AML Policy of Umarutti s.r.o.

Effective Date: 25.05.2025

1. Introduction and Purpose of the Policy

UMARUTTI s.r.o. (hereinafter referred to as the “Company” or “we”) is fully committed to preventing the use of its business activities and the AreteApp platform (hereinafter referred to as the “Platform”) for the legalization of proceeds from criminal activities (money laundering) and terrorist financing. This commitment is in line with our ethical principles, as defined in the Company's Code of Ethics, and legal obligations, particularly those arising from Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Criminal Activity and Terrorist Financing. In the diamond, precious stone, and jewelry trade sector, which may be exposed to increased risks, we consider transparent and robust AML measures crucial for building and maintaining the trust of our clients and business partners. The publication of this policy is a manifestation of our proactive approach to managing these risks.

The purpose of this AML Policy (hereinafter referred to as the “Policy”) is to inform our clients, business partners, and the public about the fundamental principles and measures that the Company applies in combating money laundering and terrorist financing. The Policy describes our status as an obliged entity and the general obligations arising therefrom for us and for our clients. A clearly formulated and publicly available AML policy can also contribute to smoother international transactions, as foreign partners and financial institutions often require evidence of robust AML measures, which can simplify their due diligence processes and potentially expedite transactions. This Policy is publicly available on the Platform's website.

This Policy applies to all wholesale sales of diamonds, precious stones, jewelry, and other goods (as defined in the Company's Terms and Conditions) conducted by the Company, including transactions carried out via the AreteApp Platform and other means of communication.

It is important to emphasize that this Policy does not contain detailed internal procedures, control mechanisms, and risk assessment systems that the Company applies in AML screening. These internal processes are considered confidential information, and their disclosure could compromise the effectiveness of our AML measures.

2. Legal Framework and Definitions

For the purposes of this Policy and for a better understanding of our AML obligations, the following definitions and legal framework are key. For the full wording of legal definitions and current information, we recommend consulting the valid version of Act No. 253/2008 Coll., on Certain Measures against the Legalisation of Proceeds from Crime and Terrorist Financing (AML Act), and official sources of the Financial Analytical Office (FAÚ), for example, the website www.fau.gov.cz.

Basic definitions:

Legalisation of proceeds from crime (money laundering): Simply put, it is an act aimed at concealing the illicit origin of assets with the aim of creating the appearance of their legal acquisition.
Terrorist financing: Simply put, it involves the collection or provision of funds with the knowledge that they will be used for terrorist activities.

Main legal regulations:

Our AML/CFT procedures are primarily governed by Act No. 253/2008 Coll., on Certain Measures against the Legalisation of Proceeds from Crime and Terrorist Financing, as amended (hereinafter referred to as the "AML Act"), and other related legal regulations of the Czech Republic and directly applicable regulations of the European Union.

Our Company as an Obliged Entity:

UMARUTTI s.r.o. is an obliged entity pursuant to Section 2(1)(n) of the AML Act. This classification stems from our activity as a trader in precious metals or precious stones, as specified in Annex No. 1 of the AML Act (which includes gold, silver, platinum, diamonds, rubies, sapphires, and emeralds). We become an obliged entity in the event of conducting trades valued at EUR 10,000 or higher. This limit is a key operational point for our internal processes and is monitored for all transactions.

This obligation applies regardless of whether the trade is conducted in cash or non-cash. If these conditions are met, the Company is obliged to fulfill all obligations stipulated by the AML Act.

Application to specific cases (according to Selected Opinions of the Financial Analytical Office):

For the better orientation of our clients and partners, we outline how AML obligations may apply to other entities in our sector:

Jewellery shops and jewellers: If a jewellery shop or jeweller trades in precious metals and stones according to Annex No. 1 of the AML Act and simultaneously conducts trades valued at EUR 10,000 or higher, it also becomes an obliged entity pursuant to Section 2(1)(n) of the AML Act.
Sellers of investment gold (including e-shops): A seller of investment gold to end customers, including through an e-shop (based on electronic contracting), is an obliged entity pursuant to Section 2(1)(n) of the AML Act under the conditions stipulated by law (i.e., upon reaching the value limit).
Sellers of investment gold providing custody services: If a seller of investment gold additionally provides gold custody services, it becomes an obliged entity not only pursuant to Section 2(1)(n) of the AML Act, but, in the case of providing custody services, also pursuant to Section 2(1)(b)(14) of the AML Act, i.e., as a person providing custody services for valuables.

The inclusion of these opinions in our public policy signals our understanding of the broader regulatory context and may help our B2B clients better understand their own potential AML obligations, which contributes to the overall integrity of the supply chain.

The following table summarises key situations establishing the status of an obliged entity:

Table 1: Overview of situations establishing the status of an obliged entity for traders in precious metals and stones (according to the AML Act and selected opinions of the FAÚ)

Type of entity/activity	Conditions for incurring AML obligation	Relevant provision of the AML Act
Trader in precious metals/stones (general)	Trade valued at EUR 10,000 or higher	Section 2(1)(n)
Jewellery shop/Jeweller	Trades in precious metals/stones (Annex 1) AND trade valued at EUR 10,000 or higher	Section 2(1)(n) (according to FAÚ opinion)
Seller of investment gold (e-shop)	Trade valued at EUR 10,000 or higher	Section 2(1)(n) (according to FAÚ opinion)
Seller of investment gold with custody services	Trade valued at EUR 10,000 or higher OR provision of custody services	Section 2(1)(n) AND/OR Section 2(1)(b)(14) (according to FAÚ opinion)

Financial Analytical Office (FAÚ):

The Financial Analytical Office (FAÚ) is the central administrative authority of the Czech Republic for combating the legalisation of proceeds from crime and terrorist financing. It serves as the financial intelligence unit and supervises compliance with the obligations stipulated by the AML Act. Further information, methodological guidelines, and current legislation are available on the official FAÚ website (e.g., www.fau.gov.cz).

3. Core Principles of Our AML Policy

UMARUTTI s.r.o. applies the following core principles and measures within its AML policy:

Customer Identification and Due Diligence (CDD):

The Company conducts identification and due diligence of its clients (Buyers) in accordance with the requirements of the AML Act.¹ The scope and depth of client identification and due diligence are tailored based on an assessment of the risks associated with the specific client, type of business relationship, or nature of the transaction. These measures primarily include ascertaining and verifying the client's identification data, obtaining information about the purpose and intended nature of the transaction or business relationship, and about the nature of the client's business. Clients are informed of this obligation and the necessity to provide cooperation, inter alia, through our Terms and Conditions.

Identification and Verification of the Ultimate Beneficial Owner (UBO):

In cases where the client is a legal entity or a trust fund, the Company identifies and takes reasonable measures to verify the identity of the client's Ultimate Beneficial Owner (UBO), as required by the AML Act. For this purpose, we use information provided by the client, data from publicly available registers (for example, the register of beneficial owners), and other reliable and independent sources of information. Ensuring the transparency of ownership structures is key for us.

Politically Exposed Persons (PEPs):

The Company applies specific and enhanced measures for the identification and due diligence of clients who are Politically Exposed Persons (PEPs), beneficial owners of clients who are PEPs, or persons closely associated with PEPs, in accordance with the AML Act. These measures primarily include ascertaining the origin of assets and sources of funds of these persons and conducting enhanced ongoing monitoring of the business relationship. PEPs represent a potentially higher risk from an AML/CFT perspective, and therefore, we pay increased attention to them.

International Sanctions:

The Company strictly undertakes to comply with all applicable international sanctions regimes, particularly sanctions imposed by the United Nations, the European Union, and the Czech Republic. We conduct regular screening of our clients, their beneficial owners, and transactions against relevant sanctions lists. The Company will not enter into a business relationship or conduct a transaction if such action would be contrary to applicable international sanctions.

Transaction Monitoring and Reporting Suspicious Transactions:

The Company continuously monitors the business relationships and transactions of its clients for the purpose of identifying unusual or suspicious activities that could indicate an attempt at money laundering or terrorist financing. In the event of identifying a suspicious transaction within the meaning of Section 6 of the AML Act (for example, transactions without an apparent economic purpose, unusually complex or large transactions, transactions indicating a connection with criminal activity or terrorist financing, or other circumstances giving rise to suspicion), the Company is obliged to report this transaction without undue delay to the Financial Analytical Unit (FAÚ) in accordance with Section 18 of the AML Act. Although, stricto sensu, the Company becomes an obliged entity only for transactions valued at EUR 10,000 or more, for the effective functioning of the AML system and in accordance with a risk-based approach, we will consider notifying the FAÚ of activities exhibiting signs of suspicious transactions that do not reach this value, if there is a reasonable suspicion of ML/TF. We consider this approach a manifestation of responsibility and an effort to exceed standard AML obligations.

Principle of Aggregating Related Transactions:

In accordance with Section 54(4) of the AML Act, the Company consistently applies the rule preventing the deliberate splitting (structuring) of payments or transactions for the purpose of evading obligations under the AML Act, particularly the threshold for client identification and due diligence. If it is evident from the circumstances that the total sum of the value of individual transactions of a single client, which are clearly related (e.g., by client identity, subject of the transaction, temporal connection), exceeds or is intended to exceed the threshold of EUR 10,000, the Company will conduct client identification and apply other obligations under the AML Act as if it were a single transaction. The assessment of the relatedness of individual transactions always depends on the specific circumstances of the case. We are aware that dealers in high-value goods may be targets for transaction structuring, and therefore, this principle is actively monitored.

Refusal or Termination of a Business Relationship:

The Company reserves the right to refuse to conduct a transaction, establish a business relationship, or terminate an existing business relationship in cases stipulated by Section 15 of the AML Act or our Terms and Conditions. We will exercise this right particularly in situations where:

the client refuses to undergo identification or due diligence;
the client fails to provide necessary cooperation, including the submission of required documents and information;
there are doubts about the truthfulness of the information provided by the client or the authenticity of the submitted documents;
client identification or due diligence cannot be performed for other reasons;
the origin of funds or other assets used in a transaction by a Politically Exposed Person is unknown.

Effective implementation of client identification and due diligence, identification of the beneficial owner, screening of Politically Exposed Persons, and transaction monitoring are interconnected processes. A deficiency in any of these areas can weaken the Company's overall AML defense.

4. Client Obligations

For the effective fulfillment of our AML policy and legal obligations, the active cooperation of our clients is essential. The Company's clients are obliged to:

Provide information and documents: Upon the Company's request, provide all information and submit valid documents necessary for carrying out client identification and due diligence in accordance with the AML Act and the Company's internal requirements. This includes, among other things, details of their identity, the identity of the beneficial owner (if the client is a legal entity or a trust fund), the purpose and intended nature of the transaction or business relationship, the source of funds, and other relevant information.
Ensure the truthfulness and completeness of information: Clients bear full responsibility for the truthfulness, completeness, and timeliness of all information and documents provided to the Company. Providing false or misleading information may lead to the immediate termination of the business relationship and potential further legal action.
Inform about changes: Inform the Company without undue delay of any changes to the data provided during client identification and due diligence and which could affect the assessment of AML risks or the timeliness of the information held (e.g., change of beneficial owner, change of registered office, change of contact details of authorized persons).
Cooperate in physical identification: In cases where the AML Act or the Company's internal procedures require it (for example, if remote identification is not possible or in cases of increased risk), the client (or a person authorized to act on their behalf) may be requested to appear in person at a location designated by the Company for the purpose of physical identification.
Comply with sanctions regulations: Clients are obliged to comply with all provisions concerning international sanctions, as detailed in Article 17 (Sanctions Clause) of the Company's Terms and Conditions.

Strict enforcement of these obligations and refusal of transactions in case of client non-cooperation is a key deterrent for potentially risky entities and contributes to maintaining the integrity of our client portfolio.

5. Record Keeping

The Company retains all data and documents obtained in the course of fulfilling its obligations under the AML Act for the period stipulated by this Act. This includes, in particular:

Identification data of the client and persons acting on their behalf.
Copies of documents submitted for identification (if they were made in accordance with § 8 paragraph 11 of the AML Act and Methodological Guideline No. 8 of the FAÚ).
Information and copies of documents obtained during client due diligence, including information on the beneficial owner, the purpose and nature of the transaction, and the source of funds.
Records of transactions carried out.
Related business correspondence.

The standard retention period for these records is 10 years from the execution of a transaction outside a business relationship or from the termination of the business relationship with the client, unless the AML Act stipulates otherwise. The long retention period underscores the seriousness of AML obligations and the potential need for retrospective transaction tracing for investigation purposes by law enforcement authorities or the FAÚ. For the Company, this means the necessity of having robust and secure systems for data archiving and management.

6. Data Protection

When collecting, processing, and storing personal data for the purposes of fulfilling obligations under the AML Act, the Company acts in full compliance with applicable data protection legislation, in particular with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Act No. 110/2019 Coll., on the processing of personal data, as amended.

Detailed information on how the Company processes personal data, including the purposes of processing, legal bases, categories of data processed, retention periods, and the rights of data subjects, is provided in a separate document 'AreteApp Privacy Policy', which is available on the Platform.

It is important to note that the fulfilment of certain obligations under the AML Act (for example, the duty of confidentiality regarding a filed suspicious transaction report pursuant to § 38 of the AML Act, or the procedure under § 9b of the AML Act not to perform client due diligence to avoid jeopardizing an investigation) may take precedence over certain rights of data subjects under GDPR (e.g., the right to information about processing or the right of access), so as not to frustrate the purpose of AML measures and any ongoing investigations. The Company must internally carefully balance these obligations and train employees to communicate correctly with clients regarding the processing of their data for AML purposes, without inadvertently disclosing sensitive information (so-called "tipping-off").

7. Whistleblowing (Reporting of Unlawful Conduct)

UMARUTTI s.r.o. has established an internal reporting system in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers. This system allows the Company's employees, its clients, suppliers, and other relevant persons to safely, confidentially, and, if necessary, anonymously report suspected unlawful conduct that the Company or its representatives may have committed, including violations in the AML/CFT area.

The inclusion of a whistleblowing mechanism in the public AML policy demonstrates our commitment to internal control and willingness to address potential problems proactively. Detailed information on how to submit reports, the procedure for handling them, and the protection of whistleblowers is available on the Company's website. An effective whistleblowing system can help the Company identify and mitigate AML risks before they escalate into larger problems or regulatory interventions, thereby contributing to the overall integrity and ethical conduct of the Company.

8. Policy Updates

This AML Policy is regularly reviewed and updated by the Company, at least annually, or more frequently if required by changes in relevant legislation, regulatory requirements, FAÚ methodological guidelines, or if there are significant changes in the Company's business activities or in the development of risks in the area of money laundering and terrorist financing. The commitment to regularly update the policy reflects the dynamic nature of AML regulation and risks.

The current version of this Policy is always available on the AreteApp Platform website. The update process requires an internal mechanism for monitoring legislative changes and reassessing risks, which is part of the Company's robust compliance management system.

9. Contact Information

Should you have any questions regarding this AML Policy or our practices in combating money laundering and terrorist financing, please contact us at:

Email: aml{'@'}areteapp.eu

Address: UMARUTTI s.r.o., Kozí 916/5, Staré Město, 110 00 Prague 1, Czech Republic

Please note that in accordance with § 38 of the AML Act and other relevant provisions, the Company may not be authorized to provide information on specific steps taken in relation to suspicious transactions, filed suspicious transaction reports, or ongoing investigations by the Financial Analytical Unit or law enforcement authorities. Personnel responsible for responding to inquiries regarding the AML policy are duly trained on the content of this policy and the legal limitations on providing information.

Jazyková doložka / Language Clause:

This document may be executed in Czech and in other language versions. In the event of any discrepancies between the Czech version and any other language version, the Czech version shall prevail. The only legally binding version of this document is the Czech language version. All translations into other languages are provided for informational purposes only and are not legally binding.