TABLE OF CONTENTS

• 1. POLICY STATEMENT
• 2. LEGAL COMPLIANCE
• 3. DEFINITIONS
• 4. KEY RESPONSIBILITIES
• 5. FRAUD DETECTION AND INVESTIGATION
• 6. MISCELLANEOUS

1. POLICY STATEMENT

1.1. BIT2ME creates opportunities for individuals and builds trust among them worldwide. BIT2ME is committed to conducting business in accordance with the highest ethical, professional, and legal standards. The public, partners, and users of BIT2ME have the right to expect that BIT2ME hires professional, competent, and trustworthy individuals.

1.2. BIT2ME will comply with applicable legislation. In accordance with applicable law, BIT2ME has a "zero tolerance" policy towards fraud, corruption, collusion, money laundering, terrorist financing, and other criminal conduct (collectively "Prohibited Conduct") and will thoroughly investigate and seek to take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent or other inappropriate actions in all BIT2ME activities and related transactions.

1.3. BIT2ME will provide adequate and appropriate resources to implement the Anti-Fraud Policy and will ensure that it is communicated and understood.

2. LEGAL COMPLIANCE

2.1. The Anti-Fraud Policy has been drafted to comply with current local and international legislation, including, but not limited to, applicable EU legislation.

2.2. Adherence to the Anti-Fraud Policy. BIT2ME will ensure compliance with all relevant laws and internal policies.

3. DEFINITIONS

In compliance with the Anti-Fraud Policy, prohibited conduct includes fraud, corruption, collusion, money laundering, terrorist financing, and other criminal conduct defined as follows:

3.1. Fraud: any act or omission, including a misrepresentation that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.

3.2. Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to improperly influence the action of another party.

3.3. Collusion: an arrangement between two or more parties designed to achieve an improper purpose, including to improperly influence the actions of another party.

3.4. Money Laundering:

1. The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of their action.
2. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity.
3. The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity.
4. Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions mentioned in the previous points.

3.5. Terrorist financing: the provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in whole or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.

3.6. Criminal conduct: conduct which constitutes a criminal offence in any part of the world or would constitute a criminal offence in any part of the world if it occurred there.

4. KEY RESPONSIBILITIES

4.1. BIT2ME conducts a "Know Your Customer" (KYC) due diligence on all new users and due diligence on all transactions to detect potential compliance or integrity issues. Such due diligence is performed in accordance with the requirements of money laundering and terrorist financing activity regulations, pursuant to the terms of KYC.

4.2. In view of the anti-fraud policy, BIT2ME is responsible for:

• Ensuring that there are efficient and effective internal systems, procedures, and controls to enable the prevention and detection of Prohibited Conduct.
• Ensuring that the Anti-Fraud Commissioner identifies the risks of prohibited conduct in their business areas and that all internal systems, procedures, and controls are implemented and applied appropriately.
• Ensuring that all members of the anti-fraud operational department have an obligation to report any suspicion or internal and external incident of prohibited conduct.
• Continuous review of its internal systems, procedures, and controls through risk management processes and audit arrangements.
• Reporting any suspicion of prohibited conduct to the relevant state authorities.

5. FRAUD DETECTION AND INVESTIGATION

5.1. The BIT2ME Operational Anti-Fraud Department, in particular the Anti-Fraud Commissioner, is the first line of detection, investigation, and protection to prevent Prohibited Conduct through the User and Transaction Evaluation Process. The Anti-Fraud Commissioner will be responsible for the proper enforcement of the Anti-Fraud Policy.

1. Authority

   The Anti-Fraud Commissioner, through the Operational Anti-Fraud Department, working in close collaboration with the Nominated Officer (cf. Know Your Customer Policy), will be responsible for:

   • Receiving reports of alleged prohibited conduct related to BIT2ME, its users, and/or related transactions.
   • Investigating such matters and cooperating directly with the Nominated Officer to facilitate investigations.
   • Reporting their findings to the management of BIT2ME and to the relevant authorities, as well as to any other third party, as necessary.

2. For situations that require an urgent response, the Anti-Fraud Commissioner may take the necessary measures for the investigation, especially to preserve evidence.

3. Independence

   The Operational Anti-Fraud Department will enjoy complete independence in the exercise of its responsibilities. The Anti-Fraud Commissioner will have full authority to open, pursue, close, and report on any investigation into Prohibited Conduct within their competence without prior notice, consent, or interference from any other person or entity.

4. Professional Standards

   All investigations of prohibited conduct conducted by the Operational Anti-Fraud Department will be fair and impartial, with due respect for the rights of the Users and the individuals or entities involved. The presumption of innocence applies to those who have allegedly committed misconduct. Those involved in the investigation of Prohibited Conduct (whether those being investigated or those conducting the investigation) must be aware of their rights and obligations and ensure they are fully respected.

5. Cooperation

   All users must cooperate with the Operational Anti-Fraud Department and the Anti-Fraud Commissioner promptly, completely, efficiently, and in the manner specified by the Operational Anti-Fraud Department, including answering relevant questions and complying with requests for information and records.

6. Confidentiality

   In accordance with BIT2ME's internal rules on access to information, all information and documents collected and generated during an investigation of Prohibited Conduct, which are not yet in the public domain, will be kept strictly confidential. The confidentiality of the information collected will be respected both in the interest of the parties involved and in the integrity of the investigation.

   In particular, during the investigation of prohibited conduct, confidentiality will be respected to the extent that it is not contrary to the interests of the investigation.

   The Operational Anti-Fraud Department will disclose such information and documents only to those persons or entities authorized to receive them or otherwise as necessary.

6. MISCELLANEOUS

6.1. BIT2ME will review the Anti-Fraud Policy to reflect new legal and regulatory developments and to ensure good practice.

6.2. I GUARANTEE THAT I HAVE NO INTENTION OF COMMITTING ANY ACT OF PROHIBITED CONDUCT DESCRIBED HEREIN; FURTHERMORE, I CONSENT TO ANY CHECKS DUE TO THE INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND AGREE TO COOPERATE FULLY AND IMMEDIATELY WITH THE ANTI-FRAUD COMMISSIONER WITHIN SAID INVESTIGATION.