AML Statement

Token Development s.r.o. is committed to implementing single global standards shaped by the most effective anti-money laundering standards available, and to complying with the sanctions laws and regulations of the European Union, the Czech Republic, the United Kingdom, the United Nations, as well as other applicable sanctions laws and regulations in the jurisdictions in which Token Development s.r.o. operates, subject to the primacy of local laws and regulations.

Token Development s.r.o. has established a Anti-Money Laundering Policy for this purpose. The objective of the AML Policy is to ensure that money laundering risks identified by Token Development s.r.o. are appropriately mitigated. This is achieved by establishing minimum governing policies, principles, and standards and implementing appropriate controls, to protect Token Development s.r.o., its employees; shareholders and customers from money laundering. The AML Policy provides guidance to all Token Development s.r.o. employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.

The AML Policy is based upon various laws, regulations and regulatory guidance from Czech Republic, the United Kingdom, the European Union, FATF and best practice in AML.

The AML Policy sets out the minimum standards applicable to its organisation, to include:

• Appointing a Money Laundering Reporting Officer (“MLRO”) of sufficient seniority who will have responsibility for oversight of compliance with all relevant Czech legislation, regulations, and industry guidance.

• Implementing and maintaining adequate systems and controls on a risk-sensitive basis to prevent money laundering and terrorist financing.

• Conducting business in conformity with high ethical standards with reputable Clients involved in lawful activities.

• Establishing and implementing risk-based Client due diligence, identification, verification and "Know Your Client" procedures, including enhanced due diligence for those Clients presenting a higher risk. Token Development s.r.o. is committed to ensuring that all Clients’ identities will be verified before they are accepted as Clients of Token Development s.r.o..

• Establishing and maintaining risk-based systems and procedures to monitor Client accounts and activity.

• Undertake and document a risk-based assessment considering other risks with Client and delivery channels and having regard to the size of the firm.

• Providing initial and ongoing training to ensure that all relevant staff are aware of the Policy and can fulfill their legal obligations and recognise the risk of Token Development s.r.o. products and services being used to assist money laundering or terrorist financing. Token Development s.r.o. will regularly update all relevant employees on any changes to the law and their anti-money laundering and counter terrorist financing obligations.

• Complying with all record keeping requirements and maintaining all relevant records for at least five [5] years.

• Ensuring that Token Development s.r.o. staff record and promptly report all suspicious activity to the MLRO and that the MLRO reports to the Financial Analytical Office (FAU) where appropriate.

• Ensuring that senior management are provided with regular reports regarding compliance with the Policy.

• Regularly monitoring and reviewing all procedures contained in the Policy to ensure that the Token Development s.r.o. Policy is strictly adhered to and developed and updated from time to time in accordance with relevant legislation, advice from enforcement agencies and best industry practice.