PLAYER PROTECTION

AML/KYC POLICIES

INTRODUCTION

 

Money laundering and the financing of terrorism (ML/FT) represent a significant threat to a country's economic, social, and political stability, as well as to global markets. Hence, the attention that governments and regulatory bodies currently pay to this phenomenon, recommending or requiring companies in the financial sector and other industries to implement a risk management system for its prevention and management.

 

ACIERTALA.COM is aware of the importance of ML/FT prevention and does not engage in any activities regulated by the law that would require the implementation of a specific policy related to the prevention of money laundering and terrorist financing. Therefore, it is not a company under the control of the Financial Intelligence Unit – Peru concerning the prevention of money laundering and terrorist financing. Nevertheless, it adopts best practices for the prevention of this matter.

 

Through this manual, ACIERTALA.COM aims to implement methodologies and procedures to design and implement a system for the prevention and control of money laundering and terrorist financing, according to best practices. It seeks to foster a culture within the organization that is oriented towards complying with the established norms in this regard.

 

Hence, this manual assigns responsibilities and establishes the duties that Shareholders, Collaborators, Directors, Managers, Attorneys, and Legal Representatives of ACIERTALA.COM must fulfill by adopting specific procedures that are mandatory.

 

1. OBJECTIVE

To provide a manual for the risk management system of money laundering and terrorist financing prevention in ACIERTALA.COM to prevent and implement controls for any transaction with a third party that may harm the company's reputation. Additionally, it demonstrates ACIERTALA.COM's commitment to the fight against ML/FT.

 

2. SCOPE

This manual's scope includes Shareholders, Directors, Managers, Representatives, and, in general, all ACIERTALA.COM staff.

 

3. LEGAL REFERENCES AND OTHER REGULATIONS

Decree-Law No. 25475 and its amending laws, which establish penalties for terrorism offenses and procedures for investigation, instruction, and trial.

Law No. 27693 and its amending laws, which create the Financial Intelligence Unit of Peru.

Law No. 27765 and its amending laws, which are the Penal Law against Money Laundering.

Supreme Decree No. 018-2006-JUS, Regulation of Law No. 27693.

SBS Resolution No. 1782-2007 and its amending laws, Regulation of Offenses and Sanctions in matters of money laundering prevention and the financing of terrorism, applicable to obligated parties that do not have a supervisory body.

Other regulations on the matter.

4. POLICIES

The following constitutes ACIERTALA.COM's general prevention policy:

 

Comply with and respect the laws and rules applicable to the Anti-Money Laundering and Counter-Terrorism Financing Prevention Manual and the Code of Ethics.

Collaborate in the fight against money laundering and terrorist financing by proposing the proper operation of the ML/FT prevention system.

Know your employees and customers, whether they are regular or occasional.

5. SANCTIONS

ACIERTALA.COM will apply corrective measures to penalize officials who directly or indirectly facilitate the use of ACIERTALA.COM as a tool for carrying out illicit operations, without prejudice to any criminal, civil, or administrative liability they may face. These measures will be detailed further below.

 

ACIERTALA.COM will reject any type of illicit operation. In accordance with the procedures set out in this Manual, ACIERTALA.COM will reject any operation or service requested by third parties that it believes arises from illicit activities.

 

Implement and disseminate the Manual: ACIERTALA.COM must, through the Compliance Officer or the individual acting in that capacity, disseminate and make known the content of the Manual. Records and analyses conducted on customer transactions, as well as the reports required by the competent authorities when necessary, shall be conducted.

 

ACIERTALA.COM places trust in its officials; therefore, these officials must carry out their activities with honesty, integrity, transparency, loyalty, and competence.

 

PREVENTION MECHANISMS RELATING TO CUSTOMERS, SUPPLIERS, AND EMPLOYEES.

5.1 CUSTOMERS

 

ACIERTALA.COM will establish internal mechanisms to ensure that employees identify customers, always through individual registration on the online platform. Concerning national customers, they will be identified through their national identity document (DNI); non-resident foreigners will be identified with their passport; and resident foreigners will be identified with their foreigner identification card.

 

If the customer is a legal entity, the natural person representing it will be identified. In this case, the appropriate identification document, in accordance with the previous paragraph, will be required, in addition to obtaining information about the name or corporate name of the legal entity, its tax identification number (RUC), and legal address, which will be verified with the respective supporting documents for each case.

 

Update customer data about their identity, addresses, phone numbers, email, administrator, manager, or representative, as applicable. Employees will inform the Compliance Officer of any unusual operations a customer may undertake or intend to undertake, considering the alert signs outlined in this Manual.

 

5.2 SUPPLIERS

 

ACIERTALA.COM will establish internal mechanisms to enable employees to identify suppliers. For national suppliers, identification will occur through their national identity document. Foreign non-resident suppliers will be identified with their passport, while resident foreigners will be identified with their foreigner identification card.

 

If the supplier is a legal entity, the natural person representing it will be identified. In this case, the appropriate identification document, in accordance with the previous paragraph, will be required, in addition to obtaining information about the name or corporate name of the legal entity, its tax identification number (RUC), and legal address, which will be verified with the respective supporting documents for each case.

 

Update supplier data about their identity, addresses, phone numbers, email, administrator, manager, or representative, as applicable. Employees will inform the Compliance Officer of any unusual operations a supplier may undertake or intend to undertake, considering the alert signs outlined in this Manual, including those identified by ACIERTALA.COM.

 

5.3 EMPLOYEES

 

ACIERTALA.COM will maintain a physical/digital personal file for each employee containing information provided under oath regarding their personal, employment, and financial history. For this purpose, the company will use formats defined by the company, and these files will be kept by the Human Resources department.

 

It is the duty of each employee to communicate any changes regarding this information to their immediate supervisor and/or Human Capital in writing within a maximum period of thirty (30) calendar days from the date of the change. The change will be reported to the Compliance Officer for the appropriate update of the employee's personal file, which will be kept by Human Capital.

 

ACIERTALA.COM will conduct training sessions (in-person/virtual) on topics related to the fight against money laundering and terrorist financing for its employees, especially those who have direct contact with customers and suppliers. This will enable ACIERTALA.COM and all its employees to have a greater understanding of money laundering and terrorist financing prevention.

 

6. REPORTS

 

These reports aim to ensure the functioning of risk control procedures included in this Manual, as well as compliance with best practices in the prevention of Money Laundering and Terrorism Financing and to cooperate with the authorities responsible for combating criminal activities.

 

6.1 INTERNAL REPORTS.

 

Internal report on unusual or suspicious transactions:

 

Whenever an employee of ACIERTALA.COM, in the course of their duties, detects an unusual and/or suspicious operation, they must report this fact to their immediate superior, who must immediately inform the Compliance Officer to initiate the respective analysis.

 

The document reporting an unusual transaction must include:

 

Date of the report.

Employee who makes the report.

Name and identification number of the related counterparty.

Clear description of the unusual and/or suspicious operation.

Additional observations.

6.2 DOCUMENT RETENTION RELATED TO THE INTEGRATED SYSTEM FOR THE PREVENTION AND CONTROL OF MONEY LAUNDERING AND TERRORISM FINANCING.

 

All records and documents generated in the implementation of the policies and procedures outlined in this Manual must comply with the criteria of integrity, reliability, availability, compliance, effectiveness, efficiency, and confidentiality of the information contained therein and must be kept in accordance with the regulations governing the company's document retention.

 

The Compliance Officer retains the documentation, both physical and digital, supporting the information related to the prevention of Money Laundering and Terrorism Financing, in a physical or digital folder designated for this purpose. This folder is available to various regulatory bodies when required.

 

6.3 HANDLING REQUESTS FOR INFORMATION

 

ACIERTALA.COM will provide the requested information for investigations or processes related to money laundering or terrorism financing as communicated and when applicable.

 

7. DETECTION OF UNUSUAL OR SUSPICIOUS OPERATIONS

 

The detection of unusual or suspicious operations for different stakeholders will be carried out as follows:

 

Each process owner is responsible for analyzing their process, and any non-compliance that may have a direct or indirect relationship with money laundering or terrorism financing must be reported immediately to the Compliance Officer, who will determine whether this unusual activity can be classified as suspicious or not.

 

8. INTEGRATION OF THE MONEY LAUNDERING/TERRORISM FINANCING PREVENTION SYSTEM WITH THE CODE OF ETHICS.

 

The system implemented to prevent and control the risk of Money Laundering and Terrorism Financing by ACIERTALA.COM is consistent with the corporate values outlined in ACIERTALA.COM's Code of Ethics.

 

9. COLLABORATORS OF THE MONEY LAUNDERING/TERRORISM FINANCING PREVENTION SYSTEM.

 

9.1 SENIOR MANAGEMENT

 

Senior management will have the following powers regarding Money Laundering/Terrorism Financing:

 

Establish policies for the prevention and control of money laundering and terrorism financing.

Approve the Money Laundering/Terrorism Financing prevention manual, as well as its updates.

Approve the mechanisms and tools they deem appropriate to use for Money Laundering/Terrorism Financing prevention in the Company.

Appoint the Compliance Officer.

Allocate the necessary resources to maintain the Money Laundering/Terrorism Financing prevention system described in this manual.

9.2 COMPLIANCE OFFICER

 

For ACIERTALA.COM, the Compliance Officer will be appointed by senior management and, as it is not obligatory, will carry out roles when any action and/or request related to Money Laundering and terrorism financing appears. They will also take the time needed to fulfill their roles when required and receive the support necessary to carry them out properly.

 

The Compliance Officer will have the following roles:

 

Ensure the effective and timely operation of controls to prevent Money Laundering and Terrorism Financing.

Present reports to senior management when required, addressing, at a minimum, the following aspects:

The effectiveness of the established mechanisms and tools and the measures taken to correct the deficiencies in the self-control system for Money Laundering and Terrorism Financing prevention.

Promote corrective measures for the Money Laundering/Terrorism Financing system.

Attend to and coordinate any request, inquiry, or diligence from competent judicial or administrative authorities on this matter.

Coordinate training plans on the Money Laundering/Terrorism Financing Prevention System for all Company employees.

The appointment of a Compliance Officer does not exempt the Company or other employees from the obligation to detect and report unusual operations internally and determine suspicious operations and report them promptly.

 

9.3 EMPLOYEES

 

All ACIERTALA.COM employees must follow internal policies related to money laundering and terrorism financing.

 

All employees must prioritize compliance with ethical and Money Laundering/Terrorism Financing risk prevention rules over achieving the Company's strategic objectives.

 

They must comply with the rules related to money laundering and terrorism financing to achieve the Company's objectives.

 

9.4 ADVISORY COMMITTEE FOR MONEY LAUNDERING/TERRORISM FINANCING

 

The Company has the ACIERTALA.COM Ethics Committee whose main objective is to contribute to the strengthening of ethical behavior within the Company, which will perform its functions for Money Laundering and Terrorism Financing prevention when the matters to be discussed exclusively relate to Money Laundering and Terrorism Financing. Directors and/or Managers of the areas involved in the process and other employees and/or third parties that are considered relevant will be invited. In the exercise of control and supervision of the Money Laundering/Terrorism Financing Prevention System, the Committee will use not only its own monitoring mechanisms but will also rely on the ACIERTALA.COM Compliance Officer and, where applicable, internal auditors. Responsibilities of the Ethics Committee regarding Money Laundering and Terrorism Financing

 

Meet whenever it is convened to analyze and review any information related to Money Laundering/Terrorism Financing when it is considered that the Company may be exposed to some type of risk.

Study, when necessary, the reports of unusual or suspicious operations that any area of ACIERTALA.COM and/or third parties may detect.

Properly document the analysis and conclusions resulting from each committee meeting on Money Laundering/Terrorism Financing topics. To this end, each meeting should be duly documented in a report signed by the attendees.

Copies of each report will be sent to the Company's General Manager.

Resolve any conflict of interest related to Money Laundering and Terrorism Financing that may arise within the Company.

10. WARNING SIGNS

 

Warning signs are a supporting tool for obligated entities, their employees, and the Compliance Officer to detect and prevent suspicious operations related to money laundering and terrorism financing. If any of the operations or situations described here are identified, it will be the responsibility of the Compliance Officer to analyze and evaluate them to determine whether they constitute suspicious operations and, in this case, report them to the Committee and/or Senior Management. Here are non-exhaustive warning signs related to shareholders, clients of ACIERTALA.COM, suppliers of ACIERTALA.COM, employees of ACIERTALA.COM, and other indicators:

 

11. SANCTIONS

 

Non-compliance with the guidelines outlined in this Manual or in the regulatory instruments related to the subject (Code of Ethics, money laundering, and terrorism financing) will be considered a labor violation, when applicable, and will be sanctioned in accordance with what is established in ACIERTALA.COM's Internal Labor Regulations. These measures will be applied considering the criteria of reasonability and proportionality of the penalty concerning the violation committed, without prejudice to the criminal or civil liability that the violation may entail. The documentation supporting the measures taken will be filed in the employee's personal file.

 

12. REVIEW OF THE PREVENTION SYSTEM

 

This manual will be reviewed annually by the Compliance Officer along with the General Manager and/or the Ethics Committee Representative, for its maintenance, adaptation to changes, or when required.