Know Your Customer (KYC) & Anti-money Laundering Policy (AML)

1. POLICY STATEMENT

Zeoangle Private limited and its employees, third parties, its customers and clients are all time
committed to the highest standards of anti-money laundering (AML) and counter terror
financing (CTF), including anti-fraud, anti-corruption and taking measures to mitigate against
financial crime defined under the law of the land

The terms “We”, “Our”, “Company”, “Cryptope” and “Us” refer to the Zeroangle Private
Limited., and the terms “User”, “You” and “Your” refer to a User of our Mobile Application
known as “CryptoPe”)

2. BACKGROUND,PURPOSE & STATEMENT

Zeroangle Private Limited is a Company registered as per the Laws of Government of India
under the company act 2013. This Policy describes the Company’s procedures instituted to
ensure that the services offered by the Company (using a Mobile app called Cryptope) are not
being used by the users to facilitate commission of any criminal offenses, including but not
limited to those under the Corruption, Drug Trafficking and Other Serious Crimes.

The Company has prepared this AML Policy to ensure the transparency of using the App and to
ensure the prevention of illegal activities including without limitation the Prevention of Money
Laundering Act 2002 (“PMLA”), the Prevention of Money Laundering (Maintenance of Records)
Rules 2005 (“PML Rules”), and various applicable guidelines, rules and regulations of the
Computer Emergency Response Team, India, and the Reserve Bank of India(RBI). Under the
provisions of the PML Act 2002, the Financial Intelligence Unit of India (FIU-IND) was
established in 2004 as the apex body for coordinating India’s AML efforts.

In order to mitigate its risks relating to money laundering and other illegal activities, we intend
to put in place this policy the KYC and Due Diligence Procedure including Risk Management
Procedure; Customer Verification Procedure; Transaction Monitoring Terms and other relevant
processes as defined below.

3. KEY TERMS

Exolnation of the Money Laundering and Terrorist Financing Terms

1. Money laundering is the illegal process of making large amounts of money generated by
a criminal activity, such as drug trafficking or terrorist funding, appear to have come
from a legitimate source.

2. Terrorism financing is the provision of funds or providing financial support to individual
terrorists or non-state actors. The objective of such financing is to support terrorist acts
or support terrorist organisations that commit terrorist acts.

4. PROCEDURE FOR KYC AND CUSTOMER DUE DILIGENCE (CDD)

Zeroangle adheres to and complies with the principles of the Know Your Customer (KYC) policy
which aims to prevent financial crime and money laundering through client identification and
due diligence.

If the Company finds any user information obtained in accordance with the procedure described
under this clause to be inadequate, insufficient, or sanction screened, the Company may in its
discretion either refuse or terminate (as the case may be) the registration of such user account
or require verification of such user’s identification documents again.

All customers/clients, who are new to the organization will undergo procedural due diligence
checks prior to opening an account, as laid out below:

4.1. PRIMARY VERIFICATION IDENTIFICATION

Proof of who every new individual or business is will be gained and recorded on a New
Customer Application.

The very first step when transacting on the Platform would be to produce documentation that
would verify Identification, Address and Selfie/ Liveness checks.

Identification & Address Proof: Documents for Identification and home/office address are
required with the person/business name on. Acceptable forms of ID can include:

Individual – For India, PAN Card and/or AADHAAR Card details/Passport Details/Driving License
for individual identity verification and document verification digitally KYC compliance as per the
policy. The Company reserves all the rights to get the verification of your PAN and/or Aadhar
done from the government authorities.

Business – Details of any beneficial owners / controlling directors, Director/Proprietor ID (as per
requirements for individuals), Certificate of Incorporation, Company Registration Number &
Registered Office, Utility Bill, Bank Statement, Tax registration documents will be collected and
stored as per the company policy.

Selfie-check/ Liveness Check: As part of the selfie-taking/ liveness check process the user is
asked to position their face within an oval on the screen, about 10 inches away, and then move
a bit closer. The company takes its KYC procedures seriously however, the process of selfie/
liveness check is subject to the technical issues faced by the company.

4.2 SECONDARY VERIFICATION

The company conducts a secondary verification in the following scenarios:

1. For transactions over 100K USD either by the Individual or 1M USD by business account
2. For users having a large number of outward transactions/withdrawals on our website, as
   the company deems alarming,
3. For any suspicious activity as per the company’s policies, rules and regulations and laws
   of the land,
4. For any User or transaction of the user having a high negative score from any of our third
   party compliance tools, etc during the periodic check

Herein, a Source of the Funds and verification of above point, KYC ought to be mentioned and
only upon the reverification of the same will the Platform allow for further transactions to take
place.

4.3 DUE DILIGENCE CHECKS

As we understand the importance of due diligence check and ongoing due monitoring; we will
conduct background checks prior to account acceptance, details of which will be kept on file as
evidence of due diligence and anti-money laundering checks with the help of the proven
solution available in the market by the way of integration with the platform or the App solution
company is providing

Due diligence checks will be conducted as per the regulations and requirements. All documents,
accounts and transactions associated with clients/customers will be retained for 3 years from
the later of a) the date of the transaction or b) the end of the customer’s relationship with
Zeroangle Private Limited

4.4. MONITORING & AUDITING DUE DILIGENCE

The Company will part internal responsibility by the way of appointing a person who is
responsible for ensuring that due diligence checks, and anti-money laundering measures are
being completed and are fit for purpose. Regular audits are completed on due diligence forms,
company checks and ongoing monitoring.

Team will conduct ongoing due diligence checks for client/customer accounts. This will ensure
us to keep up-to-date information and data and will also keep a check that no adverse
information has arisen since the last due diligence was performed.

4.5.SANCTION SCREENING

As part of our on-boarding process as well as ongoing due diligence process; all the individual
and corporate customers, connected parties of the customer, ultimate beneficial owners of the
customer will undergo the screening process. No business or transactions will be conducted
with the sanctioned individuals or entities.

4.6.ENHANCED DUE DILIGENCE (EDD)

Where a customer is assessed as higher risk either internally by the Company, then Enhanced
Customer Due Diligence (EDD) measures are applied by the company. That includes senior
management review and sign-off of new business relationships. The Company follows a process
which allows for identification of potential red flags as well as checks on behavior, pattern and
volume of the transactions.

Enhanced monitoring to be conducted on a risk-based approach of any business relationship or
transactions involving a high-risk third country or where any potential concerns are identified
during standard due diligence.

4.7 MAINTAINING RECORDS

We will ensure that records of all Customer Due Diligence (CDD) documentation and customer
transactions are held for 3 years beginning on the later of either a) date the transaction is
complete or b) the date the business relationship comes to an end. These records include but
are not limited to CDD documentation, Business wide risk assessments, customer risk
assessments.

5. RISK MANAGEMENT PROCEDURE

1. The Company may categorize its Users including you into low, medium or high-risk
   categories, after undertaking an appropriate risk assessment of each User based on the
   following factors (including without limitation)
2. Sufficiency and adequacy of identification information submitted as mentioned under
   this policy.
3. Nature of User’s business/vocational activities; or
4. Guidance notes circulated by various governmental and intergovernmental
   organizations.

You acknowledge that in order to maintain the integrity of the Risk Management
Procedure, the Company will keep your risk categorization and any data related thereto
confidential. You will not be entitled to seek disclosure of your risk categorization.
However, the Company may disclose the User’s risk categorization data to the
competent enforcement authority if it finds that a particular User has executed or is
likely to execute any Suspicious Transaction.


6. DATA SOURCING (FOR VERIFICATION)

For the purposes of verification of any user’s identity and monitoring of transactions, the
Company relies on appropriate and licensed third-party service providers to authenticate the
identification and other incidental details provided by you. As part of the on-boarding process;
due diligence will be conducted for such service providers. User data collected will be sent to
such service providers to verify the information and validate the identity or any such matter
required on the platform to give users a verified status on the app.


7. GET IN TOUCH

You may report your concerns directly to us, at any point, whether or not you have used our
internal procedures and whether or not an internal investigation is in fact ongoing at
help@zeroangle.company


8. PERIODIC REVIEW OF THE POLICY

This policy will be subject to periodic review in the light of various factors including regulatory
changes, changes in business, market intelligence, and industry standard as and when required
to update.