiarity with the issues of money laundering and terrorist financing.

4. Training can also be conducted by completing courses made available by the GIIF in electronic form.

5. The fulfillment of the training obligation must be documented. The documents should clearly indicate who was trained, when, to what extent, and by whom. Proof of an Employee's participation in training, in the case of internal training, should be at least an attendance list together with a training program containing all the required information. In the case of external training, proof of participation in the training may be, for example, a certificate of participation and the training program.

6. The AML Officer is responsible for ensuring that the training provided in NETINNOVATE complies with regulatory requirements and provides up-to-date knowledge regarding the performance of NETINNOVATE 's obligations.

7. The AML Officer shall supervise the fulfilment of the training obligation by the Employees. The AML Officer keeps records of the status of the training obligation at NETINNOVATE and submits them at least once a year to the Management Board of NETINNOVATE, which reviews them at the next Management Board meeting.

8. If negligence related to anti-money laundering or countering Financing Terrorism is found, the NETINNOVATE Management Board, at the request of the AML Officer, the Supervisory Board or on its own initiative, may decide to retrain Employees.F

9. All training obligations described in Points XXI.1 – 8 of this Procedure, including the supervision of their implementation by the AML Officer, also apply to persons and entities cooperating with NETINNOVATE (including their employees and associates) who perform NETINNOVATE 's obligations related to the anti-Money Laundering and counter Terrorist Financing.

1. NETINNOVATE assesses and identifies the Money Laundering and Terrorist Financing risks associated with its business. This includes risk factors relating to Clients, countries, geographical areas, products, services, Transactions and their delivery channels.

2. In assessing the risks associated with the business of NETINNOVATE, it takes into account:

   1. national risk assessment prepared by the GIIF,

   2. the European Commission report referred to in Directive 2015/849;

   3. the results of internal controls and audits;

   4. information from reliable external sources;

   5. information from regulatory authorities.

3. The NETINNOVATE risk assessment shall be produced in electronic or paper form and shall be updated periodically, at least every 2 years.

4. The NETINNOVATE risk assessment is prepared by the AML Officer. The AML Officer forwards the risk assessment, together with the proposed risk mitigation mechanisms, to the Management Board, which considers and, if necessary, responds to the presented risk assessment and proposed risk mitigation mechanisms.

5. The AML Officer ensures that information from the general Risk Assessment is used in the risk assessment of individual Clients, including its updates.

6. NETINNOVATE shall provide its risk assessment to the GIIF upon request.

1. NETINNOVATE shall ensure that the Member of the Management Board supervising the AML and CFT area, the AML Officer and other Employees performing activities related to the performance by NETINNOVATE of the duties referred to in sections XII - XVI of the Procedure, including persons providing information within NETINNOVATE allowing for the performance of the aforementioned duties (for the purposes of this section XXIII of the Procedure, these persons are referred to as "Protected Persons"), are protected against any attempt by Employees, Members of the Management Board of NETINNOVATE or persons or entities outside NETINNOVATE of a repressive nature or actions affecting the deterioration of their legal or factual situation, or consisting in the use of threats, or actions adversely affecting working or employment conditions. In order to ensure the protection referred to in the first sentence:

   1. NETINNOVATE shall not disclose to the Client or other third parties personal data, including contact details of Protected Persons, and in particular the Protected Person who made the decision to send the application or information or sent the application or information to the GIIF or the Public Prosecutor's Office. It is also forbidden to disclose this data by any NETINNOVATE Employee and to unauthorized NETINNOVATE Employees;

   2. It is forbidden in NETINNOVATE for any Employee, including a Member of the Management Board, to take any action of a repressive nature against the Protected Person or affecting the deterioration of the legal or factual situation of the Protected Person, or consisting in directing threats against the Protected Person, and in particular any action adversely affecting the conditions of work or employment of the Protected Person, in connection with the performance by these persons of the duties referred to in sections XII - XVI of the Procedure;

   3. NETINNOVATE assures that any action of a repressive nature or affecting the deterioration of the legal or factual situation of Protected Persons, or involving threats against them, especially actions adversely affecting their working or employment conditions, will be treated as a serious breach of the rules of the Procedure, which may result in disciplinary liability or termination of the contract linking the Employee with NETINNOVATE or the termination of cooperation, as well as giving rise to disciplinary liability or material liability, in accordance with the applicable legislation;

   4. The Member of the Management Board who supervises AML/CFT shall be responsible for the protection of the Protected Person, in particular where his or her identity has been revealed or reprisals or other unacceptable behaviour have been committed against him or her;

   5. A Protected Person whose personal information has been unauthorizedly disclosed, has experienced any of the activities referred to in this section, should immediately notify the Member of the Management Board overseeing the AML/CFT area of the situation. If analysis of the information confirms the allegations of such notification, that Member of the Management Board shall take appropriate action to protect the Protected Person.

2. A Protected Person, exposed to actions of a repressive nature or affecting the deterioration of their legal or factual situation, or consisting in directing threats against them, in particular actions negatively affecting their working or employment conditions, in connection with the performance of the duties referred to in sections XII - XVI of this Procedure, may report such actions to the GIIF.

1. All Employees are required to:

   1. familiarise themselves with the provisions of this Procedure in order to apply them in their daily work;

   2. participate in anti-money laundering and counter-terrorist financing training.

2. Failure by Employees, within their area of responsibility, to comply with the obligations contained in this Procedure may result in official liability.

3. NETINNOVATE does not establish or maintain a correspondent banking relationship with a fictitious bank (within the meaning of the Act) or with credit or financial institutions known to enter into account agreements with a fictitious bank.

4. All activities connected with possible ongoing Monitoring of the Client's business relationships must be carried out on a confidential basis. It is not permitted to inform the Client about the Monitoring of his/her Transactions or other activities undertaken in the framework of this Procedure.

5. If a Procedure specifies the deadline for the performance of a given activity in days, but it is not clear from the Procedure whether working days or calendar days are meant, it means that the deadline is counted in calendar days

6. Matters not regulated by the Procedure shall be governed by the provisions of law, in particular the Act and its implementing acts.

7. The Procedure shall enter into force on the date indicated in the resolution of the Management Board adopting this Procedure for application.

1. Reviews of this Procedure shall be performed regularly by the AML Officer, but at least once a year or more frequently in the event of:

   1. implementation of significant changes in the process affecting the provisions of the Procedure;

   2. receive recommendations from the Management Board or the person(s) responsible at NETINNOVATE for internal control;

   3. receipt of supervisory recommendations (addressed to NETINNOVATE by the Financial Supervision Commission, GIIF or other supervisory authorities);

   4. changes in common law affecting the process of preventing Money Laundering and Terrorist Financing.

   Along with the aforementioned review of the Procedure, the AML Officer also reviews NETINNOVATE ’s compliance with the requirements of the Act, other anti-money laundering and counter-terrorist financing regulations, the Procedure and supervisory authorities, including the GIIF.

2. An audit is carried out at NETINNOVATE at least once every two years of the company's compliance with the anti-money laundering and counter-terrorist financing regulations and the rules of conduct set out in the Procedure. The audit may be performed internally by the person responsible for ensuring compliance in NETINNOVATE, by the internal controller if one is appointed or by external auditors. The audit report is submitted to the Management Board. The audt may not be carried out by the AML Officer or by any other person responsible at NETINNOVATE for fulfilling obligations relating to anti-money laundering and/or counter-terrorist financing.