Anti-Money Laundering and Financial Crime (AML & FC) Policy

Dated August 14, 2026

DISCLAIMER: THIS POLICY DESCRIBES PAYADMIT’S APPROACH TO PREVENTING AND MITIGATING MONEY LAUNDERING, TERRORIST FINANCING, SANCTIONS, FRAUD AND OTHER FINANCIAL CRIME RISKS ARISING FROM ITS BUSINESS ACTIVITIES. IT IS DESIGNED TO REFLECT PAYADMIT’S ROLE AS A TECHNICAL AND INFRASTRUCTURE SERVICE PROVIDER AND DOES NOT CONSTITUTE A REPRESENTATION THAT PAYADMIT ITSELF PROVIDES REGULATED PAYMENT SERVICES OR IS SUBJECT TO AML/CFT REGULATORY OBLIGATIONS APPLICABLE EXCLUSIVELY TO REGULATED PAYMENT INSTITUTIONS. THE REGULATORY RESPONSIBILITIES APPLICABLE TO PAYMENT SERVICES PROVIDED BY PAYADMIT’S CLIENTS OR OTHER REGULATED COUNTERPARTIES REMAIN WITH THE RELEVANT ENTITY RESPONSIBLE FOR THOSE SERVICES UNDER APPLICABLE LAW. FOR THE AVOIDANCE OF ANY DOUBTS, AML/CFT REGULATORY RESPONSIBILITIES APPLICABLE TO THE PAYMENT SERVICES PROVIDED BY PAYADMIT’S CLIENTS OR OTHER REGULATED COUNTERPARTIES REMAIN WITH THE RELEVANT ENTITY RESPONSIBLE FOR THOSE SERVICES UNDER APPLICABLE LAW.

1. PURPOSE AND OBJECTIVES

PayAdmit is committed to maintaining appropriate and proportionate measures to prevent and mitigate the risk that its technology and services may be misused for money laundering, terrorist financing, fraud, sanctions evasion or other financial crime.

PayAdmit takes a risk-based approach to anti-money laundering and financial crime prevention and maintains controls appropriate to the nature, scale and complexity of its business and the risks arising from its activities.

This Policy is aimed to provide transparency regarding PayAdmit’s controls and does not constitute a representation that PayAdmit is itself a bank, payment institution, electronic money institution or other regulated financial services provider.

This Policy does not constitute legal advice, nor is it aimed to describe every internal control or procedure maintained by PayAdmit.

PayAdmit reserves the right to update this Policy from time to time to reflect changes in its business, applicable legal requirements and its anti-money laundering and financial crime risk framework.

2. NATURE OF PAYADMIT’S SERVICES

PayAdmit provides technology and payment infrastructure services, including white-label gateway, payment-bridge and cashier-related technology, to business clients acting as the payment software provider.

PayAdmit does not receive, hold, safeguard or otherwise take possession or control of funds belonging to PayAdmit’s clients or its end customers. Payment funds are handled directly by the relevant clients and/or the applicable regulated payment service providers.

PayAdmit does not independently determine the movement of customer funds and does not itself perform transaction monitoring of the underlying payment activity conducted by its clients or their payment service providers.

Where a payment service is provided by a regulated payment service provider, responsibility for the regulated payment service and the regulatory obligations applicable to that service remain with the relevant regulated entity and PayAdmit does not assume responsibility for or control over the fulfilment of those obligations.

PayAdmit’s role is limited to the provision of the software and technology related services agreed with its business clients.

3. CLIENT ONBOARDING AND DUE DILIGENCE

As part of its client onboarding and ongoing relationship management, PayAdmit conducts its internal risk-based due diligence on its business clients and relevant counterparties for the purposes of identity verification, risk assessment and compliance screening.

While assessing the nature and risk profile of the potential client, PayAdmit may request and assess information including:

– corporate registration and constitutional information;

– information concerning directors, officers and beneficial owners;

– identification and verification documents;

– information regarding the nature and purpose of the proposed business relationship;

– information concerning the client’s business activities, ownership and control structure;

– information regarding relevant licences, registrations or regulatory status;

– sanctions and other financial crime screening information;

– such additional information as PayAdmit reasonably considers necessary to assess the relationship and associated risks.

PayAdmit may carry out enhanced due diligence where a business relationship presents increased financial crime, sanctions, fraud or other compliance risks.

At the sole discretion of PayAdmit, we reserve the right to decline to establish, restrict, suspend or terminate a business relationship where appropriate due diligence cannot be completed, information provided is inadequate or inconsistent, or material financial crime or compliance concerns are identified by PayAdmit.

4. RISK-BASED APPROACH

PayAdmit applies a risk-based approach to its financial crime controls. The scope and nature of due diligence may vary depending on factors and circumstances including the client’s business model, jurisdiction, ownership and control structure, regulatory status, products and services, geographic exposure and other relevant risk factors.

Where appropriate, during the whole period of relationship with the clients PayAdmit may conduct ongoing reviews of its business relationships and may request updated information where there is a material change in the relationship or where additional information is reasonably required for compliance or risk-management purposes.

5. SANCTIONS AND FINANCIAL CRIME SCREENING

PayAdmit may conduct appropriate sanctions, politically exposed persons, adverse media and other financial crime screening in connection with its business relationships.

Where screening or other due diligence identifies a potential concern, PayAdmit may conduct further investigation and take appropriate risk-based measures, including requesting additional information, restricting services or declining or terminating the relevant relationship with such businesses.

PayAdmit maintains appropriate measures to support compliance with applicable sanctions regimes and other legal and regulatory requirements relevant to its activities and business operations.

6. SUSPICIOUS ACTIVITY AND ESCALATION

PayAdmit has established and implemented adequate internal procedures for identifying and escalating suspected financial crime, sanctions concerns, fraud and other material compliance issues.

Where PayAdmit identifies inappropriate conduct or circumstances giving rise to a legal reporting obligation, PayAdmit will take such reasonable action as is required under applicable law.

In case PayAdmit provides services to a regulated payment service provider or other regulated entity, PayAdmit may also cooperate with that entity in connection with appropriate financial crime controls, investigations and information requests, subject to applicable law and contractual arrangements.

7. RESPONSIBILITY FOR THE CLIENT’S END CUSTOMER’S ACTIVITIES

PayAdmit does not carry out due diligence or transaction monitoring of the end customers of its business clients in its own capacity, unless expressly agreed under a separate written arrangement and permitted by applicable law.

Responsibility for the onboarding, identification and verification of end customers, transaction monitoring, suspicious activity reporting and other regulatory obligations relating to the underlying payment services remains with the entity responsible for those activities under the applicable legal and contractual framework.

Nothing in this Policy is intended to transfer or diminish any regulatory responsibility that remains with a regulated payment service provider or other regulated entity.

8. GOVERNANCE AND REVIEW

PayAdmit maintains internal policies, procedures and controls designed to support its anti-money laundering and financial crime prevention framework.

PayAdmit’s relevant personnel are expected to understand and comply with PayAdmit’s internal compliance requirements and to escalate material financial crime or sanctions concerns through the designated internal channels.

In light of the nature and scope of its business activities, and its role as a payment software provider, PayAdmit is not subject to a specific regulatory requirement to appoint a Money Laundering Reporting Officer (“MLRO”). Notwithstanding the above, PayAdmit may, where considered appropriate, appoint an MLRO or other suitably qualified individual to oversee and coordinate AML/CFT and financial crime matters within the company. Any such appointment shall be determined having regard to PayAdmit’s business activities, risk profile and applicable legal requirements and shall not, in itself, imply that PayAdmit is a regulated payment institution or otherwise subject to regulatory obligations applicable specifically to regulated entities.

PayAdmit reserves the right to periodically review its anti-money laundering and financial crime controls and may update them in response to changes in its business, applicable legislation, regulatory expectations, emerging risks or other relevant circumstances.