SWISS REMIT MONEY LAUNDERING & TERRORIST FINANCING PREVENTION STATEMENT

SwissRemit works diligently to prevent its systems from being used to perpetrate any unlawful activity. We are committed to protecting our customers and preventing the use of our services for money laundering, fraudulent purposes, scams, terrorist financing, and other illegal acts.

Swiss Remit must protect the integrity and reputation of its shareholders, regulators, customers, business partner, and Switzerland as a country.

As a SwissRemit agent or business partner, it is crucial that you understand the impact of illegal transactions on you, customers, and our Company as a whole.

At SwissRemit, we take compliance seriously and are committed to following specific guidelines so that our customers can send their money worry-free. For that reason, when becoming a customer, we will ask you for certain information and documentation like:

• Your complete name and surnames;
• Your address;
• Your telephone number;
• Your email address;
• Your occupation;
• A valid form of identification;
• On occasions, we may ask you to provide proof of employment or the origin of the funds;
• We may ask you the reason for a particular money remittance;
• We may ask you the relationship of the specific beneficiary;

We will do all it takes to protect you and our Company from being exposed to criminal activity. Always keep in mind that our Data Protection Policy protects your data.

This Code of Ethics and Business Conduct of SwissRemit serves as our ethical commitment and guide to proper business conduct for all stakeholders. We at SwissRemit are committed to doing business legally, ethically, and transparently.

This policy applies to all staff who work for the Company (including officers, directors, managers, team leaders, employees, temporary, agency, interim, subcontractor, or consultant staff) and includes other organizations who do business with us.

SwissRemit expects its staff to be impartial and honest in all affairs relating to their job. In general, all teams are responsible for good faith and doing nothing to destroy the trust necessary for employment.

The success of our business is based on the trust we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitment to fairness and reaching our goals solely through ethical conduct. All staff is expected to comply with this Code in their professional and personal conduct and treat everyone with respect, honesty, and fairness.

When you work with SwissRemit, you quickly discover that everything we do and every decision we make aligns with our core values and beliefs. We are here to perform with a unique mixture of intensity and accuracy. The principles that guide our behavior to deliver our brand:

• Client-Focus At SwissRemit, the client comes first. Our primary focus is to provide personalized and creative solutions for individual needs.
• Trust and integrity Since we expect our client relationships to be long-term, it is paramount that they are based on trust and integrity. In turn, these ideas influence all the decisions of the Company and our employees.
• Excellence We strive for excellence in all aspects of our business. Our clients have come to expect and appreciate our services' quality, attentiveness, and professionalism.
• Accountability Open and honest communication is a hallmark of our Company. We work to keep our clients updated and informed.
• Community Leader We invest our time and resources to support the communities in which we live and work, improving the quality of life for everyone.
• Employee Value We value our colleagues as we do our clients. We are committed to providing our employees with professional and personal development opportunities.
• In Addition, these other terms reflect the spirit of our Company: Teamwork, Commitment, Honesty, Respect, Service, Professionalism, Loyalty, and Innovation.

Our commitment to integrity begins with complying with laws, rules, company policies, and internal regulations. We understand and comply with a lawful business's legal requirements and commercial practices. The payment service industry is highly regulated. Being aware of and complying with the ML-TF Prevention laws and regulations under which we operate is not just a critical part of our business but fundamental to who we are. It is vital to comply with laws, regulations, and company policies' letter, spirit, and intent. Violating the law or engaging in unfair, deceptive, and abusive acts or practices may weaken customer confidence, put our reputation at risk, impact our integrity, or result in regulatory legal action, fines or penalties, or other negative repercussions. We are expected to know and comply with the laws, regulations, and Company policies that apply to us.

Our staff must follow applicable laws and regulations, including the Code, at all times and must ensure compliant operation.

Our relationships with business partners are built upon trust and mutual benefits compliant with competition law. We are dedicated to ethical and fair competition, as we provide payment services based on their quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities, nor will we engage or assist in unlawful boycotts of particular customers. We commit to comply with all applicable trade controls, restrictions, sanctions, and import-export embargos.

We do not allow any violence of the fairness of any tendering process in any way. We refrain from damaging competition and the reputation of any business partners and any behavior that harms competitors' creditability.

We do not hold back maliciously, unlawfully, or unduly payments towards our partners, and we do not allow such practices in our supply chain. We fight the unethical practice of the "debt chain".

Our staff is responsible for ensuring fair business during their job and adhering to every competition, consumer protection, and honest marketing rule. Customers and business partners shall be treated fairly and equally, products and services shall be offered relatively and accurately (fair marketing and advertising), and all relevant information disclosed.

We firmly condemn and do not tolerate all forms of corruption. It is prohibited directly or indirectly from the offering, promising, giving, asking, soliciting, or accepting any unfair advantage or benefit from obtaining, retaining, or facilitating in any way the business. An unfair advantage or benefit may include cash, any cash equivalent (e.g., voucher), gift, credit, discount, travel, personal advantage, accommodation, or services. To secure or speed up routine actions, we do not permit facilitation (or "grease") payments to government officials or private businesses. Corruption also covers the misuse of function or position when someone makes that false appearance improperly influences a decision-maker.

Corruption for either obtaining or retaining business or obtaining or retaining an advantage in business conduct is considered gross misconduct. Similarly, accepting or allowing another person to take a bribe is gross misconduct. Our staff must account for all benefits received in doing business and must not give or receive bribes or otherwise act corruptly.

We are committed to confidentiality, integrity, and accessibility; we implement proper technical security measures, and our staff should uphold this. Proprietary information includes all non-public information that might be harmful to the Company, its customers, and business partners if disclosed to unauthorized parties. All staff must handle any such information as secret.

It also covers that no one is entitled to trade with securities while possessing nonpublic information or delivering non-public information to others that could impact the securities. Every rule ensuring information security must be followed at all times.

We respect the property rights of others. We will not acquire or seek to obtain trade secrets or other proprietary or confidential information by improper means. We will not engage in unauthorized use, copying, distribution, or alteration of software or other protected intellectual property.

Fraud – the act or intent to cheat, steal, deceive, or lie – is unethical and criminal in most cases. Fraud in every form (e.g., submitting false expense reports, forging or altering financial documents or certifications, misappropriating assets or misusing company property, making any untrue financial or non-financial entry on records or statements) is prohibited and unlawful.

We respect people's privacy and acknowledge that customers, employees, and other natural persons need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to complying with all personal data protection laws such a the Swiss DPA and EU GDPR. We only acquire and keep the necessary personal information, and we give accurate information on these activities to data owners. We implement proper security measures to assure confidentiality, integrity, and availability of personal information.

Our staff must observe the legal requirements, apply compliant practices and follow related procedures to ensure the legality of personal data handling and processing activities.