AML

Anti-Money Laundering Program (AML) and Compliance Procedures

• Business policy

1. It is the policy of Betside industries N.V. (the "Company") to actively prohibit and prevent money laundering and any activity that facilitates money laundering or financing of terrorist or criminal activities. The Company strives to comply with all applicable requirements in accordance with the laws in force in the jurisdictions in which the Company operates, to prevent the use of the financial system for the purpose of laundering money and financing terrorism.
2. The Company has the authorization and is regulated to offer remote games over the Internet. Under the licensing conditions issued by Curacao, the Company must have appropriate measures in place to prevent its systems from being used for money laundering, terrorist financing or any other criminal activity.

• Policy objective

1. The Company is fully committed to constantly being vigilant to prevent money laundering and combat terrorist financing in order to minimize and manage risks such as reputational risk, legal risk and regulatory risk. It also undertakes its social duty to prevent serious crimes and not to allow its systems to be abused to promote such crimes.
2. The Company will endeavour to keep up to date with developments both nationally and internationally on any initiative to prevent money laundering and terrorist financing. It is committed to protecting, at all times, the organization and its operations and safeguards its reputation, all from the threat of money laundering, the financing of terrorist activities and other criminal activities.
3. The Company's internal policies, procedures and controls are designed to ensure compliance with all laws, rules, directives and regulations relevant to the Company's operations and will be reviewed and updated periodically to ensure that appropriate internal policies, procedures and controls are implemented.

• Player Identification Program

1. The Company shall take reasonable steps to establish the identity of any person to which it intends to provide the service (hereinafter referred to as "Players"). To this end, the player registration process provided for in the Company's General Terms and Conditions provides for the "Due Diligence" process to be carried out before opening a user account.
2. The Company shall at all times maintain a secure online list of all Registered Players, and the information and documents shall be kept in accordance with the applicable data protection obligations.
3. The Company will collect certain minimum identification information from each Player who opens an account. The Company will not allow the opening of anonymous accounts or accounts with fictitious names, so that the identity of the effective beneficiary is not known. The required information shall include at least:

• Date of birth of the player (showing that the player is over eighteen (18) years of age);
• Player's first and last name;
• Place of residence of the player;
• Valid player email address; And
• Player username and password.

4. Documents to verify the identity information received will be requested from the Player if there is deemed to be a risk or uncertainty about the information provided and before any payment exceeding EUR 3,000 per occasion or when the payments to the account are EUR 3,000 or more. These documents shall include, to the extent permitted by the relevant data protection regulations:

• A copy of a valid ID or passport;
• Proof of domicile;

5. The Company may supplement the use of documentary evidence using other means, which may include:

• Independent verification of the Player's identity by comparing the information provided by the Player with information obtained from a reporting agency, public database or other source;
• Verify references to financial institutions; Or
• Get a source of funding.

6. The Company shall inform the relevant Players that the Company may seek identification information to verify their identity.
7. Any Employee of the Company who becomes aware of uncertainty regarding the accuracy and veracity of the information provided by the Player shall immediately notify the AML Compliance Person, who shall review the materials and determine whether additional identification is required and/or determine whether a report should be sent to the relevant authorities.
8. If a potential or existing Player refuses to provide the information described above upon request, or appears to have intentionally provided misleading information, the Company will not open a new account and, after considering the risks involved, consider closing any existing account of that person. In any case, the AML Compliance Person will be notified to decide whether a report needs to be sent to the relevant authorities.
9. If a Player appears to attempt or engage in any criminal or illegal activity, the Company shall take appropriate measures to immediately freeze the Player's account.
10. If you change any important personal information of a Player, verification documents will be requested.

• "Due diligence" of continuous transactions

1. The Company shall monitor account activity with special attention, and to the extent possible, the context and purpose of any complex or large transaction and any transaction that may be particularly likely, by its nature, to be related to money laundering or the financing of terrorism.
2. Monitoring will be carried out through the following methods: Transactions over EUR 1000 will be monitored and reviewed daily even all the details of the users who carry out those transactions. Documents may be requested for the determination of the AML Compliance Person.
3. The AML Compliance Person shall be responsible for this monitoring, review any activity detected by the monitoring system, decide whether additional steps are required, document when and how this monitoring is carried out, and report suspicious activities to the competent authorities.
4. Parameters that determine possible money laundering or terrorist financing include, but are not too far as possible:

• Electronic transfers to/from tax havens or high-risk geographic locations for no apparent reason.
• Many small bank transfers or deposits made with checks and money orders.
• An unexplained, repetitive, unusually large electronic transfer activity shows unusual patterns or without an apparent specific purpose.

5. When an employee of the Company detects any activity that may be suspicious, he/she shall notify the AML Compliance Person. The AML Compliance Person will determine whether and how to further investigate the matter. This may include collecting additional information internally or from external sources, contacting the government, freezing the account and/or submitting a report.
6. The Company will not accept cash or non-electronic payments from Players. Funds must be deposited only through the following methods: credit cards, debit cards, wire transfers and any other method approved by the Company or the respective regulators.
7. The Company will only make transfers of profits or refunds to the same route from which the funds come, where possible.
8. To the extent that the Company uses a third party to process and record transfers made by the Player and accounts, the Company will make every effort to ensure that the service provider has transaction monitoring systems that enable the detection of transactions in accordance with those provisions and in accordance with applicable regulations. The AML Compliance Person will be responsible for reviewing the relevant service contract together with the service provider to ensure the adequacy of the agreement.
9. Records relating to financial transactions shall be kept in accordance with the data protection and retention requirements of Curacao's applicable jurisdiction.

• Suspicious transactions and reports

The AML Compliance Person will report any suspicious transactions (including deposits and transfers) made or attempted, through a Player account involving EUR 1,000 or more (individually or together) if the AML Compliance Person knows, suspects or has reason to suspect:

1. The Player is included in any list of persons allegedly associated with terrorism or in a list of sanctions;
2. The transaction involves funds derived from illegal activities or is intended or directed to conceal funds or assets derived from illegal activities as part of a plan to violate or evade laws or regulations or to avoid any report of suspicious transactions under law or regulation;
3. The transaction does not have an ordinary legal purpose or is not an action in which the Player normally participates, and after examining the contexts, possible purpose of the transaction and other data, we do not know any reasonable explanation for the transaction; Or
4. The transaction involves the use of the Company to facilitate criminal activity.

• Training programs

1. The Company will develop continuous employee training under the leadership of the AML Compliance Person and senior managers. The training will be conducted at least once a year. It will be based on the size of the company, its player base and its resources, and will be updated when necessary to reflect any developments in the law.
2. Training shall include at least:

• how to identify red flags and signs of money laundering that arise during the course of employees' work duties;
• what to do once the risk is identified (including how, when and to whom to report the Player's unusual activity or other warning signs for analysis);
• what are the roles of employees in the Company's compliance efforts and how to perform them;
• the Company's record retention policy;
• disciplinary consequences for non-compliance with legislation.