Anti-fraud Policy

1. POLICY STATEMENT

Cryptofactory OÜ creates opportunities for the people and builds trust between them worldwide. Cryptofactory OÜ is committed to conducting business in accordance with the highest ethical, professional and legal standards. The public, Cryptofactory OÜ’s partners and Users’ have the right to expect that professional, competent and trustworthy people are employed by Cryptofactory OÜ.

Cryptofactory OÜ will comply with applicable legislation. In line with applicable legislation Cryptofactory OÜ has a ‘zero tolerance’ policy towards fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct (jointly “Prohibited Conduct”) and will thoroughly investigate and seek to take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent or other improper actions in all Cryptofactory OÜ activity and related transactions.

Cryptofactory OÜ will provide adequate and appropriate resources to implement the Anti-Fraud Policy and will ensure it is communicated and understood.

2. LEGISLATION COMPLIANCE

The Anti-Fraud Policy has been drafted to comply with the current applicable local and international legislation, including, but not limited to applicable EU legislation. Adherence to the Anti-Fraud Policy Cryptofactory OÜ will ensure compliance with all relevant legislation and internal policies.

3. DEFINITIONS

In pursuance of the Anti-Fraud Policy, Prohibited Conduct includes fraud, corruption, collusion, money laundering, financing of terrorism and other criminal conduct defined as follows:

4. KEY RESPONSIBILITIES

Cryptofactory OÜ performs a customer due diligence (CDD) and an ongoing monitoring of business relationships with Users and their transactions in order to detect possible compliance or integrity concern. Such due diligence is performed in accordance with the requirements of the money laundering and terrorist financing activities regulations, pursuant to the terms of KYC. In view of the Anti-Fraud Policy Cryptofactory OÜ is responsible for:

5. FRAUD DETECTION AND INVESTIGATION

Cryptofactory OÜ and, in particular, the Head of Compliance, is the first line of detection, investigation and protection in preventing Prohibited Conduct through the Users and transactions appraisal process. The Head of Compliance will be responsible for the proper fulfillment of the Anti-Fraud Policy.

(a) Authority. The Head of Compliance shall be responsible for:

For situations requiring an urgent response, the Head of Compliance may take any necessary measures required for the investigation, notably to preserve evidence.

(b) Independence. The Head of Compliance shall have full authority to open, pursue, close and report on any investigation on Prohibited Conduct within its remit without prior notice to, the consent of, or interference from any other person or entity.

(c) Professional Standards. All Prohibited Conduct investigations conducted by the Head of Compliance shall be fair and impartial, with due regard to the rights of the Users and persons or entities involved. The presumption of innocence applies to those alleged to have engaged in misconduct. Those involved in the Prohibited Conduct investigation (be those under investigation or those conducting the investigation) should be aware of their rights and obligations and ensure they are fully respected.

(d) Cooperation. All Users are required to cooperate with Cryptofactory OÜ and the Head of Compliance promptly, fully, efficiently and in the manner specified by Cryptofactory OÜ, including by answering relevant questions and complying with requests for information and records.

(e) Confidentiality. In accordance with Cryptofactory OÜ internal rules on access to information, all information and documents collected and generated during a Prohibited Conduct investigation, not already in the public domain, shall be kept strictly confidential. The confidentiality of the information collected will be respected both in the interests of those concerned and the integrity of the investigation.

In particular, during the Prohibited Conduct investigation the confidentiality will be respected in so far as it would not be contrary to the interests of the investigation.

Cryptofactory OÜ shall disclose such information and documents only to those persons or entities authorized to receive them or otherwise on a need-to-know basis.

6. MISCELLANEOUS

Cryptofactory OÜ will review the Anti-Fraud Policy to reflect new legal and regulatory developments and ensure good practice. I WARRANT AND GUARANTEE THAT I HAVE NO INTENTION TO COMMIT ANY OF PROHIBITED CONDUCT ACTS DESCRIBED HEREIN; FURTHERMORE, I CONSENT TO ANY CHECKS DUE TO INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND I AGREE TO COOPERATE FULLY AND PROMPTLY WITH THE HEAD OF COMPLIANCE WITHIN SUCH INVESTIGATION.