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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 s. r. o. with its registered office Riečna 154/2 811 02 Bratislava – Staré Mesto district, company registration number: 57585253, registered in the Commercial Register maintained by the Municipal Court Bratislava III, section Sro, file no. 198895/B Company.

The programme governs the procedure of the Company and its representatives in preventing the laundering of proceeds from criminal activity and in preventing the financing of terrorism according to Act No. 297/2008 Coll. on the prevention of money laundering and terrorist financing and amending certain acts, as amended (Act).

In the course of its business activities, the company is authorised to act as an intermediary in the sale, letting or purchase of immovable property and is an obliged entity under Section 5(1)(i) of the Act.

Article I.

Purpose of the Programme

The programme lays down the conditions and specific working procedures for the Company's directors and employees in preventing money laundering and the financing of terrorism, defines responsibilities, rights, and obligations when implementing measures against money laundering and the financing of terrorism, and ensures the flow of information on measures taken in connection with protection against money laundering and the financing of terrorism.

The programme is binding on the directors and all employees who perform tasks in accordance with the Act. The fulfilment of individual obligations, which are defined below for the Company, in relation to a specific client is always ensured by the director or the employee who is responsible for the given business with the client.

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 act or other act which indicates that its performance may result in the legitimisation or financing of terrorism. The individual forms of unusual business transactions 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, a State Secretary or a similar representative of a 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 other higher-level judicial bodies, against whose decisions, save in specific cases, no further appeal is possible; the President of the Judicial Council of the Slovak Republic, the Vice-President of the Judicial Council of the Slovak Republic, the President of the Specialised Criminal Court, the Vice-President of the Specialised Criminal Court, the President of a regional court, the Vice-President of a regional court, the President of an administrative court, the Vice-President of the Administrative Court, the President of a District Court or the Vice-President of a District Court, a member of the Court of Auditors or the Governing Council of the central bank, an ambassador, a chargé d’affaires, a high-ranking member of the armed forces, the armed corps or the armed security forces, a member of the governing body, supervisory body or control body of a state-owned enterprise or commercial company, the Attorney General, the Deputy Attorney General, a Special Prosecutor, a Deputy Special Prosecutor, a Regional Prosecutor, a Deputy Regional Prosecutor, district prosecutor or deputy district prosecutor, a person holding another similar position of national or regional significance or another similar position within European Union institutions or international organisations, a member of the statutory body of a political party or political movement. A politically exposed person is also deemed to be the husband, wife or a person in a similar position to the husband or wife of the person referred to in the preceding sentence, as well as a child, son-in-law, daughter-in-law, parent or a person in a similar position to the son-in-law or daughter-in-law of the person referred to in the preceding sentence. For the purposes of this Act, a politically exposed person also means a natural person who is known to be the ultimate beneficial owner of the same client or otherwise controls the same client as the person referred to in the first sentence of this paragraph, or conducts business together with the person referred to in the first sentence of this paragraph, or a client established for the benefit of the person referred to in the first sentence of this paragraph.

End user benefits - any natural person who effectively controls a legal person or a natural person who is an entrepreneur, and any natural person on whose behalf such entities carry out their activities or business. In the case of a legal person, a natural person who holds a direct or indirect share, or a combination thereof, of at least 25% of the voting rights in the legal person or of its share capital, including bearer shares, has the right to appoint, otherwise appoint or dismiss the statutory body, the management body, supervisory body or audit body of the legal entity, or any member thereof, or controls the legal entity in a manner other than that specified in the first and second points, shall be entitled to an economic benefit of at least 25% from the business of the legal entity or from any other activity thereof. In the case of a natural person–entrepreneur, a natural person who is entitled to at least 25% of the economic benefit from the business of the natural person–entrepreneur or from any other activity of that person. A natural person who is entitled to at least 25% of the economic benefit from the business of a legal entity in which they are a silent partner is also considered a beneficial owner. In the case of a general partnership or a limited partnership, a natural person who is a partner, or who directly or indirectly, through an ownership interest or by other means, controls a partner who is a legal person. In the case of an asset association, the beneficial owner is deemed to be the natural person who is the founder or promoter of the asset association; if the founder or promoter is a legal person, the natural person referred to in the preceding subparagraph is deemed to be the beneficial owner in accordance with the definition applicable to a legal person, or, where applicable, the natural person who has the right to appoint, otherwise appoint or dismiss the statutory body, management body, supervisory body or control body of the pool of assets or a member thereof, or is a member of a body which has the right to appoint, otherwise appoint or dismiss these bodies or their members, or a person who is a statutory body, management body, supervisory body, control body or a member of these bodies, or is a recipient of at least 25% of the funds provided by the asset association, if the future recipients of these funds have been designated; if the future beneficiaries are designated according to a characteristic, that characteristic shall be specified, and the beneficial owners shall become such at the moment of their identification or designation; and if the future beneficiaries of the assets of the trust have not been designated, the group of persons who derive significant benefit from the establishment or operation of the trust, or a natural person appointed to represent and protect the interests of the beneficiaries of the trust, shall be deemed to be the ultimate beneficial owners. If no natural person meets the criteria set out in the first sentence, the members of that person’s senior management shall be deemed to be the beneficial owners; a statutory body or members of a statutory body shall be deemed to be a member of senior management. A beneficial owner is also a natural person who does not themselves meet the criteria set out in the preceding sentences, but who, together with another person acting in concert or in a joint arrangement with them, meets at least some of those criteria.

Client – a contracting party is a contracting party to a contractual relationship related to the business activity of the obligated person, or participates in proceedings on the basis of which it is to become a contracting party to a contractual relationship related to the business activity of the obligated person, or represents a contracting party to a contractual relationship related to the business activity of the obligated person in proceedings with the obligated person, or is authorised to deal with the subject of a contractual relationship related to the business activity of the obligated person based on other facts. The most frequent Client of the Company is a person 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

Customer care

Client care represents the sum of the Company's duties performed in its business activities in relation to its clients under the Act, in order to be able to know its client and subsequently recognise that there is a risk in relation to the planned business transaction.

We classify due diligence according to the scope of the Company’s obligations into basic, reduced and enhanced due diligence.

The Company shall determine the level of customer due diligence appropriate to the risk of money laundering or terrorist financing. When 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 identify each of its clients and subsequently verify this identification. It carries out basic due diligence in relation to all clients. During its performance, it may conclude that, in addition to basic due diligence, duties of enhanced due diligence, as set out in Article VI of this Programme, need to be fulfilled.

A Client identification

If the client is an individual, they should identify themselves by duly providing the Company with their first name, surname, date of birth, personal identification number, permanent residence, nationality, type and number of their identity document at the beginning of the business relationship or transaction. If the individual also conducts business and the business relationship or transaction relates to this business, they shall also inform the Company of the address of their registered place of business, the address of the actual place of business operations, if different from the registered place of business, their identification number, and indicate the official register or record in which they are registered and their registration number.

If the Company’s client is a legal person or an association of assets, for identification purposes it must provide its name, registered office address, the address of the actual place of business (if different from the registered office address), identification numbers, the name of the register or register in which it is entered, and the registration number. At the same time, a natural person authorised to act on behalf of the legal entity is also required to identify themselves to the extent of the data specified in paragraph 2 of this article of the Programme.

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

If the client is a minor without identification documents, the data collected in relation to the minor shall include their first name, surname, date of birth, personal identification number, permanent address and nationality; their legal representative should provide the Company with the data specified in paragraph 2 concerning the identification of a natural person.

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 document that the client provided during the identification process. Upon presentation of this identity document, the Company will verify and compare the information provided with the details on the identity document presented. At the same time, the Company will verify that the photograph on the identity document matches the client’s actual appearance. The client should be physically present during identification.

If the client is a natural person who is also a business owner, the Company will also verify the accuracy of the information provided in relation to the client’s business activities and will itself check the information in the register or records in which the client is listed. If such a register or record is not publicly accessible, the Company will ask the client to provide a confirmation and/or extract from that register or record and will verify the accuracy of the identification on the basis of such a document.

If when verifying a natural person the Company ascertains that they are a politically exposed person or a person resident in a country designated as high-risk by the European Commission or another authorised institution, the Company shall, in addition to basic due diligence, also carry out enhanced due diligence pursuant to Article VI of the Programme.

If the client is a legal entity, the Company shall verify the correctness of the provided data on the basis of documents, data or information obtained from an official register or other official record in which the legal entity is registered, or from another trustworthy 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 according to paragraph 7 of this Article.

When representing a person based on a power of attorney, the Company shall verify the provided data based on documents, data, or information obtained from the submitted power of attorney with a notarised signature, an official register or other official record, or from another trustworthy and independent source. The Company shall verify the representative themselves in their physical presence by comparing the data on the power of attorney with the presented identity document. If representation is carried out based on a power of attorney, the authenticity of the grantor's signature on the power of attorney must be officially notarised.

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 has doubts when verifying the identity of a natural person as to whether the identity document presented by the client is false, altered, or actually belongs to that natural person, the Company shall ask the natural www.minv.sk.

If the Company has any doubts when verifying the identity of a legal entity, it will request further documentation from the official register or records in which the client is registered for the purpose of identification. This may include, for example, a certificate of registration with the tax office.

The client is obliged to provide the requested information and documents that are necessary for their identification and verification. The company will make legible copies of the identity document and other submitted documents and will retain them throughout the business relationship, as well as after its termination for the period specified in Article X of this Programme.

Confirmation of beneficial final user

The company identifies the beneficial owner of a client who is a legal entity or an association of assets using the register of beneficial owners maintained by the Statistical Office of the Slovak Republic. The Company has established access to the register of beneficial owners and, upon its electronic request, data on the client’s beneficial owner is provided electronically in an automated manner. The Company verifies the information from the register of beneficial owners during a conversation with the client. Should there be a suspicion that the person registered as the beneficial owner is not the actual beneficial owner, the Company will request the completion of a declaration of beneficial ownership, a template of which is attached to this Programme. Where there is another reliable source from which information about the beneficial owner could be obtained, and to which the Company has access, the Company shall also verify this information from that source.

In cases where the client is a foreign legal entity or an association of property, the Company shall request the client to complete a declaration of beneficial owner.

In the event that the Company ascertains that the beneficial owner is a politically exposed person or a sanctioned person, it shall proceed in accordance with the enhanced customer due diligence rules under Article VI of this Programme.

D Acquisition and evaluation of trade information

The company, in cooperation with the client, shall ascertain the purpose and intended nature of the transaction or business relationship and assess the truthfulness of that information.

The company's activities will primarily focus on ascertaining the reason for selling, buying, or renting a property. The company will focus on whether the client is buying or selling a property to resolve their own housing situation or what specific intention the client has with the property. The company will also verify how the client intends to deal with the purchased property, whether they are interested in using it long-term, renting it out, or anticipate an early transfer.

The company will then assess the information provided to determine whether it appears to be accurate and acceptable in terms of standard property management practices, or whether the client has provided information that is contradictory or unusual in the context of property management.

In the event that the client is a legal entity, the Company shall also obtain information on the nature of the client's business, for the purpose of understanding the nature of the client's business, ownership structure, and management structure, where relevant to the intended transaction.

E Information gathering on the origin of funds used in a transaction

When communicating with a client, the company ascertains the source of the funds used to purchase the property. In particular, it ascertains whether the funds are the client’s own resources, e.g. savings or an inheritance, or whether they are funds from a third party (e.g. a bank or another person who has provided the client with a loan). In order to ascertain the origin of the funds, the Company will ask the client to provide a declaration of the origin of the funds, which forms an annex to this Programme.

The company will also, when communicating with the client, assess whether the client's own financial resources appear to be adequate considering their profession, business activity or status, or the reason for their acquisition (e.g. inheritance, gift). In cases where the client acquired monetary funds from a third party other than a bank, the company will attempt to ascertain the relationship between the client and the third party and the reason/legal title for the provision of the monetary funds.

F Ascertaining whether the client is acting in their own name

The company will verify when communicating with the client whether the client is acting in their own name or on behalf of another person in the business relationship. The company will ask the client to confirm whether the client is acting in their own name in a declaration that forms Annex 1 to this Programme.

If the Company ascertains or suspects that the client is not acting in their own name, it shall request them to prove, by means of a binding written declaration, the name, surname, personal identification 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 the transaction is being carried out. A template declaration is attached to this Programme.

Ongoing monitoring of the business relationship during its duration

The company continuously monitors this business relationship and individual transactions conducted during it throughout its duration. The company specifically monitors whether the information obtained during basic client due diligence is consistent with the executed transactions. The company also monitors whether there are any changes in discovered facts, or if there is any inconsistency between the facts stated by the client and the actual situation. The company records and updates any changes in information along with identifying data. The company constantly monitors and assesses the risk associated with the client and the source of funds and assets used in the transaction/business relationship.

Situations where the Company is obliged to perform essential customer 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) if substantial changes occur with the client that could affect the risk of money laundering or terrorist financing.

A situation where the Company does not perform basic care for a 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 customer 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 carrying out an unusual business transaction, and if there is doubt as to whether it is simplified due diligence, the Company shall proceed with performing enhanced due diligence.

The company may proceed with simplified due diligence if the planned transaction with the client presents a low risk of money laundering or terrorist financing in accordance with Article VII of the Programme and in relation to the client category and transaction:

riadne zdůvodnil jejich nízké riziko v hodnocení rizik.

were not assessed as risky in the national risk assessment

the conditions for the exercise of enhanced care are not met.

When providing simplified client care, the Company

verify and record compliance with the conditions for simplified care

identify the client and the person acting for the client,

in an appropriate manner, ascertains and records data on the beneficial owner and checks whether the client is 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 is obliged to keep a record of the fulfilment of the conditions for carrying out simplified due diligence in relation to each client for whom simplified due diligence has been applied.

The company will only apply simplified due diligence if the risk of unusual business due diligence is not confirmed.

Article VI

Enhanced customer care

The company exercises enhanced due diligence if, on the basis of a risk assessment carried out in accordance with Article VII of the Programme, any client, type of transaction or specific transaction presents a higher risk of money laundering or terrorist financing.

The obliged entity shall always exercise enhanced due diligence when entering into a transaction or business relationship with a politically exposed person or with a person established in a country that has been determined to be high-risk by the European Commission, an intergovernmental institution, or an international organisation that establishes internationally recognised standards for the prevention of money laundering and terrorist financing and monitors their compliance. A person established in a high-risk country is considered to be an individual if they are a national of a high-risk country or have permanent or other residency there, a sole trader if they have their place of business there, and a legal entity if it has its registered office, branch, organisational unit, or place of business 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 will apply enhanced due diligence if the client is not physically present during the identification process and the subsequent verification of that identification, and if the risk assessment indicates that enhanced due diligence is required. The Company will request the submission of additional documents, data and information to carry out the identification and will 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,

from the client that the first payment under the transaction should be made from this bank account.

Where a client of the Company is a politically exposed person, the Company shall require the client to provide the consent of the statutory body of the entity in which the politically exposed person acts, or the consent of the person responsible within that entity for carrying out tasks relating to the prevention of money laundering and terrorist financing, the reporting of unusual business transactions and through whom ongoing contact with the financial intelligence unit is maintained, prior to establishing or continuing a business relationship. At the same time, the Company shall ascertain the origin of the funds or assets used in the transaction. In relation to politically exposed persons, the Company monitors the course of the business relationship in detail and on an ongoing basis.

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 for business cooperation 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 business cooperation immediately upon being approached.

Should the Company decide to cooperate commercially, it is obliged, in the case of a trade or business relationship with a person established in a country identified as high-risk by the European Commission, to ascertain additional information about the client and the beneficial owner, additional information about the purpose and intended nature of the business relationship or trade, the origin of assets and the origin of funds used in the business relationship or trade, additional information from trusted sources, the consent of the statutory body, the designated person prior to entering into the business relationship or continuing the business relationship, and to monitor the business relationship continuously and in detail.

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

The division of risks of legalisation and financing of terrorism and their assessment

The company identifies, assesses, evaluates and updates risks relating to money laundering and terrorist financing according to the type of transactions and business relationships with clients within the scope of its business activities, and assesses whether a transaction is unusual.

The company primarily assesses risks in relation to the client, in relation to business and business cooperation, and from a geographical perspective.

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

a) the business relationship proceeds under unusual circumstances (e.g. the client does not request a personal inspection of the offered property, the client chooses the property solely from an advertisement, the client avoids personal meetings, or cancels them multiple times and sends a representative instead, the client attends meetings with a third party and there is suspicion that they are in a subordinate position in relation to them, the client insists on an unusually rapid conclusion of the contractual relationship and a quick payment for the purchase of the property),

b) the client extensively uses cash in their activities (payment of the brokerage fee in cash is appropriate; risk arises if they wish to pay a high purchase price for real estate in cash),

c) the client wishes to maintain their anonymity as much as possible, even during actions where this is unusual (e.g., signing a contract without the presence of a Company representative or the other contracting party),

c) the client's ownership structure appears unusual or unduly complex given the nature of their business, or the client uses shell companies in their transactions.

The company, in relation to trade and commercial activity, primarily considers 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 states that they wish to transfer the purchased property to other parties in the near future,

Within commerce, transactions are designed or carried out that do not have economic or business significance,

the planned trade is unusually large.

The company will consider the geographical risk of a transaction if it were to take place in a high-risk country according to the European Commission or another international organisation, in 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 where terrorist organisations operate.

The company assesses the risks for each client comprehensively, taking into account all circumstances and contexts known to it in relation to the client, business cooperation, and the transaction.

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, business relationship or transaction.

Any change to a previously determined risk, consisting of a reduction or a classification into a riskier category, must be recorded by the Company in writing, along with the reasons for the reassessment and the change in risks.

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 reduces 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 that in a contract involving financial performance, which is not paid to the Company's account (e.g. a purchase agreement, lease agreement), they should provide a bank account held in a member state or a third country that guarantees 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 the Company determines that further measures are necessary to eliminate the increased risk, the Company, through its director, shall implement these measures and document their implementation in writing. (Example – the Company will move from basic to enhanced due diligence, even if enhanced due diligence is not otherwise applicable to the client. The Company will request that the client make the first payment through an account held in their name/title at a credit institution, and will request their consent for the transaction to be concluded from their immediate superior.)

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,

when the client is causing a time crunch and the Company is trying to get under the time crunch,

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 is pushing to close the deal.,

in which the client wishes to conduct a transaction from an account they have stated is theirs, but which does not belong to them, and the Company has no way of verifying this 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

The Company assesses every transaction, whether contemplated or executed, from the perspective of its usualness. In this process, it evaluates and manages risk and applies the 'know your customer' principle. The basis for this is the correct application of appropriate customer due diligence, and the Company compares every contemplated or executed transaction against an overview of NPO forms.

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, in accordance with the procedure under this Programme, assesses a planned or executed transaction as unusual, the director responsible for that transaction shall promptly prepare an internal report and gather all supporting documents so that an SAR can be reported to the Financial Intelligence Unit without undue delay.

During the assessment of a suspicious transaction report, the Company will hold this transaction until an unusual financial transaction is reported to the Financial Intelligence Unit. If the client enquires as to why the transaction has not yet been executed, the Company will state technical problems or other plausible reasons that may affect the speed of the transaction.

The Company maintains a list of Suspicious Transactions and, after preparing an internal report, assigns a serial number and year to this report, along with information on the resolution of the Suspicious Transaction. The Managing Director responsible for communication with the Financial Intelligence Unit will assess the report on the Suspicious Transaction. If it is not a Suspicious Transaction, the Company will proceed with the deferred transaction. If it is a Suspicious Transaction, it will be immediately reported to the Financial Intelligence Unit. All internal reports on Suspicious Transactions are kept 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 receipt of a written request, the company shall notify the financial intelligence unit of any supplementary information relating to the NOO report and shall provide the relevant NOO 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,

The Company shall suspend the NOO if there is a risk that its execution may frustrate or substantially impede the recovery of proceeds of crime or funds intended for the financing of terrorism, or if the Financial Intelligence Unit requests it to do so in writing, until it receives notification from the Financial Intelligence Unit to proceed with the NOO, but for a maximum of 120 hours. Upon expiry of this period, the Company shall suspend the NOO on the basis of a notification from the financial intelligence unit that the matter has been referred to the criminal justice authorities, but for a maximum of a further 72 hours. Saturdays and public holidays shall not be counted towards the period of suspension of the NOO. The obliged person shall immediately inform the Financial Intelligence Unit of the suspension of the NOO.

However, the company will not withhold the NOO if

(a) it cannot be delayed for operational or technical reasons; in such cases, the obliged entity shall immediately inform the financial intelligence unit, or

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

Should the Company, upon assessing the conditions and risks of a business transaction, conclude that it does not constitute a reportable financial transaction and proceed with the transaction, it is obliged to prepare a written record with the justification for its assessment.

Article X

Other Obligations of the Company

The company, and specifically both directors ensuring the fulfilment of obligations under the Programme, are obliged to maintain confidentiality regarding the notification of a suspicious transaction and measures implemented by the financial intelligence unit in relation to third parties, including those to whom this information relates, as well as all additional information requested by the financial intelligence unit.

Where a financial intelligence unit requests, for the purpose of fulfilling its statutory duties, data on business relationships, transactions, documents and information concerning persons who have been involved in a transaction in any way, the Company shall also maintain confidentiality regarding such a request.

The company is authorised to process clients' personal data without consent in order to fulfil its tasks, specifically to collect, obtain, record, store, use, and otherwise process them. The company is authorised to obtain personal data necessary for the purpose of processing by copying, scanning, or otherwise recording official documents onto an information carrier, and to process personal identification numbers and other data and documents without the consent of the data subject.

The company is therefore authorised to make copies of official documents, identity cards and other deeds submitted during a business relationship. Copies of documents must be made in such a way that the relevant data is legible and can be retained; the image of the identified natural person on the identity document must be of such quality as to allow verification of the identity of the person concerned.

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 Financial Intelligence Unit may request the Company to extend the period for retaining information, specifying the scope of the retention of data and written records. The extended period may not exceed a further five (5) years.

Article XI

Final provisions

The Programme is binding on both Directors of the Company. In the event of an employee being accepted into employment with the Company, the Programme shall be updated to genuinely reflect this fact. The new employee shall be duly acquainted with the Programme, and the content and schedule of their professional training will also be set.

As the Company only has two managing directors, the person responsible for fulfilling the tasks according to this Programme and ensuring ongoing contact with the Financial Intelligence Unit is Mgr. Katarína Vlasáková.

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

Training is conducted regularly once a year, at which time the Programme is reviewed in detail by the directors and an assessment is made as to whether there have been any changes to the relevant legislation. Training will always be held in the event of a significant amendment to the Act or any amendment or addition 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 updates the Programme if new SARs or new types of risk are identified, and in the event of a change in legislation regarding money laundering and terrorist financing prevention.

The programme can only be amended in writing. The programme shall always be issued as a consolidated text with an update date.

The following annexes are an integral part of the Programme:

Annex no. 1 – Declaration of the beneficial owner

Annex No. 2 – Declaration of Origin of Funds

Annex No. 3 – Declaration of Conduct

Annex 4 - Internal NOO reporting

Annex 5 NOO reporting for the financial reporting unit

In Bratislava, on 1 January 2010

Last updated: 15.1.2025

_________________________________________

LUMIA Ltd.

Substitute: Mgr. Katarína Vlasáková, managing director

Annex 1

Client's declaration of end-user benefits

In accordance with the provisions of Act No. 297/2008 Coll. on the Prevention of Legalisation of Criminal Proceeds and on the Prevention of Terrorism Financing and on Amendments and Supplements to Certain Acts, as amended LUMIA s. r. o. with its registered office Riečna 154/2 811 02 Bratislava – Staré Mesto district, company registration number: 57585253, When carrying out basic care in relation to a client, it requires that the client informs and identifies the beneficial owner.

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

In Bratislava, on _______________

____________________________

client

Annex 2

DECLARATION OF ORIGIN OF FUNDS

In accordance with Act No. 297/2008 Coll. on Combating the Legalisation of the Proceeds of Crime and Combating the Financing of Terrorism and on Amendments and Supplements to Certain Acts, the company LUMIA s. r. o. with its registered office Riečna 154/2 811 02 Bratislava – Staré Mesto district, company registration number: 57585253 (The Company), which is obliged to implement measures against the legalisation of proceeds from criminal activity and the financing of terrorism, including ongoing monitoring of business relationships with the client. With regard to the above, the Company requests that when carrying out basic customer due diligence, the following information regarding the origin of financial resources intended for the execution of the transaction be provided.

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 from performing a function in a business company (e.g. a performance contract with a managing director/board member)

freelance income

Heritage

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

commissions or interest on a loan

revenue from the sale of intellectual property rights, including patents

franchise income

income from virtual crypto currencies

other (please specify):

In Bratislava, on __________________

______________________________________

client

Annex 3

Declaration of acting on one’s own behalf

In accordance with the provisions of Act No. 297/2008 Coll. on the Protection against the Laundering of Proceeds of Crime and the Protection against the Financing of Terrorism and on Amendments and Supplements to Certain Acts, as amended, LUMIA s.r.o., with its registered office at Krasovského 3742/13, 851 01 Bratislava, IČO: 36 803 898, when performing its due diligence in relation to a client, requires the client to inform it whether they are acting in their own name or to identify the person they are duly representing.

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
Registration number in the register / record
Represented by
Bank account number

Business relationship / Business

Type of contract
Date of conclusion
Transaction amount

Unusual trade transaction information:

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

Third-party data subjects who have knowledge of an unusual business transaction:

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

In Bratislava, on the________________

Annex 5

Reporting an unusual commercial operation

Obliged person:

LUMIA s. r. o. with its registered office Riečna 154/2 811 02 Bratislava – Staré Mesto district, company registration number: 57585253, registered in the Commercial Register maintained by the Municipal Court Bratislava III, section Sro, file no. 198895/B (Company) represented by its managing director: Mgr. Katarína Vlasáková, telephone number: 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
Registration number in the register / record
Represented by
Bank account number

Unusual trade transaction information:

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

Third-party data subjects who have knowledge of an unusual business transaction:

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 contract concluded with the client

In Bratislava, on the________________

___________________________________________

LUMIA Ltd.

Replaced by. Mgr. Katarína Vlasáková

Managing Director

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

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

You can download the document below:

260521_AML_Proprietary Activity Programme_update_June 2026_2_FINAL

The programme was developed for its internal needs by LUMIA s. r. o., with its registered office at Riečna 154/2, 811 02 Bratislava, IČO: 57585253, registered in the Commercial Register kept by the Municipal Court Bratislava III, Section Sro, File No. 198895/B (the "Company").

The Programme governs the procedure of the Company and its representatives in preventing the legalisation of proceeds from criminal activity and the prevention of terrorist financing in accordance with Act No. 297/2008 Coll. on Protection against the Legalisation of Proceeds from Criminal Activity and on Protection against Terrorist Financing and on Amendments and Supplements to Certain Acts, as amended (the Act).

Article I.

Purpose of the Programme

The programme lays down the conditions and specific working procedures for the Company's directors and employees in preventing money laundering and the financing of terrorism, defines responsibilities, rights, and obligations when implementing measures against money laundering and the financing of terrorism, and ensures the flow of information on measures taken in connection with protection against money laundering and the financing of terrorism.

The programme is binding on the directors and all employees who perform tasks in accordance with the Act. The fulfilment of individual obligations, which are defined below for the Company, in relation to a specific client is always ensured by the director or the employee who is responsible for the given business with the client.

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,

(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 act or other act which indicates that its performance may result in the legitimisation or financing of terrorism. The individual forms of unusual business transactions 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, a State Secretary or a similar representative of a 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 other higher-level judicial bodies, against whose decisions, save in specific cases, no further appeal is possible; the President of the Judicial Council of the Slovak Republic, the Vice-President of the Judicial Council of the Slovak Republic, the President of the Specialised Criminal Court, the Vice-President of the Specialised Criminal Court, the President of a regional court, the Vice-President of a regional court, the President of an administrative court, the Vice-President of the Administrative Court, the President of a District Court or the Vice-President of a District Court, a member of the Court of Auditors or the Governing Council of the central bank, an ambassador, a chargé d’affaires, a high-ranking member of the armed forces, the armed corps or the armed security forces, a member of the governing body, supervisory body or control body of a state-owned enterprise or commercial company, the Attorney General, the Deputy Attorney General, a Special Prosecutor, a Deputy Special Prosecutor, a Regional Prosecutor, a Deputy Regional Prosecutor, district prosecutor or deputy district prosecutor, a person holding another similar position of national or regional significance or another similar position within European Union institutions or international organisations, a member of the statutory body of a political party or political movement. A politically exposed person is also deemed to be the husband, wife or a person in a similar position to the husband or wife of the person referred to in the preceding sentence, as well as a child, son-in-law, daughter-in-law, parent or a person in a similar position to the son-in-law or daughter-in-law of the person referred to in the preceding sentence. For the purposes of this Act, a politically exposed person also means a natural person who is known to be the ultimate beneficial owner of the same client or otherwise controls the same client as the person referred to in the first sentence of this paragraph, or conducts business together with the person referred to in the first sentence of this paragraph, or a client established for the benefit of the person referred to in the first sentence of this paragraph.

End user benefits - any natural person who effectively controls a legal person or a natural person who is an entrepreneur, and any natural person on whose behalf such entities carry out their activities or business. In the case of a legal person, a natural person who holds a direct or indirect share, or a combination thereof, of at least 25% of the voting rights in the legal person or of its share capital, including bearer shares, has the right to appoint, otherwise appoint or dismiss the statutory body, management body, supervisory body or control body of the legal person or any member thereof, controls the legal entity in a manner other than that specified in the first and second points, has the right to an economic benefit of at least 25 % from the business of the legal entity or from its other activities. In the case of a natural person–entrepreneur, a natural person who is entitled to at least 25% of the economic benefit from the business of the natural person–entrepreneur or from any other activity of that person. A natural person who is entitled to at least 25% of the economic benefit from the business of a legal entity in which they are a silent partner is also considered a beneficial owner. In the case of a general partnership or a limited partnership, a natural person who is a partner, or who directly or indirectly, through an ownership interest or by other means, controls a partner that is a legal person. In the case of a trust, the beneficial owner is deemed to be the natural person who is the settlor or founder of the trust; if the founder or establisher is a legal person, the natural person referred to in the preceding subparagraph shall be deemed the beneficial owner in accordance with the definition applicable to a legal person, or, where applicable, the natural person who has the right to appoint, otherwise designate or dismiss the statutory body, the management body, supervisory body or control body of the asset association or a member thereof, or is a member of a body which has the right to appoint, otherwise designate or dismiss these bodies or a member thereof, or a person who is a statutory body, management body, supervisory body, audit body or a member of these bodies, or is a recipient of at least 25% of the funds provided by the asset association, if the future recipients of these funds have been designated; if the future beneficiaries are designated according to a characteristic, that characteristic shall be specified, and they shall become the ultimate beneficial owners upon their identification or designation; and if the future beneficiaries of the assets of the trust have not been designated, the group of persons who derive significant benefit from the establishment or operation of the trust, or a natural person appointed to represent and protect the interests of the beneficiaries of the trust, shall be deemed to be the beneficial owner. A person who exercises actual control over the assets of the trust through direct or indirect ownership or by other means, and who is not mentioned in the preceding sentences, shall be deemed to be the beneficial owner. If no natural person meets the criteria set out in the first sentence, the members of that person’s senior management shall be deemed to be the beneficial owners; a statutory body or members of a statutory body shall be deemed to be a member of senior management. A beneficial owner is also a natural person who does not themselves meet the criteria set out in the preceding sentences, but who, together with another person acting in concert or in a joint arrangement with them, meets at least some of those criteria.

Client – a contracting party is a contracting party to a contractual relationship related to the business activity of the obligated person, or participates in proceedings on the basis of which it is to become a contracting party to a contractual relationship related to the business activity of the obligated person, or represents a contracting party to a contractual relationship related to the business activity of the obligated person in proceedings with the obligated person, or is authorised to deal with the subject of a contractual relationship related to the business activity of the obligated person based on other facts. The most frequent Client of the Company is a person 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

Customer care

Client care represents the sum of the Company's duties performed in its business activities in relation to its clients under the Act, in order to be able to know its client and subsequently recognise that there is a risk in relation to the planned business transaction.

We classify due diligence according to the scope of the Company’s obligations into basic, reduced and enhanced due diligence.

The Company shall determine the level of customer due diligence appropriate to the risk of money laundering or terrorist financing. When 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 identify each of its clients and subsequently verify this identification. It carries out basic due diligence in relation to all clients. During its performance, it may conclude that, in addition to basic due diligence, duties of enhanced due diligence, as set out in Article VI of this Programme, need to be fulfilled.

Client Identification

If the client is an individual, they should identify themselves by duly providing the Company with their first name, surname, date of birth, personal identification number, permanent residence, nationality, type and number of their identity document at the beginning of the business relationship or transaction. If the individual also conducts business and the business relationship or transaction relates to this business, they shall also inform the Company of the address of their registered place of business, the address of the actual place of business operations, if different from the registered place of business, their identification number, and indicate the official register or record in which they are registered and their registration number.

If a client of the Company is a legal entity or a legal person or an asset association, it is necessary for it to identify itself by stating its name, registered office address, addresses of actual places of business operations, if different from the registered office address, identification numbers, the designation of the register or record in which it is registered, the number of this registration, including the names and surnames of the persons who are members of the management body of the legal entity. At the same time, the natural person who is authorised to act on behalf of the legal entity must also identify themselves to the extent of the data referred to in paragraph 2 of this Article of the Programme.

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

If the client is a minor without identification documents, the data collected in relation to the minor shall include their first name, surname, date of birth, personal identification number, permanent address and nationality; their legal representative should provide the Company with the data specified in paragraph 2 concerning the identification of a natural person.

Verification of identity

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 document that the client provided during the identification process. Upon presentation of this identity document, the Company will verify and compare the information provided with the details on the identity document presented. At the same time, the Company will verify that the photograph on the identity document matches the client’s actual appearance. The client should be physically present during identification.

If the client is a natural person who is also a business owner, the Company will also verify the accuracy of the information provided in relation to the client’s business activities and will itself check the information in the register or records in which the client is listed. If such a register or record is not publicly accessible, the Company will ask the client to provide a confirmation and/or extract from that register or record and will verify the accuracy of the identification on the basis of such a document.

If when verifying a natural person the Company ascertains that they are a politically exposed person or a person resident in a country designated as high-risk by the European Commission or another authorised institution, the Company shall, in addition to basic due diligence, also carry out enhanced due diligence pursuant to Article VI of the Programme.

If the client is a legal entity, the Company shall verify the correctness of the provided data on the basis of documents, data or information obtained from an official register or other official record in which the legal entity is registered, or from another trustworthy 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 according to paragraph 7 of this Article.

When representing a person based on a power of attorney, the Company shall verify the provided data based on documents, data, or information obtained from the submitted power of attorney with a notarised signature, an official register or other official record, or from another trustworthy and independent source. The Company shall verify the representative themselves in their physical presence by comparing the data on the power of attorney with the presented identity document. If representation is carried out based on a power of attorney, the authenticity of the grantor's signature on the power of attorney must be officially notarised.

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 has doubts when verifying the identity of a natural person as to whether the identity document presented by the client is false, altered, or actually belongs to that natural person, the Company shall ask the natural minv.sk.

If the Company has any doubts when verifying the identity of a legal entity, it will request further documentation from the official register or records in which the client is registered for the purpose of identification. This may include, for example, a certificate of registration with the tax office.

The client is obliged to provide the requested information and documents that are necessary for their identification and verification. The company will make legible copies of the identity document and other submitted documents and will retain them throughout the business relationship, as well as after its termination for the period specified in Article X of this Programme.

Verification of the Ultimate User

The Company identifies the beneficial owner of a client, which is a legal entity or an asset association, with the assistance of the register of beneficial owners kept by the Statistical Office of the Slovak Republic. The Company has established access to the register of beneficial owners and, based on its electronic request, data on the client's beneficial owner are provided electronically in an automated manner. The Company verifies the information from the register of beneficial owners during discussions with the client. The Company does not rely solely on this register when identifying the beneficial owner. In the event that a suspicion arises that the person registered as the beneficial owner is not the actual beneficial owner, a declaration of truth about the beneficial owner will be requested to be completed, a template of which is attached to this Programme. If there is another credible source from which information about the beneficial owner could be obtained, and to which the Company could have access, the Company will also verify this fact from that source.

In cases where the client is a foreign legal entity or an association of property, the Company shall request the client to complete a declaration of beneficial owner.

In the event that the Company ascertains that the beneficial owner is a politically exposed person or a sanctioned person, it shall proceed in accordance with the enhanced customer due diligence rules under Article VI of this Programme.

D Obtaining and evaluating trade information

The company, in cooperation with the client, shall ascertain the purpose and intended nature of the transaction or business relationship and assess the truthfulness of that information.

The company's activities will primarily focus on ascertaining the reason for selling, buying, or renting a property. The company will focus on whether the client is buying or selling a property to resolve their own housing situation or what specific intention the client has with the property. The company will also verify how the client intends to deal with the purchased property, whether they are interested in using it long-term, renting it out, or anticipate an early transfer.

The company will then assess the information provided to determine whether it appears to be accurate and acceptable in terms of standard property management practices, or whether the client has provided information that is contradictory or unusual in the context of property management.

In the event that the client is a legal entity, the Company shall also obtain information on the nature of the client's business, for the purpose of understanding the nature of the client's business, ownership structure, and management structure, where relevant to the intended transaction.

E Information on the origin of funds used in a transaction

When communicating with a client, the company ascertains the source of the funds used to purchase the property. In particular, it ascertains whether the funds are the client’s own resources, e.g. savings or an inheritance, or whether they are funds from a third party (e.g. a bank or another person who has provided the client with a loan). In order to ascertain the origin of the funds, the Company will ask the client to provide a declaration of the origin of the funds, which forms an annex to this Programme.

The company will also, when communicating with the client, assess whether the client's own financial resources appear to be adequate considering their profession, business activity or status, or the reason for their acquisition (e.g. inheritance, gift). In cases where the client acquired monetary funds from a third party other than a bank, the company will attempt to ascertain the relationship between the client and the third party and the reason/legal title for the provision of the monetary funds.

F Zistenie, zda klient koná vlastním jménem

The company will verify when communicating with the client whether the client is acting in their own name or on behalf of another person in the business relationship. The company will ask the client to confirm whether the client is acting in their own name in a declaration that forms Annex 1 to this Programme.

If the Company ascertains or suspects that the client is not acting in their own name, it shall request them to prove, by means of a binding written declaration, the name, surname, personal identification 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 the transaction is being carried out. A template declaration is attached to this Programme.

Ongoing monitoring of the business relationship throughout its duration

The company continuously monitors this business relationship and individual transactions conducted during it throughout its duration. The company specifically monitors whether the information obtained during basic client due diligence is consistent with the executed transactions. The company also monitors whether there are any changes in discovered facts, or if there is any inconsistency between the facts stated by the client and the actual situation. The company records and updates any changes in information along with identifying data. The company constantly monitors and assesses the risk associated with the client and the source of funds and assets used in the transaction/business relationship.

Situations where the Company is obliged to undertake 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) if the client experiences significant changes that could affect the risk of money laundering or terrorist financing.

A situation where the Company does not perform basic care for a client

If the Company suspects that a client is preparing or carrying out an unusual business transaction and there is reason to believe that continuing to apply the basic due diligence measures in relation to the client may reveal this suspicion, the Company may not proceed with the performance of the basic due diligence in relation to the client.

In such a case, the Company is obliged to report an unusual business operation and state in the report:

a) the circumstances and reasons for not performing basic care in relation to the client to an extent that would allow an assessment of the suitability of such a procedure, and
b) the scope of basic care measures that the Company has not carried out.

Article V

Simplified customer 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 carrying out an unusual business transaction, and if there is doubt as to whether it is simplified due diligence, the Company shall proceed with performing enhanced due diligence.

The company may proceed with simplified due diligence if the planned transaction with the client presents a low risk of money laundering or terrorist financing in accordance with Article VII of the Programme and in relation to the client category and transaction:
riadne zdůvodnil jejich nízké riziko v hodnocení rizik.
were not assessed as risky in the national risk assessment
the conditions for the exercise of enhanced care are not met.
When providing simplified client care, the Company
verify and record compliance with the conditions for simplified care
identify the client and the person acting for the client,
in an appropriate manner, ascertains and records data on the beneficial owner and checks whether the client is 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 is obliged to keep a record of the fulfilment of the conditions for carrying out simplified due diligence in relation to each client for whom simplified due diligence has been applied.

The company will only apply simplified due diligence if the risk of unusual business due diligence is not confirmed.

Article VI

Enhanced customer care

The company exercises enhanced due diligence if, on the basis of a risk assessment carried out in accordance with Article VII of the Programme, any client, type of transaction or specific transaction presents a higher risk of money laundering or terrorist financing.
The obliged entity shall always exercise enhanced due diligence when entering into a transaction or business relationship with a politically exposed person or with a person established in a country that has been determined to be high-risk by the European Commission, an intergovernmental institution, or an international organisation that establishes internationally recognised standards for the prevention of money laundering and terrorist financing and monitors their compliance. A person established in a high-risk country is considered to be an individual if they are a national of a high-risk country or have permanent or other residency there, a sole trader if they have their place of business there, and a legal entity if it has its registered office, branch, organisational unit, or place of business 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 will apply enhanced due diligence if the client is not physically present during the identification process and the subsequent verification of that identification, and if the risk assessment indicates that enhanced due diligence is required. The Company will request the submission of additional documents, data and information to carry out the identification and will 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,
from the client that the first payment under the transaction should be made from this bank account.
Where a client of the Company is a politically exposed person, the Company shall require the client to provide the consent of the statutory body of the entity in which the politically exposed person acts, or the consent of the person responsible within that entity for carrying out tasks relating to the prevention of money laundering and terrorist financing, the reporting of unusual business transactions and through whom ongoing contact with the financial intelligence unit is maintained, prior to establishing or continuing a business relationship. At the same time, the Company shall ascertain the origin of the funds or assets used in the transaction. In relation to politically exposed persons, the Company monitors the course of the business relationship in detail and on an ongoing basis.
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 for business cooperation 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 business cooperation immediately upon being approached.
Should the Company decide to cooperate commercially, it is obliged, in the case of a trade or business relationship with a person established in a country identified as high-risk by the European Commission, to ascertain additional information about the client and the beneficial owner, additional information about the purpose and intended nature of the business relationship or trade, the origin of assets and the origin of funds used in the business relationship or trade, additional information from trusted sources, the consent of the statutory body, the designated person prior to entering into the business relationship or continuing the business relationship, and to monitor the business relationship continuously and in detail.
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

The division of risks of legalisation and financing of terrorism and their assessment

The company identifies, assesses, evaluates and updates risks relating to money laundering and terrorist financing according to the type of transactions and business relationships with clients within the scope of its business activities, and assesses whether a transaction is unusual.

The company primarily assesses risks in relation to the client, in relation to business and business cooperation, and from a geographical perspective.

In relation to the client, the firm shall assess in particular whether
a) the business relationship is proceeding under unusual circumstances (e.g., the client does not request a personal viewing of the property offered, the client chooses the property solely from the advertisement, the client avoids personal meetings or cancels them multiple times and sends a representative instead, the client attends meetings with a third party and there is suspicion that they are in a subordinate position in relation to them, the client insists on an unusually rapid conclusion of the contractual relationship and a quick payment for the property purchase),
b) the client uses cash extensively in their activities (payment of brokerage fees in cash is appropriate; risk arises if they wish to pay a high purchase price for a property in cash),
c) the client wishes to maintain their anonymity as much as possible, even during procedures where this is unusual (e.g., signing a contract without the Company's representative or the other contracting party present),
c) the client's ownership structure appears unusual or overly complex given the nature of their business, or the client uses shell companies in their transactions.
The company, in relation to trade and commercial activity, primarily considers 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 states that they wish to transfer the purchased property to other parties in the near future,
Within commerce, transactions are designed or carried out that do not have economic or business significance,
the planned trade is unusually large.
The company will consider the geographical risk of a transaction if it were to take place in a high-risk country according to the European Commission or another international organisation, in 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 where terrorist organisations operate.

The company assesses the risks for each client comprehensively, taking into account all circumstances and contexts known to it in relation to the client, business cooperation, and the transaction.

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,
(c) for the duration of the business relationship in the exercise of care in relation to 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,
(c) information from publicly available sources,
d) risk indicators relating to the client, business relationship or transaction.

Any change to a previously determined risk, consisting of a reduction or a classification into a riskier category, must be recorded by the Company in writing, along with the reasons for the reassessment and the change in risks.

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 reduces 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 that in a contract involving financial performance, which is not paid to the Company's account (e.g. a purchase agreement, lease agreement), they should provide a bank account held in a member state or a third country that guarantees 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 the Company determines that further measures are necessary to eliminate the increased risk, the Company, through its director, shall implement these measures and document their implementation in writing. (Example – the Company will move from basic to enhanced due diligence, even if enhanced due diligence is not otherwise applicable to the client. The Company will request that the client make the first payment through an account held in their name/title at a credit institution, and will request their consent for the transaction to be concluded from their immediate superior.)

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,
when the client is causing a time crunch and the Company is trying to get under the time crunch,
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 is pushing to close the deal.,
in which the client wishes to conduct a transaction from an account they have stated is theirs, but which does not belong to them, and the Company has no way of verifying this 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

The Company assesses each proposed or executed transaction for its regularity, evaluating the associated risks and applying the 'know your customer' principle. The basis for this is the correct application of appropriate customer due diligence, and the Company compares each proposed or executed transaction against an overview of NOO (Non-Operational) forms.

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, in accordance with the procedure under this Programme, assesses a planned or executed transaction as unusual, the director responsible for that transaction shall promptly prepare an internal report and gather all supporting documents so that an SAR can be reported to the Financial Intelligence Unit without undue delay.

During the assessment of a suspicious transaction report, the Company will hold this transaction until an unusual financial transaction is reported to the Financial Intelligence Unit. If the client enquires as to why the transaction has not yet been executed, the Company will state technical problems or other plausible reasons that may affect the speed of the transaction.

The Company maintains a list of Suspicious Transactions and, after preparing an internal report, assigns a serial number and year to this report, along with information on the resolution of the Suspicious Transaction. The Managing Director responsible for communication with the Financial Intelligence Unit will assess the report on the Suspicious Transaction. If it is not a Suspicious Transaction, the Company will proceed with the deferred transaction. If it is a Suspicious Transaction, it will be immediately reported to the Financial Intelligence Unit. All internal reports on Suspicious Transactions are kept by the Company.

The company is obliged to report an NPO (Non-Profit Organisation) and the refusal to carry out an NPO without undue delay to the Financial Intelligence Unit. The report can be made electronically by the Company. Electronic reporting of a report can be carried out via the web application part of the goAML information system.

Upon receipt of a written request, the company shall notify the financial intelligence unit of any supplementary information relating to the NOO report and shall provide the relevant NOO 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,
(c) if it considers that it is a NOO.

The Company shall delay the Extraordinary Obligation if there is a risk that its execution could frustrate or significantly impede the securing of proceeds of criminal activity or funds intended for the financing of terrorism, or if it is requested in writing by the Financial Intelligence Unit, until it receives notification from the Financial Intelligence Unit to proceed with the Extraordinary Obligation, for a maximum of 120 hours. After this period, the Company shall delay the Extraordinary Obligation based on a notification from the Financial Intelligence Unit that the matter has been handed over to law enforcement authorities, for a maximum of an additional 72 hours. Saturdays and public holidays shall not be counted towards the delay of the Extraordinary Obligation. The obligated person shall immediately inform the Financial Intelligence Unit of the delay of the Extraordinary Obligation.

However, the company will not withhold the NOO if
a) it cannot be delayed for operational or technical reasons; the obligated 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.

Should the Company, upon assessing the conditions and risks of a business transaction, conclude that it does not constitute a reportable financial transaction and proceed with the transaction, it is obliged to prepare a written record with the justification for its assessment.

Article X

Other Obligations of the Company

The company, and specifically both directors ensuring the fulfilment of obligations under the Programme, are obliged to maintain confidentiality regarding the notification of a suspicious transaction and measures implemented by the financial intelligence unit in relation to third parties, including those to whom this information relates, as well as all additional information requested by the financial intelligence unit.

Where a financial intelligence unit requests, for the purpose of fulfilling its statutory duties, data on business relationships, transactions, documents and information concerning persons who have been involved in a transaction in any way, the Company shall also maintain confidentiality regarding such a request.

The company is authorised to process clients' personal data without consent in order to fulfil its tasks, specifically to collect, obtain, record, store, use, and otherwise process them. The company is authorised to obtain personal data necessary for the purpose of processing by copying, scanning, or otherwise recording official documents onto an information carrier, and to process personal identification numbers and other data and documents without the consent of the data subject.

The company is therefore authorised to make copies of official documents, identity cards and other deeds submitted during a business relationship. Copies of documents must be made in such a way that the relevant data is legible and can be retained; the image of the identified natural person on the identity document must be of such quality as to allow verification of the identity of the person concerned.

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 Financial Intelligence Unit may request the Company to extend the period for retaining information, specifying the scope of the retention of data and written records. The extended period may not exceed a further five (5) years.

Article XI

Final provisions

The Programme is binding on both Directors of the Company. In the event of an employee being accepted into employment with the Company, the Programme shall be updated to genuinely reflect this fact. The new employee shall be duly acquainted with the Programme, and the content and schedule of their professional training will also be set.

As the Company only has two managing directors, the person responsible for fulfilling the tasks according to this Programme and ensuring ongoing contact with the Financial Intelligence Unit is Mgr. Katarína Vlasáková.

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

Training is conducted regularly once a year, at which time the Programme is reviewed in detail by the directors and an assessment is made as to whether there have been any changes to the relevant legislation. Training will always be held in the event of a significant amendment to the Act or any amendment or addition 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 updates the Programme in the event of the identification of new ML/TF or new types of risk, and in the event of changes to the legal framework in the area of prevention of money laundering and terrorist financing.

The programme can only be amended in writing. The programme shall always be issued as a consolidated text with an update date.

The following annexes are an integral part of the Programme:

Annex no. 1 – Declaration of the beneficial owner

Annex No. 2 – Declaration of Origin of Funds

Annex No. 3 – Declaration of Conduct

Annex 4 - Internal NOO reporting

Annex 5 NOO reporting for the financial reporting unit

In Bratislava, dated 28.04.2026

Last updated: 1.6.2026

____________________________________

LUMIA s.r.o.

Substitute: Mgr. Katarína Vlasáková, managing director

Annex 1

Client's declaration of end-user benefits

In accordance with the provisions of Act no. 297/2008 Coll. on the Protection Against Money Laundering and Protection Against the Financing of Terrorism and on Amendments to Certain Acts, as amended, LUMIA s. r. o., with its registered office at Riečna 154/2, 811 02 Bratislava, company identification number: 57585253, registered in the Commercial Register maintained by the Municipal Court Bratislava III, section Sro, file no. 198895/B, requires that when carrying out its basic due diligence in relation to a client, the client shall inform and identify the ultimate beneficial owner.

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

In Bratislava, on _______________

____________________________

client

Annex 2

DECLARATION OF ORIGIN OF FUNDS

In accordance with Act No. 297/2008 Coll. on the Prevention of Legalisation of Proceeds of Criminal Activity and on the Prevention of the Financing of Terrorism and on Amendments to Certain Acts, LUMIA s. r. o., registered at Riečna 154/2, 811 02 Bratislava, Company ID: 57585253, entered in the Commercial Register maintained by the Municipal Court Bratislava III, Section Sro, Insert No. 198895/B (the Company), is obliged to implement measures against the legalisation of proceeds of criminal activity and the financing of terrorism, including ongoing monitoring of business relationships with the client. With regard to the above, the Company requests, when providing basic client care, the following information regarding the origin of funds intended for the execution of the transaction.

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 from performing a function in a business company (e.g. a performance contract with a managing director/board member)
freelance income
Heritage
more
winning the lottery
income from a court decision awarding: damages, compensation, or alimony
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
commissions or interest on a loan
revenue from the sale of intellectual property rights, including patents
franchise income
income from virtual crypto currencies
other (please specify):

In Bratislava, on __________________

______________________________________

client

Annex 3

Declaration of acting on one’s own behalf

In accordance with the provisions of Act No. 297/2008 Coll. on Protection against the Legalisation of Proceeds from Criminal Activity and on Protection against the Financing of Terrorism and on Amendments and Supplements to Certain Acts, as amended, LUMIA s. r. o., with its registered office at Riečna 154/2, 811 02 Bratislava, Company ID: 57585253, registered in the Commercial Register kept by the Municipal Court Bratislava III, Section Sro, Insert No. 198895/B, when performing due diligence in relation to a client, requires the client to inform it whether they are acting in their own name or to identify the person they duly represent in the proceedings.

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
Registration number in the register / record
Represented by
Bank account number

Business relationship / Business

Type of contract
Date of conclusion
Transaction amount

Unusual trade transaction information:

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

Third-party data subjects who have knowledge of an unusual business transaction:

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

In Bratislava, on the________________

Annex 5

Reporting an unusual commercial operation

Obliged person:

LUMIA s. r. o., with its registered office at Riečna 154/2, 811 02 Bratislava, Company ID: 57585253, registered in the Commercial Register maintained by the Municipal Court Bratislava III, Section Sro, file no. 198895/B, represented by its Managing Director: Mgr. Katarína Vlasáková, telephone contact: 0918/186963 (the 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
Registration number in the register / record
Represented by
Bank account number

Unusual trade transaction information:

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

Third-party data subjects who have knowledge of an unusual business transaction:

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 contract concluded with the client
[l]
[l]

In Bratislava, on the________________

___________________________________________

LUMIA Ltd.

Replaced by. Mgr. Katarína Vlasáková

Managing Director

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