Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy

Polopo Shop AML/CFT Policy is designed to ensure that we comply with the requirements and obligations set out in Hong Kong and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards, which must be complied with by Polopo and employees and includes:

• Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to Polopo;

• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;

• Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;

• Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

• Procedures for reporting suspicious fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;

• The maintenance of appropriate records for the minimum prescribed periods;

• Training and awareness for all relevant employees;

• And the provision of appropriate management information and reporting to senior management of the Group’s compliance with the requirements.

• CS may require its clients to provide additional information or documentation to fulfill our legal obligations and where it deems appropriate refuse any client or transaction that is suspected of being related to financial crime.

The Polopo AML and KYC policies are as follows:

• Transactions conducted via the Polopo platform will be subject to our internal AML transaction monitoring.

• Identity and proof of address documents and transaction records for high volume trades (exceeding HK$120,000) will be maintained for at least six years and will be submitted to regulators as required without prior notification to registered users.

• Polopo may at any time without liability and without disclosing any reason, suspend the trade with any suspicious user. Polopo shall notify you after exercising its rights under this clause.

• High volume trading users will be required to verify their identity and adhere to the Polopo KYC policy. This includes the submission of both government ID and proof of address. Valid ID includes a passport, Hong Kong Identity Card, or drivers license. Valid proof of address includes utility and rates bills not older than 3 months. Other forms of ID and Address verification will not be accepted. Your account will be unregistered and no trade could be done until account verification has been completed.

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