Know Your Client / AML Policy

1.1. In this know your client (“KYC”)/anti-money laundering (AML) policy (the "Policy"), Remote42 (or the “Company”), establish principles and procedures to identify the customers (the term “customers” encompassing both clients and contractors of Remote42 registered the Platform) and prohibit and actively prevent money laundering and any activities that facilitate money laundering or the financing of terrorist or criminal activities. This Policy applies to all users and customers who wish to get Remote42’s Services (such Services are to be provided under terms of service and other applicable documents located at Remote42’s website, including its subdomains) regardless of any form of payment.

1.2. Remote42 may use, for the purpose of carrying out the activities set forth in this document, the services of a KYC/AML service provider (KYC/AML service provider and/or different service providers that may be engaged by Remote42 from time to time, collectively, the "KYC/AML Service Provider").

2.1 Remote42 or the person designated by Remote42 will collect all information and documents from each customer who has created an account at the Platform to enable the customer to be identified under this Policy based on the following principles:

1. risk-based management to identify and verify the identity of each customer,

2. recording all information and documents of the customer,

3. providing customers with notice that Remote42 will seek identification information to verify customers’ identities,

4. comparing whether the customer is on relevant international and national lists of suspected terrorists and/or sanctioned persons.

2.2. High-risk countries and questionable origins of client information and/or documents. Remote42 will carry out enhanced due diligence if the customer meets one or several of the following criteria:

1. the legal person is incorporated in an offshore jurisdiction and/or the customer’s shareholder(s) is incorporated in an offshore jurisdiction,

2. an individual or legal person from a high-risk country or sanctioned territory (collectively, the “High Risk Countries”),

3. information and/or documents provided by a client during the customer's due diligence are of questionable origin. In all such cases, Remote42 shall take all necessary and reasonable steps to enhance its customer due diligence requirements and procedures, which Remote42 will decide upon according to section 2.3. (2.3.7).

Remote42 does not offer or provide Services to any customer who, as it follows from the information collected, is a citizen or a resident (tax or otherwise) of a state where Remote42 has decided not to provide its Services, as may be decided from time to time, and to any person included in the Watchlists Databases.

2.3. The customer shall undergo the following risk-based Customer due diligence and KYC identification program which may be carried out by Remote42 itself or by the person designated (KYC/AML Service Provider) by Remote42:

1. the customer creates a user account at the Platform;

2. the customer uploads to his/her account the information and documents required under section 2.4.;

3. the information and documents submitted by the customer will be transferred to the KYC/AML Service Provider to verify the customer’s identity;

4. the KYC/AML Service Provider will review and verify the provided information and documents;

5. the KYC/AML Service Provider will perform a search regarding the customer in the Government Sanctions Lists, Politically Exposed Persons Lists, Anti-Terrorism Watchlists, Anti-Money Laundering (AML) Watchlists, CIA Watchlists, Global Watchlist, Disqualified Directors, and similar watchlists (collectively the “Watchlists Databases”);

6. the KYC/AML Service Provider will verify the customer or decline the customer after the customer information review and the search in the Watchlists Databases;

7. if the customer meets any of the criteria under section 2.2, then Remote42 will perform enhanced due diligence based on a risk-based approach or refuse such customer in the provision of Services and refund to that customer any funds that have been previously advanced by such customer to the account from which they had originated, in the same type and manner (if applicable), and within a reasonable time, unless otherwise is provided in this Policy and/or required by applicable laws and regulations;

8. Remote42 will request additional information and/or documents for customers from high-risk countries or if there is information and/or documents submitted by the customer referring to a higher risk of money laundering, terrorist financing, and sanctions.

2.4. Once the customer creates a user account at the Platform, the following information and/or documents will be collected for all accounts, and for any person (individual or legal entity) that is creating a new user account and whose name is on the account prior to providing any Services to such person:

1. name;

2. date of birth (for an individual) and a date of registration (for a legal entity);

3. nationality / citizenship (or a country of registration for a legal entity);

4. residence and domicile;

5. gender;

6. email;

7. phone number;

8. address (including the country, state, city, and address line);

9. information regarding the proof of identity (passport, driving license, or national identity card that includes a picture of the holder) for an individual;

10. photo of the front and back side of the identity document and a “selfie” for an individual or certificate of incorporation, memorandum and/or articles of association, beneficial owners' information, and such legal entity directors’ identity documents/information as provided above in 2.4.10. and 2.4.11 for individuals, and proof of a business address for a legal entity;

11. proof of residential address: a utility bill less than three months old or a bank statement for an individual, or a registered address or other location for a legal entity.

The customer may be requested to provide any other reasonable information and/or documents needed to verify the customer's identity. Such information and/or documents may be provided via separate message or through any other means used by Remote42 in accordance with its policies and terms of use valid at the time.

2.5. Based on the risk, which shall be determined on a case-by-case basis, and to the extent reasonable, using risk-based procedures to verify and document all information received by Remote42 in regards to a customer, Remote42 will ensure and make all necessary efforts to form a reasonable belief that Remote42 (a) knows the true identity of a customer and (b) the information and documents provided by a customer are accurate and true. Remote42 and KYC/AML Service Provider will analyze all the information and documents received and/or collected from a customer to verify whether such information and/or documents are sufficient to form a reasonable belief that Remote42 knows the true identity of a customer. Customer identity may be verified through documentary and/or non-documentary means. Remote42 may use any appropriate method of verification based on each case's risks.

2.6. In the event Remote42 and/or KYC/AML Service Provider find suspicious information in the information and/or documents provided by a customer that indicates possible money laundering, terrorist financing activity, or any other suspicious activity, Remote42 will report the activity in accordance with applicable laws and regulations to the respective authority (if necessary).

2.7. When Remote42 cannot form a reasonable belief that it knows the true identity of a customer (or in regards to a legal entity – its directors, shareholders, beneficial owners and/or any related persons), Remote42 has the right to:

1. deactivate the customer's user account on the Platform,

2. close the user account after multiple attempts to verify the customer's identity have failed,

3. refund to that customer any funds that have been previously advanced by such customer to the account from which they had originated, in the same type and manner, and within a reasonable time, unless otherwise is provided in this Policy and/or required by applicable laws and regulations, and

4. determine whether it is necessary to notify the authorities.

2.8. If the potential or actual customer either refuses to provide any part of the information described above when requested by Remote42 or Remote42 reasonably believes and/or has found that the customer has intentionally provided false, wrong, and/or misleading information, then Remote42 has the right to deactivate the customer's account and consider closing any existing account.

2.9. Any funds that have been previously deposited by such customer shall be refunded to that customer to the originated account in the same type and manner within a reasonable time, unless otherwise is provided in this Policy and/or required by the applicable laws and regulations.

3.1. Remote42 will keep and maintain all logs of verifications, including all identifying information provided by a customer and third parties as described herein, and all steps and resolutions made by Remote42 within the identification and verification process. Remote42 will keep and maintain records containing the following:

1. in respect to documentary verification - all information and documents that Remote42 relied on to identify and verify a customer’s identity;

2. in respect to non-documentary verification – all information and logs that describe the results of any steps that Remote42 took to verify the identity of a customer;

3. in respect to verification based on third-party verifying service providers – information of the customer’s verification status and logs/messages between Remote42 and such third party in regards to such customer.

All information to be kept in regards to customer verifications is highly confidential and will not be provided by Remote42 to any third party, unless otherwise specified herein or prescribed by applicable laws and regulations.

4.1. In compliance with applicable regulations, including but not limited to the Anti- Money Laundering Directive 5 (AMLD5), Remote42 may request any additional information necessary for verification purposes. This may involve further checks and documentation to ensure adherence to the stringent regulations governing financial activities.

4.2. Remote42 reserves the right to reject any customer or to terminate any customer's access to Remote42's services without additional explanation at its own discretion.

4.3. Remote42 reserves the right to use or require customers to use external services for identity verification and compliance checks, including but not limited to SumSub, AMLbot, WorldCheck and others. Additionally, Remote42 may appoint external lawyers to verify the compliance data. These measures are taken to uphold the highest standards of due diligence and to ensure the integrity of Remote42's operations in preventing money laundering and related criminal activities.