Kero Anti-Money Laundering Policy

1. Purpose

This Anti-Money Laundering (AML) Policy outlines Kero's commitment to prevent and detect money laundering and terrorist financing. The purpose is to ensure compliance with applicable laws and safeguard financial system integrity.

2. Scope

This Policy applies to all employees, contractors, agents, and representatives acting on behalf of Kero. It encompasses all business activities, domestically and internationally.

3. Legal Compliance

The Company commits to complying with relevant anti-money laundering laws and regulations in jurisdictions where it and its clients operate, including:

United Kingdom: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Terrorism Act 2000, and the Proceeds of Crime Act 2002 (POCA) (as amended by the Serious Organised Crime and Police Act 2005 (SOCPA)).

South Africa: the Financial Intelligence Centre Act 38 of 2001 and the Prevention of Organized Crime Act 121 of 1998.

United States: the Bank Secrecy Act (BSA), the USA PATRIOT Act, and other applicable international laws.

4. Risk Assessment

The Company will conduct periodic risk assessments to identify and evaluate money laundering and terrorist financing risks associated with its products, services, customers, and geographic locations. Appropriate mitigation measures will be implemented.

5. Customer Due Diligence

The Company will establish and maintain risk-based procedures for customer due diligence, including identity verification, understanding business nature, and monitoring for unusual or suspicious transactions.

6. Reporting Suspicious Activities

Covered Parties must promptly report suspicions of money laundering or terrorist financing to the designated compliance officer or through established reporting channels. The Company encourages reporting without retaliation fear.

7. Record Keeping

The Company will securely maintain accurate, up-to-date records of customer information, transactions, and customer due diligence results in accordance with applicable laws and regulations.

8. Training and Awareness

The Company commits to providing regular training to Covered Parties on anti-money laundering policies, procedures, and vigilance importance in detecting and preventing money laundering and terrorist financing activities.

9. Monitoring and Reporting

The Company will implement monitoring mechanisms to detect and report suspicious activities. Reports will be filed with relevant authorities as required by law. The Company will fully cooperate with law enforcement and regulatory agencies.

10. Third-Party Relationships

The Company will conduct due diligence on third parties, including vendors, partners, and agents, to ensure they adhere to anti-money laundering standards. Business relationships with parties involved in money laundering are strictly prohibited.

11. Consequences of Violations

Policy violations result in disciplinary action, potentially including employment termination, legal action, and civil or criminal penalties. Consequence severity depends on violation nature and extent.

12. Review and Update

This Policy will be periodically reviewed to ensure effectiveness and relevance. Amendments may be made to reflect applicable law changes or business practice modifications.

13. Responsibilities for the Process

The Director: Operations or duly appointed representative holds responsibility for policy preparation, verification, issuance, filing, and updating. The Compliance Officer or duly appointed representative oversees monitoring, measurement, and continual improvement.