Anti-Money Laundering Policy

Ascentix Swiss SA (“Ascentix” or “the Company”) is committed to full compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) laws and regulations of Switzerland. This policy outlines the internal controls, procedures, and training measures implemented to prevent and detect money laundering and the financing of terrorism.

Ascentix adopts a zero tolerance approach to any form of money laundering, terrorist financing, or other financial crime, and ensures that its business activities are conducted with integrity, transparency, and in accordance with applicable laws.

This policy is guided by the following Swiss legislation and guidance:

• Swiss Anti-Money Laundering Act (AMLA)
• Swiss Criminal Code (SCC), particularly Articles 305bis and 260ter
• Anti-Money Laundering Ordinance (AMLO-FINMA)
• Financial Market Supervision Act (FINMASA)
• Guidelines issued by the Swiss Financial Market Supervisory Authority (FINMA)
• Applicable international standards, including the FATF recommendations

This policy applies to:

• All directors, officers, employees, consultants, and contractors of Ascentix
• All business relationships, clients, and counterparties
• All products and services offered by Ascentix

• Money Laundering: the process by which the proceeds of crime are disguised to give the appearance of legitimacy
• Terrorist Financing: the collection or provision of funds for terrorist acts
• Customer Due Diligence (CDD): the process of identifying and verifying a customer’s identity
• Politically Exposed Person (PEP): an individual with prominent public functions, and their immediate family and close associates

Ascentix adopts a risk-based approach to AML/CFT compliance by:

• Assessing the risk of money laundering and terrorist financing posed by each client, product, and service
• Applying proportionate CDD measures based on the risk level
• Implementing enhanced due diligence (EDD) for high-risk clients and transactions, including PEPs and those in high-risk jurisdictions

Before establishing a business relationship, Ascentix shall:

• Identify and verify the client’s identity
• Identify beneficial owners
• Understand the nature and purpose of the business relationship

EDD is applied when:

• The client is a PEP
• The client is from a high-risk jurisdiction
• The transaction is complex or unusually large with no apparent economic rationale

May be applied in low-risk cases with documented justification, in accordance with FINMA guidance.

All business relationships are subject to continuous monitoring, including:

• Scrutiny of transactions for consistency with the client’s profile
• Periodic review of client files
• Updating CDD information when necessary

• Employees must report any suspicion of money laundering or terrorist financing to the nominated officer or Money Laundering Reporting Officer (MLRO) immediately
• Reports must be submitted in writing
• The MLRO assesses the suspicion and, if appropriate, submits a Suspicious Activity Report (SAR) to the Money Laundering Reporting Office Switzerland (MROS)

Records of CDD, transactions, and internal reports are retained for at least 10 years from the end of the business relationship or the date of the transaction, as required by Swiss law.

All staff receive AML/CFT training tailored to their role, including:

• Recognizing suspicious activity
• Understanding legal obligations under the Swiss AML regime
• Internal reporting procedures

Ascentix will periodically review and update its AML framework. An independent audit or compliance review may be conducted to assess the programme’s effectiveness.

• Board of Directors: oversees AML governance and ensures effective risk management
• MLRO: ensures AML compliance, evaluates internal reports, and files SARs with MROS
• All employees: must comply with this policy and report any suspicions promptly

Ascentix screens clients and transactions against sanctions lists, including:

• Swiss SECO (State Secretariat for Economic Affairs)
• United Nations Security Council
• European Union
• US OFAC (where applicable)

Business will not be conducted with any sanctioned individuals or entities.

This policy shall be reviewed annually or upon significant changes in Swiss legislation or the operations of Ascentix Swiss SA.

Approved by the Board of Directors.