AML/KYC Policy

1. Purpose and Scope

Vestinit Ventures Australia Pty Ltd ACN 123 456 789 ("Vestinit") is committed to preventing its platform from being used for money laundering, terrorism financing, or any other financial crime. This policy describes our approach to customer due diligence, identity verification, and ongoing monitoring in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the "AML/CTF Act") and AUSTRAC guidelines.

This policy applies to all users of the Platform, including investors, issuers, and associated persons.

2. Customer Identification and Verification (KYC)

2.1 Individual Investors

Before accessing investment opportunities, individual investors must provide:

• Full legal name, date of birth, and residential address
• A primary government-issued photo identity document: Australian Driver's Licence, Australian Passport, or equivalent foreign government document
• A secondary identity document may be required at Vestinit's discretion

Identity is verified electronically through Frankie One Pty Ltd using the Australian Government's Document Verification Service (DVS), which checks driver's licences against state/territory registries (NEVDIS) and passports against the Department of Home Affairs register (DPS/DFAT).

2.2 Corporate Investors and Entities

For corporate entities, trusts, superannuation funds and other non-individual investors, we require:

• Entity name, ABN/ACN or foreign registration number, and registered address
• ASIC or equivalent company register extract
• KYC verification for all beneficial owners holding 25% or more of the entity, and all directors
• Trust deed (for trusts)
• Certified copies of board resolution authorising investment activity (for companies)

2.3 Issuers

Companies seeking to list on the Platform must complete corporate KYC, including verification of directors and ultimate beneficial owners, and provide ASIC company extract and certificate of incorporation.

3. Source of Funds

Vestinit may request information about the source of funds proposed to be invested. This is required to ensure funds are derived from legitimate sources. Users may be asked to provide:

• Employment income and payslips or employment contracts
• Business income and financial statements
• Investment proceeds and account statements
• Inheritance documentation
• Property sale proceeds

Vestinit will treat source of funds information with strict confidentiality and will only use it for compliance purposes.

4. Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who holds or has held a prominent public function, or who is a close family member or associate of such a person. This includes heads of state, senior government officials, senior executives of state-owned enterprises, senior political party officials, and senior military officers.

Vestinit screens all users against PEP databases at registration and on an ongoing basis. PEPs are subject to enhanced due diligence, which may include additional documentation, senior management approval and enhanced ongoing monitoring. Vestinit reserves the right to decline to onboard a PEP or to close an existing PEP account at its sole discretion.

5. Sanctions Screening

Vestinit screens all users and associated persons against applicable sanctions lists, including those maintained by:

• The Australian Department of Foreign Affairs and Trade (DFAT)
• The United Nations Security Council
• The United States Office of Foreign Assets Control (OFAC)
• The United Kingdom HM Treasury Financial Sanctions
• The European Union Consolidated List

Users who appear on any sanctions list will be denied access to the Platform. Existing accounts will be suspended and reported to AUSTRAC where required.

6. Ongoing Monitoring

KYC is not a one-time activity. Vestinit conducts periodic re-verification of user information, with enhanced monitoring applied to higher-risk users and transactions. Events that may trigger re-verification include:

• Material changes in investment activity or transaction amounts
• Changes in a user's circumstances (e.g. new corporate structure, change of country of residence)
• Adverse media or intelligence reports
• Regulatory direction
• Expiry of identity documents

7. Suspicious Matter Reporting

Where Vestinit forms a suspicion that a transaction or activity may be related to money laundering, terrorism financing or proceeds of crime, we are required to submit a Suspicious Matter Report (SMR) to AUSTRAC. We are legally prohibited from disclosing to you ("tipping off") that a report has been made.

Vestinit may suspend or terminate your account without prior notice while an SMR investigation is pending.

8. Record Keeping

All KYC and AML records, including identity documents, verification results, transaction records and SMRs, are retained for at least 7 years from the date of the relevant activity, in accordance with the AML/CTF Act.

9. Contact