GUIDELINES FOR ANTI-MONEY LAUNDERING, COMBATING FINANCING TERRORIST AND SANCTION MEASURES

INTRODUCTION

1. ****The purpose of these Guidelines for Anti-Money Laundering (AML), Combating Terrorist Financing (CFT) and Sanctions measures is to ensure that Kemfinity s.r.o. (Company) has internal guidelines to prevent the use of its business for money laundering and terrorist financing and internal guidelines for implementation of international sanctions.

These Guidelines have been adopted to ensure that the Company complies with the rules and regulations set out in:

• the Czech Republic Money Laundering and Terrorist Financing Prevention Act;
• the Czech Republic International Sanctions Act (ISA);
• FAO general guidelines regarding measures against money laundering, terrorist financing and regarding implementation of international sanctions;
• DIRECTIVE (EU) 2018/843 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU (AMLD5).

These Guidelines are the subject of a review by the Management Board at least annually. The proposal for a review and the review of these Guidelines may be scheduled more often by the decision of the Company's Money Laundering Reporting Officer (MLRO) or the Internal Control Officer.

These Guidelines shall be accepted and approved by the resolution of the Management Board.

DEFINITIONS

The Company means legal entity with following data:

• Company name: Kemfinity s.r.o.;
• Registration number: 221 62 194;
• Address: Chudenická 1059/30, Hostivař, 102 00 Praha 10;
• Email**: [email protected];**

The Guidelines – this document including all annexes as provided above. The Guidelines include inter alia the Company's Internal control rules regarding the Guidelines and the Company's risk assessment policy regarding risk based approach for ML/TF risks.

The Money Laundering (ML) means the concealment of the origins of illicit funds through their introduction into the legal economic system and transactions that appear to be legitimate. There are three recognized stages in the money laundering process:

• placement, which involves placing the proceeds of crime into the financial system;
• layering, which involves converting the proceeds of crime into another form and creating complex layers of financial transactions to disguise the audit trail and the source and ownership of funds;