Anti-Money Laundering & Counter-Terrorist Financing Policy

QOR LTD is a Nigerian technology company that develops and operates digital platforms, including Cashmama.

QOR LTD is committed to preventing its platforms and services from being misused for money laundering, terrorist financing, fraud, sanctions evasion, or other financial crime.

This Anti-Money Laundering and Counter-Terrorist Financing Policy ("AML Policy") describes the principles and controls that guide QOR LTD's approach to identifying, assessing, preventing, and mitigating financial crime risks associated with its platforms and services.

Cashmama is a digital platform developed and operated by QOR LTD. Where services require specialised or regulated capabilities, Cashmama integrates with appropriate third-party providers operating under their applicable requirements.

This policy applies to QOR LTD's relevant operations, the Cashmama platform, users, employees, contractors, and applicable third-party relationships, to the extent relevant to their respective roles and responsibilities.

QOR LTD maintains its AML and financial crime controls with regard to applicable laws, regulations, regulatory guidance, and recognised international standards relevant to its activities.

Our framework may take into account:

• Applicable Nigerian anti-money laundering and counter-terrorist financing legislation;

• Applicable requirements and guidance issued by competent Nigerian authorities;

• Applicable sanctions and counter-terrorist financing requirements;

• Relevant Financial Action Task Force (FATF) recommendations; and

• Applicable requirements in jurisdictions relevant to our services and third-party relationships.

Where a service is provided through a licensed or regulated third-party provider, the provider's applicable regulatory obligations, policies, controls, and reporting responsibilities may also apply to that service.

This policy is reviewed periodically and may be updated to reflect changes in our services, risk environment, applicable requirements, and regulatory developments.

QOR LTD applies a risk-based approach to financial crime prevention.

We consider relevant factors including:

• The nature and characteristics of a service;

• Customer and account information;

• Transaction activity and patterns;

• Geographic and jurisdictional risks;

• Product and service risks;

• Sanctions and other financial crime risks;

• Information obtained through identity verification and due diligence; and

• Information received from appropriate third-party providers or other lawful sources.

The level of verification, monitoring, or additional review applied may vary according to the level and nature of identified risk.

Depending on the service and applicable requirements, users may be required to complete identity verification and other customer due diligence procedures before accessing certain features or transaction capabilities.

These measures may include:

Users may be subject to transaction or feature restrictions where required verification has not been completed.

QOR LTD maintains controls designed to identify unusual or potentially suspicious activity associated with the services it operates or facilitates.

Depending on the service, these controls may include automated monitoring, manual review, risk rules, alerts, transaction limits, and information received from third-party providers.

Examples of activity that may require additional review include:

• Unusual transaction volumes or frequency;

• Activity inconsistent with known account information or expected usage;

• Transactions involving higher-risk jurisdictions;

• Attempts to structure transactions to circumvent applicable controls or limits;

• Rapid or unusual movement of funds without an apparent legitimate purpose;

• Activity associated with suspected fraud or other financial crime; and

• Other activity identified through our risk-management systems.

Where activity is flagged for review, we may request additional information, restrict or delay activity, decline a transaction, suspend an account, or take other appropriate action.

Where QOR LTD identifies activity that it reasonably suspects may involve money laundering, terrorist financing, fraud, sanctions violations, or another form of financial crime, the matter may be escalated for investigation and appropriate action.

Where reporting is required by applicable law or falls within the responsibility of an applicable regulated third-party provider, information may be reported or provided to the relevant competent authority, financial intelligence authority, law-enforcement agency, regulator, or other authorised body.

QOR LTD may restrict or suspend an account or transaction where necessary to manage financial crime risk or comply with applicable requirements.

We do not disclose information about investigations or reports where doing so would be prohibited by law or could constitute unlawful tipping-off.

QOR LTD maintains controls designed to prevent its platforms and services from being used in connection with applicable sanctions restrictions.

Depending on the service, applicable requirements, and third-party provider arrangements, screening may involve relevant sanctions lists and restrictions issued by competent authorities or other applicable bodies.

These may include, where applicable:

• United Nations Security Council sanctions;

• Nigerian sanctions and applicable domestic restrictions;

• Other applicable national sanctions regimes; and

• Sanctions requirements applicable to relevant third-party providers or services.

Where a person, entity, transaction, or activity is identified as presenting a sanctions concern, appropriate action may include additional review, restriction, rejection, suspension, or reporting where required.

QOR LTD maintains appropriate records relating to customer due diligence, transactions, compliance reviews, and financial crime controls in accordance with applicable legal, regulatory, contractual, and operational requirements.

Records may include:

• Customer identification and verification information;

• Transaction information;

• Compliance and risk assessments;

• Monitoring and review records;

• Relevant communications and supporting documentation; and

• Records relating to investigations or reports where applicable.

Records are protected using appropriate technical and organisational measures and may be made available to competent authorities or applicable third-party providers where lawfully required.

Retention periods may vary depending on the type of record, applicable legal or regulatory requirements, the nature of the service, and legitimate business or compliance needs.

QOR LTD expects employees and contractors whose roles involve relevant platform operations, customer information, transactions, compliance, or financial crime risk to understand and follow applicable AML and financial crime controls.

Relevant personnel may receive training appropriate to their responsibilities, including areas such as:

• Identifying indicators of money laundering and financial crime;

• Customer due diligence requirements;

• Escalation and reporting procedures;

• Sanctions awareness;

• Fraud prevention;

• Data protection and confidentiality; and

• Applicable internal policies and procedures.

Cashmama integrates with third-party providers to deliver certain specialised services.

Where applicable, QOR LTD considers relevant financial crime, compliance, security, and operational risks associated with third-party relationships.

Depending on the service, third-party providers may perform their own:

• Customer identification and verification;

• Transaction monitoring;

• Sanctions screening;

• Risk assessment;

• Fraud controls;

• Regulatory reporting; and

• Other compliance functions.

Responsibilities between QOR LTD and a third-party provider may vary according to the service, contractual arrangements, applicable law, and the provider's regulatory responsibilities.

QOR LTD does not represent that it assumes the regulatory responsibilities of a licensed third-party provider.

Users must not use Cashmama or any QOR LTD-operated platform to:

• Launder or conceal proceeds of crime;

• Finance terrorism or other unlawful activities;

• Circumvent applicable sanctions;

• Facilitate fraud or financial crime;

• Structure transactions for the purpose of evading applicable controls or reporting requirements;

• Provide false, misleading, or fraudulent identity information;

• Use an account on behalf of an undisclosed third party where prohibited;

• Attempt to circumvent identity verification, transaction monitoring, or other security controls; or

• Engage in any activity prohibited by applicable law or the applicable service terms.

Where prohibited activity is identified or reasonably suspected, QOR LTD may restrict or suspend the relevant account or transaction and take other appropriate action.

QOR LTD may cooperate with competent authorities, law-enforcement agencies, regulators, financial intelligence authorities, and other authorised bodies where required by applicable law or lawful process.

This may include providing information or records relevant to an investigation, compliance request, or legal obligation.

Any disclosure will be handled in accordance with applicable law, privacy requirements, and our contractual obligations.

This AML Policy is reviewed periodically and may be updated when necessary to reflect:

• Changes to applicable laws or regulatory requirements;

• Changes to QOR LTD's platforms or services;

• Changes in financial crime risks;

• Changes in third-party provider arrangements;

• Changes in internal controls or procedures; and

• Findings from internal reviews, risk assessments, or other relevant sources.

The current version of this policy will be made available through the QOR LTD website.

Questions regarding this AML Policy or financial crime compliance matters may be directed to: