Expert Guidance. Decisive Results.

I, Lord Charles G. Rouse of South Clifton, Chief Executive Officer of VE-comedus UG, hereby affirm the unwavering and absolute commitment of this company, its subsidiaries, and all associated personnel to combat Money Laundering (ML), Terrorist Financing (TF), and the Financing of Proliferation (PF) across all our operations globally.

This Statement of Commitment serves as the foundation for our Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy.

1. Zero-Tolerance Policy

VE-comedus UG adopts a zero-tolerance stance toward illicit financial activity. We recognize that failure to prevent these crimes poses significant risks to global financial stability, our corporate reputation, and the legal compliance of the jurisdictions in which we operate.

2. Adherence to Global Standards

VE-comedus UG is committed to adhering to all applicable AML/CFT laws, rules, and regulations in every jurisdiction where we conduct business, specifically including:

• The Risk-Based Approach (RBA) principles set forth by the Financial Action Task Force (FATF).
• The directives of the European Union (EU) AML Directives.
• All pertinent international sanctions regimes, including those mandated by the United Nations (UN), the European Union (EU), and the Office of Foreign Assets Control (OFAC).
• The principle that where local regulatory standards are less stringent than our corporate policy or home country laws, the higher standard shall prevail.

3. Allocation of Resources and Responsibility

I commit to ensuring that the AML/CFT program is adequately funded, staffed, and technologically supported to meet these stringent obligations. Specifically, I commit to:

• Appointing a qualified AML Compliance Officer (AMLCO) with sufficient authority and independence to oversee the program, we used an internationally recognised Escrow/paymaster company..
• Ensuring continuous, risk-focused training for all employees to recognize and report suspicious activity.
• Maintaining robust systems for Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and automated Transaction Monitoring.

4. Culture of Compliance

Compliance is a shared responsibility, not a function solely of the Compliance Department. Every director, officer, and employee is personally responsible for understanding and adhering to the procedures outlined in this policy. Any intentional violation of this policy will result in immediate disciplinary action, up to and including termination of employment and referral to law enforcement.

We will foster a culture where integrity and transparency are paramount, and where suspicious activities are reported promptly and without fear of reprisal.

Framework for an International Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy for VE-comedus UG

A robust international AML/CFT policy must establish internal controls, compliance procedures, and training to ensure adherence to all applicable laws and regulations in every jurisdiction where the entity operates.

1. Governance and Oversight

This section defines the roles, responsibilities, and commitment of the organization's leadership.

Statement of Commitment from Lord Charles G. Rouse, CEO

I, Lord Charles G. Rouse, Chief Executive Officer of VE-comedus UG (European Tax No. DE451943906), hereby affirm the unwavering and absolute commitment of this company, its subsidiaries, and all associated personnel to combat Money Laundering (ML), Terrorist Financing (TF), and the Financing of Proliferation (PF) across all our operations globally.

This Statement of Commitment serves as the foundation for our Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Policy.

1. Zero-Tolerance Policy

VE-comedus UG adopts a zero-tolerance stance toward illicit financial activity. We recognize that failure to prevent these crimes poses significant risks to global financial stability, our corporate reputation, and the legal compliance of the jurisdictions in which we operate.

2. Adherence to Global Standards

VE-comedus UG is committed to adhering to all applicable AML/CFT laws, rules, and regulations in every jurisdiction where we conduct business, specifically including:

• The Risk-Based Approach (RBA) principles set forth by the Financial Action Task Force (FATF).
• The directives of the European Union (EU) AML Directives.
• All pertinent international sanctions regimes, including those mandated by the United Nations (UN), the European Union (EU), and the Office of Foreign Assets Control (OFAC).
• The principle that where local regulatory standards are less stringent than our corporate policy or home country laws, the higher standard shall prevail.

3. Allocation of Resources and Responsibility

I commit to ensuring that the AML/CFT program is adequately funded, staffed, and technologically supported to meet these stringent obligations. Specifically, I commit to:

• Appointing a qualified AML Compliance Officer (AMLCO) with sufficient authority and independence to oversee the program.
• Ensuring continuous, risk-focused training for all employees to recognize and report suspicious activity.
• Maintaining robust systems for Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and automated Transaction Monitoring.

4. Culture of Compliance

Compliance is a shared responsibility, not a function solely of the Compliance Department. Every director, officer, and employee is personally responsible for understanding and adhering to the procedures outlined in this policy. Any intentional violation of this policy will result in immediate disciplinary action, up to and including termination of employment and referral to law enforcement.

We will foster a culture where integrity and transparency are paramount, and where suspicious activities are reported promptly and without fear of reprisal.

[Signature Placeholder for Lord Charles G. Rouse] Lord Charles G. Rouse of South Clifton, Chief Executive Officer Date: 20.10.2025

• Designation of an AML Compliance Officer (AMLCO):
  • Appointment of a senior, independent individual with sufficient authority and resources.
  • The AMLCO's duties, including managing the day-to-day operations of the AML/CFT program, reporting to the Board, and serving as the primary point of contact for regulators.
• Board/Senior Management Responsibilities: Oversight of the AML/CFT program's effectiveness and approval of significant changes.
• Internal Audit Function: Requirement for an independent audit function to periodically test the AML/CFT program's adherence to the policy and regulatory requirements.

2. Risk-Based Approach (RBA)

The RBA is fundamental to an effective international AML/CFT regime, focusing resources where the risks are highest.

• Enterprise-Wide Risk Assessment (EWRA): A documented process to identify, assess, and understand the ML/TF risks related to:
  • Customers: Types of customers, beneficial ownership, and politically exposed persons (PEPs).
  • Products and Services: New and existing offerings, particularly cross-border or high-value transactions.
  • Geographies: Jurisdictions of operation, particularly those identified as high-risk by FATF or other international bodies.
  • Delivery Channels: Non-face-to-face onboarding, reliance on intermediaries, and digital platforms.
• Risk Mitigation Strategies: Procedures tailored to the assessed risk levels:
  • Standard Due Diligence (SDD): Applied to low-risk scenarios.
  • Enhanced Due Diligence (EDD): Applied to high-risk customers, transactions, or geographies (e.g., PEPs, correspondent banking, high-risk countries).
  • Simplified Due Diligence (CDD): Applied to appropriately qualified low-risk scenarios, where permissible by local law.

3. Customer Due Diligence (CDD) and Know Your Customer (KYC)

This is the cornerstone of AML prevention, ensuring the identity and nature of customers are known.

• Identification and Verification (ID&V): Procedures for verifying the identity of the customer and any beneficial owners (typically anyone with ownership or control, though local laws may vary).
  • Collecting and verifying documentation for individuals and legal entities.
  • Using reliable, independent source documents, data, or information.
• Beneficial Ownership (BO) Identification: Detailed procedures for identifying and verifying the natural persons who ultimately own or control the customer.
• Ongoing Monitoring:
  • Periodic Reviews: Re-verifying customer information based on risk categorization (e.g., annually for high-risk, every few years for low-risk).
  • Trigger Events: Procedures for conducting ad-hoc reviews following specific events (e.g., change in ownership, significant change in business activities, or sanctions alerts).
• Politically Exposed Persons (PEPs): Specific policies for identifying, assessing, and applying EDD to PEPs, their family members, and close associates.

4. Transaction Monitoring and Reporting

This involves monitoring customer activity for unusual or suspicious patterns.

• Monitoring System: Implementation and maintenance of automated or manual systems to monitor transactions against established thresholds, patterns, and risk indicators.
• Red Flags/Suspicious Indicators: A list of behaviors, transactions, or activities that could indicate ML/TF (e.g., rapid movement of funds, complex transactions with no clear economic purpose, use of multiple accounts).
• Suspicious Activity Reporting (SAR) / Suspicious Transaction Reporting (STR) Procedures:
  • Detailed internal reporting procedures for employees to escalate potential suspicions to the AMLCO.
  • Mandatory reporting process to the relevant Financial Intelligence Unit (FIU) in all operating jurisdictions, ensuring compliance with local secrecy and "no tipping off" laws.
  • Maintaining records of all internal and external reports.
• Watchlist and Sanctions Screening: Procedures to screen customers and transactions against global and local sanctions lists (e.g., UN, OFAC, EU) and lists of known terrorists or criminals.

5. Record Keeping and Retention

Legal requirements mandate that records must be kept for a specific duration to aid investigations.

• Retention Period: Typically five to seven years after the business relationship ends or the date of the transaction, as required by the strictest applicable local law.
• Required Records:
  • Customer ID and verification documents (CDD/EDD records).
  • Transaction data and account files.
  • SAR/STR filings and related internal documents.
  • Training materials and attendance logs.

6. Training and Communication

An effective policy is useless without a well-informed staff.

• Mandatory Training Programs: Development and delivery of mandatory, risk-appropriate AML/CFT training for all relevant employees (e.g., front-line staff, compliance, senior management).
• Training Frequency: Typically mandatory annual refreshers, with specific training for new hires.
• Content: Covering the latest ML/TF methods, regulatory changes, internal policy updates, and the employees' roles in reporting suspicious activity.

7. Global Consistency and Local Requirements

For international operations, consistency must be balanced with local compliance.

• The "Higher Standard" Principle: Where local AML/CFT laws are less stringent than the organization's global policy or the laws of the organization's home country, the organization must apply the higher standard unless prohibited by local law.
• Local Policy Supplements: Creating appendices or supplementary documents for each branch/subsidiary to address specific local regulatory requirements (e.g., different reporting thresholds, local sanctions lists, specific record-keeping periods).

Lord Charles G. Rouse Chief Executive Officer VE-comedus UG

Date: 17.10.2025  Signature: