GEMFOREX’s Anti-MoneyLaundering Policy

GEM GROUP NZ LIMITED (“GEMFOREX”) as the company providing Investment Services to the Client in relation to Financial Instruments, issued this Anti Money Laundering Policy on provision of Investment Services in relation to Financial Instruments (“Anti Money Laundering Policy”).

As a financial company is subject to laws and other forms of regulation of anti-money laundering (“AML”), which results in many particular measures, principles and rules that can be seen by applicants for business, clients or partners while dealing with GEMFOREX. itself, its subsidiaries, branches, subordinated enterprises or affiliates. To show the importance and willingness to comply withlegal requirements and so to help achieve the goals of such, GEMFOREX. has adopted within its structure the policies and measures required by the laws of European Union, which are widely known for being highly severe with subject persons performing within its jurisdiction and requiring them to follow very strict rules. Due to these rules and requirements, GEMFOREX focuses on the following.

• Paying a great attention to each client or partner, especially its background, relevant activities and the verification of identity of every applicant for business and all information provided by such
• Continuously monitoring the activity of clients, partners and their transactions and making sure that they correspond to our knowledge of clients
• Creating andsafe keeping records on accounts, transactions, communications with clients and partners, gathered information, concerned internal matters and particular procedures
• Evaluating possible risk of money laundering while dealing with clients and transactionsand risk rate our clients
• Applying enhanced due diligencein case of dealing with suspicious persons, trustees, politically exposed persons, clients from non-reputable jurisdictions andlarge deposits over the threshold limit
• Organizing quarterly and annualexternal trainings for employees, especially for those who deal directly with clients and partners
• Cooperating with responsible Money Laundering Compliance Officer appointed upon employees of GEMFOREX. and approved by the regulatory authorities
• Monitoring changes to relevant legislation,sanction list, and International Financial Regulators relevant guidance and adopting new measures, if necessary
• Prohibiting offering any anonymous account or maintaining business relationship with a shellbank
• Suspicious Transaction Reporting to the competent Authority if deemed suspicious by the Money Laundering Compliance Officer

Further, in case it happens that GEMFOREX. is in any way operating within a jurisdiction, where AML rules require some additional measures, GEMFOREX. makes sure to meet all the additional requirements and to treat relevant matters accordingly.

The goal GEMFOREX. would like to achieve by adopting a strict AML policy is to prevent itself, its clients, partners, employees, and the industry from being misused for money laundering, terrorist　financing or other financial crimes

GEMFOREX is fully aware of possible harmful effects and danger to the global society, which comes together with the possibility for wrongdoers and criminals to disguise criminal origin of property, transfer, acquire or in any way legalize the ownership of such property.

The most significant consequences of GEMFOREX.’s AML policy, that may affect either applicants for business, clients or partners, are following:

• GEMFOREX has developed a specific application through which any applicant has to enter data and upload documents if new account opening is requested. The application safe keeps all data, documents, records on transactions and trades executed by each client.
• While requesting a new account opening, every applicant has to enter detailed personal data including, but not limited to, full name, address, nationality, date and place of birth, ID number and nature of business in case it is a company. During this process(but still before the account is opened) all this data is verified by requesting applicants to upload a copy of their ID card, another proof of identity and proof of residence (plus proof of existence, list of directors and shareholders in case the applicant is a company, and other necessary due diligence documents). Applicant must further fill in an investment questionnaire, where employment and income details, history and experience with investment services are asked about.
• All communication between GEMFOREX. and any client or partner concerning financial services provided by GEMFOREX. is recorded, regardless of the meaning of communication.

Deposits to be saved on particular account must come from an account opened with authorized credit institution or a credit card, which is owned and held in the name of the particular owner or applicant for opening account with GEMFOREX otherwise the deposit is rejected. Documents verifying ownership of a card or account are also requested during the account opening process and later on, if necessary.

Withdrawals are normally processed to the same deposit account.

New copies of verification documents are always requested from clients prior to the expiration of the current ones.Clients are obligated to provide new copies of verification documents once they expire.

In the case of ongoing monitoring of suspicious activityand High Risk, client account and activity will be investigated and if deemed necessary reported to the relevantauthorities.

May 21, 2018