DXB PARTNERS (DXBP) GLOBAL ANTI-MONEY LAUNDERING POLICY 2023

Introduction

1.1 As a company, we are committed to carrying on business in accordance with the highest ethical standards. This includes complying with all applicable laws and regulations aimed at combating money laundering and terrorist financing. This Policy has been developed by DXBP to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its solutions. This Policy explains our individual responsibility in complying with anti-money laundering and counter- terrorist financing laws (“AML Laws”) around the world and ensuring that any third parties that we engage to act on our behalf, do the same.

1.2 The management of DXBP is committed to complying with all laws. Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.

1.3 If you have any questions about this Policy you should contact the founders.

Policy Statement on AML

1.4 It is DXBP’s policy to comply with all applicable AML Laws in our operations worldwide. To this end, DXBP will only conduct business with customers who are involved in legitimate business activity and whose funds are derived from legitimate sources.

1.5 This Policy is intended to help employees, contractors, and other third parties acting on the company’s behalf to understand where breaches of AML Laws might arise and to support them in making the right decisions in line with our corporate position as stated in this Policy.

Board Endorsement

1.6 The Board of DXBP will not criticise management for any loss of business resulting from adherence to this Policy. No employee or contractor will suffer as a consequence of bringing to the attention of the Board or senior management, in good faith, a known or suspected breach of this Policy nor will any employee or contractors suffer any adverse employment or contract decision for abiding by this Policy.

Who is subject to this Policy?

1.7 This Policy applies to DXBP’s operations globally, including all legal entities worldwide owned or controlled by DXBP (including all group companies), and to all directors, officers, employees, contractors, and other third parties acting on behalf of the foregoing.

What’s the risk?

1.8 Violations of AML Laws may lead to severe civil and/or criminal penalties against companies and individuals, including significant monetary fines, imprisonment, extradition, blacklisting, revocation of licenses, and disqualification of directors.

1.9 In addition, violations of AML Laws can lead to damaging practical consequences, including harm to reputation and commercial relationships, restrictions in the way we can do business, and extensive time and cost in conducting internal investigations and/or defending against government investigations and enforcement actions.

What do we mean by Money Laundering and Terrorist Financing?

1.10 Money laundering means exchanging money or assets that were obtained criminally for money or other assets that are ‘clean’. The clean money or assets don’t have an obvious link with any criminal