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Programme of own activities against money laundering and financing of terrorism (Programme)

The programme has been developed by the company for its internal needs LUMIA PROPERTY MANAGEMENT s.r.o. with registered office at Krasovského 3742/13, 851 01 Bratislava, ID No.: 36 803 898, registered in the Commercial Register kept by the Municipal Court of Bratislava III, Section Sro, Insert No. 46903/B (the Company).

The programme regulates the Company's and its agents' approach to preventing the laundering of proceeds of crime and the financing of terrorism, as set out in Act No. 297/2008 Coll. on protection against legalization of proceeds of crime and protection against financing of terrorism and on amendment and supplementation of certain acts, as amended (Act).

The company is authorised to broker the sale, lease or purchase of real estate in the performance of its activities and is an obliged person pursuant to § 5 (1) (i) of the Act.

Article I.

Purpose of the Programme

The programme sets out the conditions and specific working procedures for the Company's officers and employees in preventing money laundering and terrorist financing, defining responsibilities, rights and obligations in the implementation of anti-money laundering and counter-terrorist financing measures, and ensuring the flow of information on the measures implemented in relation to the protection against money laundering and terrorist financing.

The Programme is binding on the Managing Directors and all employees who carry out tasks under the Act. The performance of the various duties defined below for the Company in relation to a particular client shall always be the responsibility of the Managing Director or the employee in charge of that client's business.

Article II.

Definition of basic terms

Legalisation of the proceeds of crime - intentional conduct consisting in

(a) changing the nature of property or transferring property with knowledge that the property is derived from criminal activity or from participation in criminal activity, with a view to concealing or disguising the illicit origin of the property or with a view to assisting a person involved in the commission of such criminal activity to avoid the legal consequences of his or her conduct,

(b) concealing or disguising the origin or nature of property, the location or movement of property, title to property or any other right in property, knowing that the property is derived from criminal activity or from participation in criminal activity,

(c) the acquisition, possession, use and enjoyment of property knowing that such property is derived from criminal activity or from participation in criminal activity,

(d) participation in an act referred to in points (a) to (c), including in the form of conspiracy, aiding, abetting, inciting and inciting, as well as in an attempt to commit such an act.

Financing of terrorism - the provision or accumulation of funds or property with the intent to use them, or knowing that they are to be used, in whole or in part, for

(a) the commission of the offence of establishing, organising and supporting a terrorist group or the offence of terrorism and certain forms of participation in terrorism,

(b) the financing of the daily needs of a person who may be presumed to intend to commit or to have committed an offence of terrorism and certain forms of involvement in terrorism,

(c) committing the offence of theft, the offence of extortion or the offence of forgery and alteration of a public document, official seal, official seal, official emblem and official mark, or inciting, aiding or abetting a person to commit or attempt to commit such an offence with a view to committing the offence of establishing, forming and supporting a terrorist group or the offence of terrorism and certain forms of participation in terrorism,

(d) the commission of offences under international treaties ratified and promulgated in the manner prescribed by law to which the Slovak Republic is bound.

Unusual business operation - a legal or other act which indicates that its performance may lead to money laundering or terrorist financing. The various forms of unusual business transaction are described in Article VIII of this Programme.

Politically exposed person - the Head of State, the Prime Minister, the Deputy Prime Minister, a Minister, the head of a central government body, the State Secretary or a similar deputy minister, a member of the legislature, a judge of the Supreme Court, a judge of the Supreme Administrative Court, a judge of the Constitutional Court or of other higher judicial bodies, whose decision may no longer be appealed against, except in special cases, the President of the Judicial Council of the Slovak Republic, the Deputy President of the Judicial Council of the Slovak Republic, the President of the Specialised Criminal Court, the Deputy President of the Specialised Criminal Court, the President of a Regional Court, the Deputy President of a Regional Court, the President of an Administrative Court, the Deputy President of an Administrative Court, the President of a District Court or the Deputy President of a District Court, a member of the Court of Auditors or of the Board of the Central Bank, an ambassador, a chargé d'affaires, a high-ranking member of the armed forces, the armed forces or the armed security forces, a member of the governing body, supervisory body or controlling body of a State-owned enterprise or a State-owned commercial company, an Attorney-General, a Deputy Attorney-General, a special prosecutor, a deputy special prosecutor, regional prosecutor, deputy regional prosecutor, district prosecutor or deputy district prosecutor, a person in another similar function of national or regional importance or another similar function performed in the institutions of the European Union or in international organisations, a member of a statutory body of a political party or political movement. A politically exposed person shall also be deemed to be a spouse or a person who has a similar status to that of the spouse of a person referred to in the preceding sentence, as well as a child, son-in-law, daughter-in-law, parent or a person who has a similar status to that of a son-in-law or daughter-in-law of a person referred to in the preceding sentence. For the purposes of this Act, a politically exposed person shall also mean a natural person who is known to be the ultimate beneficiary of the same client or otherwise controls the same client as a person referred to in the first sentence of this paragraph, or is doing business with a person referred to in the first sentence of this paragraph or a client that has been set up for the benefit of a person referred to in the first sentence of this paragraph.

End user benefits - any natural person who effectively controls or controls a legal person, a natural person - entrepreneur, and any natural person for whose benefit these entities carry out their activity or trade. In the case of a legal person, a natural person who has a direct or indirect interest, or the aggregate thereof, of at least 25 % in the voting rights in the legal person or in its share capital, including bearer shares, shall have the right to appoint, otherwise appoint or remove a statutory body, governing body, supervisory body or controlling body in the legal person or any member thereof, controls the legal person in a manner other than those referred to in the first and second subparagraphs, has the right to an economic benefit of at least 25 % from the business of the legal person or from any of its other activities. In the case of a natural person-entrepreneur, a natural person who has the right to an economic benefit of at least 25 % from the natural person-entrepreneur's business or from another of its activities. A natural person who is entitled to an economic benefit of at least 25 % from the business of a legal person in which he or she is a silent partner shall also be regarded as an end beneficiary. In the case of a public company or a limited partnership, a natural person who is a partner or who directly or indirectly, through an ownership interest or otherwise, controls a partner who is a legal person. In the case of a pool of assets, the ultimate beneficial owner shall be the natural person who is the founder or settlor of the pool of assets; where the founder or settlor is a legal person, the natural person referred to in point (a) deemed to be the ultimate beneficial owner as defined in the case of a legal person, or the natural person who has the right to appoint, otherwise appoint or dismiss the statutory body, management body, supervisory body or controlling body of the asset pool or a member thereof or is a member of the body, who has the right to appoint, otherwise appoint or remove those bodies or a member thereof, or a person who is a statutory body, management body, supervisory body, controlling body or member of those bodies, or is a recipient of at least 25 % of the funds provided by the asset pool, if future recipients of those funds have been identified; where the future beneficiaries are determined by a characteristic, that characteristic shall be determined, with the ultimate beneficiaries becoming the ultimate beneficiaries at the time of their identification or designation and, where the future beneficiaries of the assets pool have not been determined, the ultimate beneficiaries shall be the circle of persons who benefit significantly from the establishment or operation of the assets pool or, where applicable, the natural person who is appointed to represent and protect the interests of the beneficiaries of the assets pool. If no natural person fulfils the criteria under the first sentence, the ultimate beneficial owners of that person shall be deemed to be members of its top management; the statutory body or members of the statutory body shall be deemed to be a member of the top management. A natural person who does not himself meet the criteria in the preceding sentences but who, together with another person acting in concert or in concert with him, meets at least some of those criteria, shall also be an ultimate beneficiary.

Client - the person who is a party to the contract is a party to the obligated person's business-related commitment, or participates in the proceedings on the basis of which he or she is to become a party to the obligated person's business-related commitment, or represents a party to the obligated person's business-related commitment in the proceedings with the obligated person, or is otherwise entitled to dispose of the subject matter of the obligated person's business-related commitment. The most frequent Client of the Company is a person who is interested in buying, selling or renting real estate.

Association property - the client, which is a foundation, a non-profit organisation providing services of general benefit, a non-investment fund or other special-purpose asset pool, regardless of its legal personality, which manages and distributes funds,

Article III

Client care

Client due diligence is the totality of the obligations that the Company performs in its business activities in relation to its clients under the Act, in order to have the opportunity to get to know its client and subsequently to recognize that there is a risk in relation to the intended business transaction.

We divide care according to the scope of the Company's responsibilities into basic, reduced and enhanced care.

The firm shall determine the extent of client care appropriately with regard to the risk of money laundering or terrorist financing. In assessing the risk of money laundering or terrorist financing, the Company is required to evaluate and take into account the risk factors set out in the risk assessment under Article VII of the Programme.

Article IV

Primary care

The company is obliged to ensure the identification of each of its clients and to verify this identification. Basic due diligence is carried out in relation to all clients. In the course of its performance, it may find it necessary to supplement basic care with the enhanced care obligations set forth in Article VI of this Program.

A Client identification

If the Client is a natural person, the Client should identify himself/herself by duly notifying the Company of his/her name, surname, date of birth, birth number, permanent residence, nationality, type and number of identity document at the beginning of the business relationship or transaction. If the natural person is also engaged in business and the business relationship or trade relates to that business, he/she shall also notify the Company of the address of the place of business, the address of the actual place of business, if different from the address of the place of business, the identification number and identify the official register or register in which he/she is registered and the number of the registration in the register/register.

If the Company's client is a legal entity or a pool of assets, it is necessary for it to identify itself by stating its name, the address of its registered office, the address of its actual place of business, if different from its registered office, its identification numbers, the name of the register or registry in which it is registered, the number of this registration. At the same time, the natural person who is authorised to act on behalf of the legal person shall also be required to identify himself within the scope of the data pursuant to paragraph 2 of this Article of the Programme.

If the client is represented by another person on the basis of a power of attorney, the data shall be collected in relation to the client to the extent of whether the client is a natural or legal person as referred to in paragraphs 2 and 3 of this Article. At the same time, the representative acting under a power of attorney shall be identified to the same extent. The company shall verify the validity and scope of the representation authorisation.

If the client is a minor child without an identity document, data in the range of first name, surname, date of birth, birth number, permanent residence, nationality shall be obtained in relation to the minor and his/her legal representative should provide the Company with the data in the range according to paragraph 2 concerning the identification of the natural person.

B Verification of identification

The Company is obliged to verify that the identification data provided by the Client is true before the conclusion of the business relationship in the physical presence of the Client.

If the client is a natural person, the Company is obliged to request the identity card provided by the client at the time of identification. Upon presentation of this ID, the Company will verify and compare the information provided with the information on the ID presented. At the same time, the Company will verify that the photograph on the identity card matches the Client's actual likeness. The Client should be physically present at the time of identification.

If the client is a natural person who is also an entrepreneur, the Company shall also verify the truthfulness of the data provided in relation to the client's business activity and shall itself check the data in the register or records in which the client is registered. If such register or record is not publicly accessible, the Company shall request the Client to produce a certificate and/or an extract from such register or record and shall verify the correctness of the identification on the basis of such document.

If, in the course of verifying an individual, the Company determines that the individual is a politically exposed person or a person established in a country designated as high risk by the European Commission or other authorized institution, the Company shall, in addition to basic due diligence, exercise enhanced due diligence pursuant to Article VI. Program.

If the client is a legal entity, the Company shall verify the accuracy of the information provided on the basis of documents, data or information obtained from the official register or other official records in which the legal entity is registered or from another reliable and independent source. At the same time, the Company shall also verify the natural person authorised to act on behalf of the legal entity in the manner provided for in paragraph 7 of this Article.

In the case of a person represented by a power of attorney, the Company shall verify the information provided on the basis of documents, data or information obtained from the power of attorney presented with a certified signature, official register or other official records or from another reliable and independent source. The representative himself shall be verified by the Company in his physical presence by comparing the information on the power of attorney and on the identity document presented. If the representation is made on the basis of a power of attorney, the authenticity of the principal's signature on the power of attorney must be officially certified.

If the client is a minor without an identity document, the Company shall verify the personal data provided by the minor's representative on the basis of the identity document presented.

If the Company, when verifying the identification of a natural person, has doubts whether the identity document presented by the Client is not false, altered or whether it actually belongs to that natural person, the Company will ask the natural person for another identity document (e.g. travel document or driving license) to verify the data. The Company may verify that the identity document is not a stolen or lost identity document in the publicly accessible lost and stolen documents register maintained at www.minv.sk.

If the Company has doubts in verifying the identification of the legal entity, it shall request for the purpose of identification an additional document from the official register, the register in which the client is registered. This may be, for example, a certificate of registration with the tax office.

The Client is obliged to provide the requested information and documents necessary for its identification and verification. The Company shall make legible copies of the identity card and other documents submitted and keep them throughout the business relationship and after its termination for the period specified in Article X of this Program.

C Verification of end-user benefits

The company identifies the end-user of the client's benefits, which is a legal entity or a pool of assets, using the register of end-users of benefits maintained at the Statistical Office of the Slovak Republic. The Company has established access to the Register of End-User Beneficiaries and, upon its electronic request, data on the client's end-user beneficiary is provided electronically in an automated manner. The company verifies the information from the register of the end-user of the benefits during an interview with the client. If it is suspected that a person registered as an End Beneficiary is not the actual End Beneficiary, it shall request the completion of an End Beneficiary Affidavit, a specimen of which is attached to this Scheme. In the event that there is another credible source from which information about the Ultimate Beneficiary could be ascertained and to which the Company may have access, the Company will verify this fact from that source as well.

If the client is a foreign legal entity or pool of assets, the Company will ask the client to complete an affidavit of ultimate beneficial owner.

In the event that the Company determines that the ultimate beneficiary is a politically exposed person or sanctioned individual, the Company will follow the enhanced client care rules under Article VI of this Program.

D Obtaining and evaluating trade information

When working with a client, the Company will ascertain the purpose and intended nature of the transaction or business relationship and evaluate the veracity of that information.

The company's main focus will be to establish the reason for the sale, purchase or lease of the property. The company will focus on whether the client is buying or selling the property to sort out their own housing or what specific intention the client has with the property. The company will also examine how the client intends to dispose of the property purchased, whether he/she is interested in using or renting it out in the long term or envisages an early transfer.

The Company will then evaluate the information provided to determine whether it appears to be truthful and acceptable in terms of the normal disposal of real estate, or whether the client has provided information that is contradictory and unusual in relation to the disposal of real estate.

Where the client is a legal entity, the Company, where relevant in relation to the proposed transaction, also obtains information about the nature of the client's business in order to understand the nature of the client's business, ownership structure and management structure.

E Obtaining information on the origin of funds used in trade

When communicating with the client, the company finds out the source of the funds used to purchase the property. In particular, they find out whether it is the client's own resources, e.g. savings, inheritance, or whether it is third-party finance (e.g. from a bank or other person who has provided the client with a loan). In order to establish the origin of the funds, the Company will ask the client for a declaration of the origin of the funds, which forms an annex to this Programme.

The company will also assess, when communicating with the client, whether the client's own funds appear to be appropriate in relation to the client's profession, business or position, or the reason for their acquisition (e.g. inheritance, gift). If the client has obtained the funds from a third party other than the bank, he/she will try to establish the relationship between the client and the third party and the reason/legal title of the funds.

F Determining whether the client is acting on its own behalf

When communicating with a client, the company shall check whether the client is acting on its own behalf or on behalf of another person in the business relationship. The Company will ask the Client to confirm whether the Client is acting on his/her own behalf in a statement attached to this Scheme.

If the Company discovers or suspects that the Client is not acting on its own behalf, it shall ask the Client to prove in the form of a binding written statement the name, surname, birth number or date of birth of the natural person or the business name, registered office and identification number of the legal entity on whose behalf it is conducting business. A specimen of the declaration is annexed to this Programme.

G Continuous monitoring of the business relationship throughout its duration

The Company continuously monitors this business cooperation and the individual trades executed during the entire business relationship with the Client. In particular, the Company monitors whether the information obtained as part of the basic client care is consistent with the trades executed. The Company also monitors whether there are any changes in the facts ascertained or whether there is a discrepancy between the facts claimed by the client and the actual situation. The Company records and also updates any changes to the information along with identifying details, The Company continuously monitors and evaluates the risk associated with the client and the source of funds and assets used in the trade/business relationship.

H Situations where the Company is obliged to carry out basic client care

The company is obliged to exercise basic care in relation to the client

(a) when entering into a business relationship,

(b) in the execution of an occasional trade outside the main business relationship in a value of at least EUR 15 000 and in the execution of an occasional trade outside the main business relationship in cash of at least EUR 1 000, irrespective of whether the trade is executed individually or as a number of successive trades which are or may be linked,

(c) where it is suspected that the client is preparing or executing an unusual trading operation, regardless of the value of the trade,

(d) when in doubt as to the veracity or completeness of previously obtained data necessary to exercise care in relation to the client (including the identification of the ultimate beneficiary),

(e) where there are material changes in the client that could affect the risk of money laundering or terrorist financing.

I Situation where the Company fails to provide basic care to the client

An obliged person shall not exercise basic due diligence in relation to a client who is suspected of preparing or executing an unusual business transaction, irrespective of the value of that suspicious transaction, if
its execution in whole or in part would frustrate or jeopardise the processing of the unusual commercial transaction; or
A firm is instructed in writing by the FIU not to perform basic due diligence in relation to a client in whole or in part on the grounds that the performance of such due diligence could frustrate or jeopardise the processing of an unusual business transaction.

Article V

Simplified client care

In carrying out the simplified care in relation to the client, the company is obliged to carry out client identification a verify that according to the information available to the Company about the Client or the business, there is no suspicion that the client is preparing or conducting an unusual business operation.

If there is any suspicion that a client is preparing or conducting an unusual business operation and if there is any doubt as to whether it is a simplified diligence, the Company will proceed to conduct basic diligence.

A firm may proceed to simplified due diligence if the proposed transaction with the client poses a low risk of money laundering or terrorist financing under Article VII of the Programme and in relation to the category of the client and the transaction:
properly justified their low risk in the risk assessment.
have not been assessed as at risk in the national risk assessment
the conditions for the exercise of enhanced care are not met.

In simplified client care Company
verify and record compliance with the conditions for simplified care
identify the client and the person acting for the client,
appropriately identify and record details of the end user of the benefits and verify that the client is not a politically exposed person,
verify the origin of the funds used in the transaction
verify that the information about the client or the trade does not suggest that the client is preparing or executing an unusual business operation and that it is a simplified diligence.

The company shall keep a record of the fulfilment of the conditions for simplified care in relation to each client for whom it has entered into simplified care.

The company will only proceed to simplified diligence if the risk of unusual commercial diligence is not confirmed.

Article VI

Increased client care

The Company shall exercise enhanced due diligence if, based on the risk assessment under Article VII of the Programme, any client, any type of trade or any particular trade poses a higher risk of money laundering or terrorist financing.
Due diligence shall always be exercised by the obliged person in any trade or business relationship with a politically exposed person or a person established in a country designated as high risk by the European Commission, an intergovernmental institution or an international organisation which sets internationally recognised standards for the prevention of money laundering and terrorist financing and which monitors compliance with those standards. A natural person shall be deemed to be established in a high-risk country if he or she is a national of, or has his or her domicile or other residence in, a high-risk country, a natural person who is an entrepreneur and a legal person who has a registered office, branch, branch or establishment in such a country.
In the event of increased care, the Company shall take additional measures to eliminate the increased risk to an acceptable level, in addition to the basic care required under Article IV of the Program.
The company shall exercise enhanced diligence if the client is not physically present when the identification and subsequent verification of that identification is made and the risk assessment indicates that enhanced diligence is necessary. The Company shall request the submission of additional documents, data and information to make the identification and shall also request:
a document proving that the client has opened a bank account in a bank operating in the territory of the Slovak Republic or in the territory of another Member State,
the Client to make the first payment in the transaction from this bank account.
In case the client of the Company is a politically exposed person, the Company shall request the client to submit the consent of the statutory body of the entity in which the exposed person operates or the consent of the person who ensures the performance of tasks in the given entity in the protection against money laundering and financing of terrorism, the reporting of unusual business operations and through whom the ongoing contact with the financial intelligence unit is ensured before the conclusion of a business relationship or the continuation of a business relationship. At the same time, the Company shall ascertain the origin of the funds or assets used in the transaction. The Company shall closely and continuously monitor the progress of the business relationship in relation to the politically exposed person.
The Company is required to apply the enhanced care obligations relating to a politically exposed person for at least 12 months after the end of the performance of a significant public function; however, no later than until the obliged person has eliminated the risk specific to politically exposed persons on the basis of a risk assessment of that client.
The Company determines that, when approached with a business relationship by a person established in a high-risk country, it will carefully consider whether to enter into such a business relationship at all and whether to refuse the business relationship immediately after being approached.
In the event that the Company chooses to cooperate commercially, it is obliged, in the case of a trade or business relationship with a person established in a country designated by the European Commission as high-risk, to find out additional information about the client and the ultimate beneficiary, additional information about the purpose and intended nature of the business relationship or trade, the origin of the assets and the origin of the funds used in the business relationship or transaction, additional information from reliable sources, the consent of the statutory body, the designated person before entering into the business relationship or to continue the business relationship, and to monitor the business relationship on an ongoing and detailed basis.
The list of high-risk countries can be found on the website of the Ministry of Foreign Affairs of the Slovak Republic, where it is regularly updated.

Article VII

Laundering and terrorist financing risk allocation and assessment

The Company identifies, assesses, evaluates and updates the risks of money laundering and terrorist financing according to the type of transactions and business relationships with clients within its business activities and evaluates whether there is an unusual business operation.

In particular, the Company assesses risks in relation to the client, in relation to trade and business cooperation and risks from a geographical perspective.

In relation to the client, the firm shall assess in particular whether

(a) the business relationship takes place under unusual circumstances (e.g. the client does not ask for a personal inspection of the offered property, the client chooses the property only from the offer in the advertisement, the client avoids a personal meeting or cancels it several times and sends a representative on his/her behalf, the client attends meetings with a third party and there is a suspicion that he/she is in a subordinate position in relation to the third party, the client insists on an unusually quick conclusion of the contractual relationship and a quick payment for the purchase of the property),

(b) the client makes heavy use of cash in its business (cash payment is appropriate for the payment of the brokerage fee, but the risk arises if the client wants to pay a high purchase price for the purchase of the property in cash),

c) the client wishes to preserve his/her anonymity as much as possible, even in actions where this is unusual (e.g. signing a contract without the presence of a representative of the Company or the other party),

(c) the ownership structure of the client appears unusual or excessively complex having regard to the nature of its business or the client uses shell firms in its business.

In relation to trading and trading activity, the Company considers, in particular, whether
the client does not insist on an unusually complicated deal structure that tries to make it difficult to identify the end user of the benefits,
the client uses funds from foreign entities that may be interconnected or any other third party to pay the price,
the client notifies that he/she wishes to transfer the acquired property to other persons in the short term,
transactions are proposed or executed in the course of trade that have no economic or commercial significance,
the planned trade is unusually large.
The Company will take into account the geographic risk of a trade if it is to take place in a country considered high risk by the European Commission or another international organisation, a country with a high level of corruption or other criminal activity, a country subject to international sanctions and embargoes, countries that financially support terrorist organisations or in whose territories terrorist organisations operate.

The Company assesses the risks for each client comprehensively and takes into account all the circumstances and contexts known to the Company in relation to the client, the business relationship and the business.

Over time, the Company assesses or reassesses risks:

a) at the conclusion of the business relationship - from the first contact with the client, the business relationship,

(b) when carrying out occasional trade outside a business relationship - from the first contact with the client,

(d) when terminating the business relationship.

Risk assessment or risk reassessment shall be carried out by the Company in accordance with:

a) information and documents provided by the client, the business relationship,

(b) information already obtained and about the client from previous business dealings with the client or trades executed,

(d) risk indicators relating to the client, the business relationship or the trade.

Any change to a previously determined risk, consisting of a downgrade or reclassification to a higher risk category, must be recorded in writing by the Company, together with the reasons for the reassessment and the change in risk.

Based on the procedure set out in paragraphs 1 to 8 of this Article, the company shall recognise:

a) low risk,

(b) risky,

c) high risk,

(d) unacceptable.

The Company takes into account the national risk assessment developed by the financial reporting entity.

The company manages and mitigates risk (measures):
by carrying out client identification and verification of identification when executing a trade whose value reaches at least EUR 1,000 and does not exceed EUR 10,000,
by exercising due diligence - basic, simplified or enhanced due diligence - at the time of entering into and during the course of the business relationship or when conducting business outside the business relationship,
accepting payments from customers in the execution of transactions, in particular by means of bank transfers, card transactions or deposits into a bank account in a Member State or in a third country guaranteeing an equivalent level of protection against money laundering and terrorist financing,
instruct the client to specify in the contract, the subject of which is a financial transaction that does not go to the Company's account (e.g. purchase contract, lease contract) a bank account maintained in a Member State or in a third country guaranteeing an equivalent level of protection against money laundering and terrorist financing,
by delaying an unusual business operation,
by reporting an unusual commercial operation,
refusing to enter into a business relationship, terminating a business relationship or refusing to execute a trade and subsequently reporting an unusual business transaction.

If, in the opinion of the Company, further action is necessary to eliminate the increased risk, the Company, through its Managing Director, shall take such action and record its implementation in writing. (Example - the Company will proceed from basic care to enhanced care even without the client being subject to enhanced care. The Company asks the client to make the first payment through an account opened in his/her name(s) at a credit institution, asks the client to obtain approval to enter into the transaction from the employee's immediate supervisor.)

Article VIII

Overview of forms of unusual business operations

in relation to the Company's activities

Unusual business operation (NOO) is a legal or other act which indicates that its performance may lead to the laundering of the proceeds of crime or the financing of terrorism.

In the Company's operating environment, NOO is primarily a business:

which, by reason of its complexity, unusually large amount of funds or other nature, is manifestly outside the normal scope or nature of a particular type of trade or a particular client's trade,
which, by reason of its complexity, unusually large amount of funds or other nature, has no obvious economic purpose or obvious lawful purpose,
where the client refuses to identify himself or to provide the data necessary for the company to carry out the care,
where the client refuses to provide information about a pending trade or tries to provide as little information as possible or provides information that is very difficult or costly for the Company to verify,
in which the client provided information that later turned out to be false,
where the client asks for it to be carried out on the basis of a project that raises doubts,
where funds of low nominal value are used in a disproportionately high volume,
with a client who, because of his or her occupation, status or other characteristics, may be presumed not to be, or not to be in a position to be, the owner of the necessary funds,
which is clearly intended to be purely fictitious and may be used for possible laundering or terrorist financing,
where the client wants to pay for a property that has been brokered in cash and the amount of funds involved is at least EUR 100,000,
in which the client, without any apparent economic or other lawful purpose, requests the mediation of the purchase and immediate subsequent sale of the property,
where the client, without any apparent economic or other lawful purpose, requests mediation in the purchase of real estate and is willing to pay a price unusually above the market value,
in which the client induces time pressure and tries to get the Company under time pressure,
where the Client forces the Company to breach its obligations or to act quickly and unbureaucratically without any apparent reason for doing so,
where funds are sent (or transferred or deposited into a bank account) to the Company as if "by mistake" from a known client or a previously unknown entity and a subsequent request for their repayment (the client or entity requests repayment in cash, by cheque or to another account specified by the client or entity),
associated with the urgent transfer of the property at a price that differs significantly from the normal market price,
if the client applies for the mediation of the lease of a property of which he has no knowledge as to its characteristics, condition, etc., and is not interested in such information,
where the amount of funds at the client's disposal is manifestly disproportionate to the nature or extent of his business activity or his declared assets,
where the client acts as an intermediary or is accompanied by another unknown person or persons,
the client is nervous for unknown reasons compared to previous visits and pushes to close the deal,
where the Client wishes to execute a trade from an account that the Client has indicated as his/her own, but which does not belong to him/her and the Company is unable to verify the account,
where there is a reasonable belief that the funds or property to be used or which has been used to finance terrorism are the proceeds of crime or are related to the financing of terrorism,
where there is a reasonable expectation that the ultimate beneficial owner is a person who collects or provides funds or property for the purpose of financing terrorism that is carried out from or to a country in the territory of which terrorist organisations operate, or who provides funds or other support to terrorist organisations,
where there is a reasonable expectation that the client or ultimate beneficiary is a person subject to international sanctions under a specific provision, or a person who may be related to a person subject to international sanctions under a specific provision; or
where there is a reasonable presumption that the subject matter is or is intended to be an item or service that may be related to an item or service subject to an international sanction under a specific provision.

An NOO may also be a trade not listed above, but to the Company's knowledge of the client, the business relationship or the trade, it is outside the scope of previous known business activity, or exhibits other unusual circumstances (unreliable documents, non-standard execution requirements, etc.).

Article IX

Procedure for detecting an unusual commercial transaction

For each trade that is prepared or executed, the Company assesses the trade for its normal course of business, assesses and manages risk in doing so, and applies the know your customer principle. This is based on the correct application of appropriate client due diligence and the Company compares each trade being prepared or executed against a review of the forms of NOO.

The company pays special attention to:
all complex, unusually large trades and all trades of an unusual nature which have no obvious economic purpose or obvious lawful purpose, and the Company shall investigate the purpose of such trades as far as possible by exercising due diligence in relation to the client and by verifying information from independent sources; the Company, through the Managing Director, shall at the same time make a written record of such trades,
any risk that may arise from the type of trade, the specific trade and shall take appropriate measures, if necessary, to prevent their use for money laundering and terrorist financing purposes.

In assessing trades, the Company shall:
the client had no reason to believe that the trade it was preparing or executing was being treated by the Company as a NOO,
provided the client with sufficient time to explain the plausibility/transparency of the trade being prepared or executed (including the submission of relevant documents),
in the event that the Client ascertains the grounds on which the information and written documents are requested from the Client, the Company shall indicate to the Client that a comprehensive overview of the trade is a condition for its proper execution,
in cases where the Client directly asks whether its trades can be reported, the Company responds to the Client that the Company complies with all laws governing the business,
did not comment to any client on suspected money laundering, suspected terrorist financing, or the possible assessment and reporting of NOOs.

If the Company, following the procedure under this Scheme, judges a trade being prepared or executed to be unusual, the Managing Director responsible for that trade shall immediately prepare an internal report and gather all supporting documentation so that the NOO can be reported to the Financial Intelligence Unit without undue delay.

During the assessment of the NOO report, the company shall hold the trade until the unusual trade has been reported to the financial reporting unit. In the event that the client is investigating the reason why the trade has not yet been executed the Company will indicate technical problems and/or other credible facts that may affect the speed of the trade.

The company maintains a list of NOOs and, after preparing an internal report, assigns a serial number and year to the report with information on the resolution of the NOO. The managing director responsible for communication with the financial reporting unit shall review the NOO report. If it is not a NOO, the Company shall carry out the delayed trade. If it is a NOO, an urgent report to the Financial Reporting Unit will be made. All internal NOO reports are retained by the Company.

The company is required to report the NOO, as well as the refusal to execute the NOO, without undue delay to the financial reporting entity. The notification may be made by the Company in person, in writing, electronically or by telephone, if the matter cannot be delayed. The telephone notification must be completed in writing or in person within three days. A template for the report is attached to this Scheme.

Contact details for reporting NOOs:

Financial Police Intelligence Unit of the Office for Combating Organised Crime of the Presidium of the Police Corps

Pribinova 2

812 72 Bratislava Tel:(+421)96101402 Fax: (+421) 9610 590 47

Electronic reporting of a complaint can be done via the web-based application part of the goAML information system.

Upon written request, the Company shall notify the Financial Reporting Entity, upon written request, of additional information to the NOI report and provide related NOI documentation.

The reporting of a NOO is without prejudice to the obligation to report facts suggesting that a criminal offence has been committed.

The company is obliged to refuse to enter into a business relationship, to terminate a business relationship or to refuse to execute a specific trade if

(a) the obliged person is unable to carry out the care in relation to the client which he or she is required by law to carry out; and/or

(b) the client refuses to prove on whose behalf he is acting,

A company shall delay an EOI if there is a risk that its execution may frustrate or materially impede the seizure of proceeds of crime or terrorist financing, or if requested in writing by a financial intelligence unit, until it has received notification from the financial intelligence unit to execute the EOI, but for no more than 120 hours. After that period, the Company shall delay the NOO upon notification by the FIU that it has handed the matter over to law enforcement authorities, but not for more than a further 72 hours. Saturdays and public holidays shall not be counted as part of the NOO hold period. The obliged person shall immediately inform the financial intelligence unit of the delay of the NOO.

However, the company will not withhold the NOO if

(a) it cannot be delayed for operational or technical reasons; the obliged person shall immediately inform the financial intelligence unit of this fact; or

(b) the delay could, according to the prior warning of the financial intelligence unit, frustrate the processing of the NOO.

In the event that the Company, in assessing the conditions and risks of a trade, concludes that it is not a NOO and proceeds to execute the trade, it is obliged to make a written record of its assessment.

Article X

Other Obligations of the Company

The Company, and specifically the two Managing Directors ensuring compliance with the obligations under the Scheme, are required to maintain confidentiality regarding the reporting of the NOO and the actions taken by the Financial Reporting Entity in relation to third parties, including the persons to whom such information relates, as well as any additional information requested by the Financial Reporting Entity.

In the event that a financial intelligence unit requests data on business relationships, transactions, documents and information on persons who have participated in any way in a transaction in order to fulfil its statutory tasks, the Company shall also maintain the confidentiality of such a request.

In the performance of its tasks, the Company is entitled to process the personal data of its clients without consent, namely to ascertain, obtain, record, store, use and otherwise process them. The Company is entitled to obtain personal data necessary to achieve the purpose of the processing by copying, scanning or otherwise recording official documents on an information carrier and to process birth numbers and other data and documents without the consent of the data subject.

The company is thus entitled to make copies of official documents, identity cards and other documents presented in the course of the business relationship. The copies of the documents must be made in such a way that the relevant data are legible and the possibility of preserving them is ensured; the representation of the identified natural person in the identity document must be of such quality as to enable the conformity of the likeness of the identified person to be verified.

The firm is required to retain for a period of five years from the end of the contractual relationship with the client or from the execution of an occasional trade outside the business relationship

(a) data and written evidence obtained in the course of providing care to clients,

(b) all data and written evidence of the transactions carried out,

(c) all data obtained in the course of exercising due diligence in relation to the client, records of the process of assessing and determining the client's risk profile, business correspondence, the results of analyses carried out, records of all actions taken, including any obstacles related thereto, in a manner and to an extent that ensures the verifiability of the individual trades and the procedures associated with them.

The reporting financial entity may request the Company to extend the retention period, specifying the scope of the retention of data and written documents. The extended period shall not exceed an additional five (5) years.

Article XI

Final provisions

The programme is binding on both Managing Directors of the Company. In the event that an employee is employed by the Company, the Programme will be updated to reflect this. The new employee will be duly familiarised with the Programme and the content and timetable of his/her training will also be set.

As the Company has only two managing directors, the person responsible for the performance of tasks under this Programme and for ongoing liaison with the Financial Intelligence Unit is Mgr. Katarína Vlasáková.

Both Directors of the Company have been duly informed of this Scheme and undertake to comply with it. Both Managing Directors confirm that they have permanent access to the Programme.

Training is carried out on a regular basis once a year, when the Programme is again reviewed in detail by the Managing Directors to assess whether there has been any change in the legislation. Training shall take place whenever there is a material change in the Law or an amendment to the Programme.

The Managing Director, designated as the person responsible for ensuring the performance of tasks under this Programme, shall continuously monitor compliance with the Programme during the provision of services to clients.

The Company shall update the Programme if new NOOs or new risks are identified and in the event of a change in the legislation on the protection against money laundering and terrorist financing.

The programme can only be changed in writing. The programme shall always be drawn up as a complete version with the date of update.

The following annexes are an integral part of the Programme:

Annex 1 - Declaration of the final beneficiary

Annex 2 - Declaration of origin of funds

Annex 3 - Statement of Procedure

Annex 4 - Internal NOO reporting

Annex 5 NOO reporting for the financial reporting unit

In Bratislava, on 1.1.2010

Last updated: 15.1.2025

_________________________________________

LUMIA PROPERTY MANAGEMENT s. r. o.

Substitute: Mgr. Katarína Vlasáková, managing director

Annex 1

Client's declaration of end-user benefits

Pursuant to the provisions of Act No. 297/2008 Coll. on the Protection against the Legalization of the Proceeds of Crime and on the Protection against the Financing of Terrorism and on Amendments and Supplements to Certain Acts, as amended, LUMIA PROPERTY MANAGEMENT s.r.o., with its registered office at Krasovského 3742/13, 851 01 Bratislava, ID No.: 36 803 898, when carrying out basic care in relation to a client, requires the client to notify and identify the actual end user of the benefits.

Client identification data:

Business name
Headquarters
ID
Represented by

declares that the end-user of the benefits is a natural person:

First name Last name	Birth number / date of birth[1]	Address of permanent residence	Nationality

Bratislava, on _______________

____________________________

client

Annex 2

DECLARATION OF ORIGIN OF FUNDS

Pursuant to Act No. 297/2008 Coll. on the Protection against the Legalization of the Proceeds of Crime and on the Protection against the Financing of Terrorism and on Amendments and Supplements to Certain Acts, LUMIA PROPERTY MANAGEMENT s.r.o. with its registered office at Krasovského 3742/13, 851 01 Bratislava, ID No.: 36 803 898 (the Company) is obliged to apply measures against the legalization of the proceeds of crime and the financing of terrorism, including the continuous monitoring of business relations with the client. In view of the above, the Company requests the following information regarding the origin of the funds to be used to execute the trade when providing basic client care.

Client identification data:

Name and surname /Business name
Permanent residence / Registered office
Date of birth / ID number
Business:	Purchase contract / Brokerage contract / Lease contract

I hereby declare as a client that the funds I wish to use in the trade/business relationship are:

income from employment, including employment bonuses, severance pay, redundancy payments
revenue from social contributions and benefits
income from business activities
income for performing a function in a company (e.g. performance contract with a managing director/board member)
freelance income
Heritage
more
winning the lottery
income from a court order awarding, for example: damages, settlements or maintenance
old-age pension, invalidity pension or other social benefits
income from the rental or sale of immovable property,
income from the sale of antiques, jewellery or works of art
credit or loan
proceeds from the sale of securities, shares, interests and the exercise of rights arising therefrom
funds from renting, leasing, sale of assets
funds originating from end-user funding
commission or interest on the loan
revenue from the sale of intellectual property rights, including patents
franchise income
revenue from virtual cryptocurrencies
other (please specify):

Bratislava, on __________________

______________________________________

client

Annex 3

Declaration of acting on own behalf

Pursuant to the provisions of Act No. 297/2008 Coll. on the Protection against the Legalization of the Proceeds from Crime and on the Protection against the Financing of Terrorism and on Amendments and Supplements to Certain Acts, as amended, LUMIA PROPERTY MANAGEMENT s.r.o., with its registered office at Krasovského 3742/13, 851 01 Bratislava, ID No.: 36 803 898, when exercising basic care in relation to a client, requires that the client informs the company whether it is acting on its own behalf or whether it has properly identified the person it is representing in the proceeding.

Client identification data:

First name Last name / Business name
Permanently residing / Registered office
Birth number / ID number
Represented by

The Client hereby declares that:

acts on his own behalf
represents a third party

Third party identification data:

First name Last name / Business name
Permanently residing / Registered office
Birth number / ID number

Bratislava, on __________________

_________________________________

client

Annex 4

Internal reporting of an unusual business operation

The client involved in the unusual business operation:

Identification data of the client - natural person

First name Last name
Permanently residing
Birth number / Date of birth
Type and number of identity card
Nationality
Place of business
Identification number
Register/Evidence for business activities
Bank account number

Identification data of the client - legal entity:

Business name
Headquarters
Identification number
Register/Evidencia
Number of entry in the register/record
Represented by
Bank account number

Business relationship / Business

Type of contract
Date of conclusion
Transaction amount

Details of the unusualness of the business operation:

[reason for unusual NOO by program, information on material circumstances of the trade, timing of events]

Details of third parties who have knowledge of the unusual business operation:

First name Last name
Permanently residing
Birth number / Date of birth
Relationship to the obliged person

Done at Bratislava, on_______________

Annex 5

Reporting an unusual commercial operation

Obliged person:

LUMIA PROPERTY MANAGEMENT s.r.o. with its registered office at Krasovského 3742/13, 851 01 Bratislava, ID No.: 36 803 898, registered in the Commercial Register kept by the Municipal Court of Bratislava III, Section Sro, Insert No. 46903/B, represented by the Managing Director: Mgr. Katarína Vlasáková, telephone contact: 0918/186963 (Company).

The client involved in the unusual business operation:

Identification data of the client - natural person

First name Last name
Permanently residing
Birth number / Date of birth
Type and number of identity card
Nationality
Place of business
Identification number
Register/Evidence for business activities
Bank account number

Identification data of the client - legal entity:

Business name
Headquarters
Identification number
Register/Evidencia
Number of entry in the register/record
Represented by
Bank account number

Details of the unusualness of the business operation:

[reason for unusualness, information about the material circumstances of the transaction, timing of events]

Details of third parties who have knowledge of the unusual business operation:

First name Last name
Permanently residing
Birth number / Date of birth
Relationship to the obliged person

The obliged person shall provide the following documents:

Photocopies of identity documents
Photocopies of the concluded contract with the client
[l]
[l]

Done at Bratislava, on_______________

___________________________________________

LUMIA PROPERTY MANAGEMENT, s.r.o.

Replaced by. Mgr. Katarína Vlasáková

Managing Director

[1] Indicate date of birth if no birth number has been assigned

Internal program focused on preventing the legalization of proceeds from criminal activity and financing of terrorism

The Client hereby declares that: