GUARDA ANTI-MONEY LAUNDERING (AML) POLICY

1. OBJECTIVE OF THE AML POLICY
   1. 1.1. Guarda (the Company) staff is committed to pursue the highest standards of AML/CFT and Know Your Business (KYB) to mitigate the risk of Guarda services being used to facilitate financial crimes.
   2. 1.2. The Company has implemented the AML/CFT Policy to ensure that all the necessary procedures are taken in order to achieve full compliance.
2. AML POLICY
   1. 2.1. AML Policy is the procedure to prevent the Company’s services from being used for purposes of money laundering, terrorist financing or any other criminal activity. KYB measures are part of the AML Policy. The objective of KYB measures is to enable the Company to know their Partners and be able to mitigate the above mentioned risks. The Company may update such procedures in the future to assure the compliance with best AML practice.
3. MEASURES RELATED TO KYB AND SCREENING
   1. 3.1. The Company shall identify the Partner i.e. legal entities which are partnered with Guarda. Such Partners of the Company must finish an identification and verification procedure and provide all required information.
   Corporate customers

   Information collected	Purpose of collection of data
   legal name	to provide the Company’s services to resolve the customer’s claims; to communicate with the Partner; Others (such as requests from the law-enforcement bodies etc.)
   date of incorporation
   Partner’s email
   Partner’s place of incorporation
   description and nature of the Partner’s business

   1. 3.2. The Partner shall provide the Company with following valid documents serve as basis for identification:
      • a high-resolution copy of the certificate of incorporation (an extract from the Commercial Register or equivalent document, evidencing the registration of the corporate customer);
      • names and addresses of all directors and beneficial owners of the corporate entity.
   2. 3.3. The Company shall identify the beneficial owners (UBOs) and, for the purpose of verifying their identities, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owners are, and understands the ownership and control structure of the corporate customer, or of the person participating in the transaction. A representative of the Partner must submit a document certifying his/her powers (a power of attorney), which has been authenticated by a public notary and/or legalized and/or certified with an apostille, unless otherwise provided for in an international agreement.
   3. 3.4. All the information and documents provided by the Partner shall be completely clear and readable.
   4. 3.5. The Partner agrees to provide additional information and documents on the request of the Company within a reasonable period of time.
   5. 3.6. The Company reserves the right to impose additional due diligence requirements to accept the Partner residing in certain countries.
   6. 3.7. In case of any suspicious activity, false documents or non-cooperation by the Partner within the due diligence process, the Company is obligated to reject the Partner’s documents, close any existing accounts, and terminate the business relationship.
4. MONITORING
   1. 4.1 In addition to gathering information from the Partners, the Company may continue to monitor information on the Partner.
5. SANCTIONS POLICY
   1. 5.1. Guarda is prohibited from transacting with companies and countries that are on prescribed sanctions lists. The Company will therefore screen its Partner against international sanction lists on a periodical basis.