WeAffiliates Anti Money Laundering Policy (the “AML Policy”)

Money laundering refers to the process where the identity of the proceeds generated from crime is disguised so as to portray the appearance of a legitimate income. WeAffiliates acknowledges that it is common for criminals to specifically target firms which are providing financial services through which they attempt to launder criminal proceeds without such firm’s knowledge or suspicions.
Within the territories of the UK alone, estimations indicate that billions are laundered on an annual basis and on global scale and in revenue terms, the high volume of money laundered made it the third largest industry.
In response to the scale and effect of money laundering the United Kingdom, in common with many other countries has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms and outline the offense and penalties for failing to comply.
AML Legal and Regulatory Framework
The AML obligations, limitations and penalties on which the WeAffiliates operation is based are as indicated under the following legislation and regulations:
a) The Proceeds of Crime Act 2002 (POCA) as amended by the: (i) Serious Organized Crime and Police Act 2005 (SOCPA); and (ii) Proceeds of Crime Act (Amendment) regulations 2007;
b) The Terrorism Act 2000, as amended by the: (i) The Anti Terrorism, Crime and Security Act 2001; and the (ii) Terrorism Act (Amendment) Regulations 2007;
c) The Terrorism Act 2006;
d) The Money Laundering Regulations 2007;
e) The Bribery Act 2010;
f) The FCA Handbook of Rules and Guidance and in particular, the Senior Management Arrangement System; and
g) The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing. The above is subject to amendments as applicable in the jurisdiction in which WeAffiliates operates.

The WeAffiliates AML Policy is designed to ensure that all group companies comply with the restrictions and requirements set out under the UK AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the WeAffiliates being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
a) The appointment of a money laundering reporting officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry standard.
b) Establishing and maintaining a risk based approach toward assessing and managing the money laundering and terrorist financing risks to WeAffiliates.
c) Establishing and maintaining risk based customer due diligence, identification, verifications and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs).
d) Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity.
e) Training and awareness for all relevant employees.
f) The maintenance of appropriate records for the minimum duration required under the applicable law.

Sanctions Policy
The WeAffiliates sanction policy is designated to ensure our compliance with the laws and regulations in the applicable jurisdictions in which we operate. WeAffiliates is prohibited from executing transactions with individuals, companies or countries which are on the prescribed Sanctions lists. WeAffiliates will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (the “OFAC”) sanctions lists in all jurisdictions in which we operate, except if such screening conflicts with local legislation.

Anti- Bribery and Anti Corruption Policy
WeAffiliates acknowledges that bribery and corruption inflict great damages to the communities within which it occurs and does not and will not tolerate bribery and corruption. Furthermore, corruption is strongly related to organized crime, money laundering and on occasions the financing of terrorism. WeAffiliates is dedicated to high standards of integrity within its operation which may be under any applicable laws and regulations related to the subject matter in different jurisdictions, including the UK Bribery Act 2010.