Anti-Money Laundering (AML) Policy

This Anti-Money Laundering (AML) Policy establishes the obligations, procedures and controls that World Gold Diamonds ("the Company") applies to detect, prevent and report money laundering, terrorist financing and proliferation financing in accordance with applicable international standards and national legislation.

This policy applies to all directors, officers, employees, contractors, agents and representatives of World Gold Diamonds, and to all business activities including gold trading, diamond trading, mineral brokerage, export logistics and any ancillary services offered by the Company.

World Gold Diamonds conducts its AML programme in alignment with the following international frameworks and standards:

• Financial Action Task Force (FATF) 40 Recommendations and related guidance for Dealers in Precious Metals and Stones (DPMS)
• FATF Guidance on Risk-Based Approach for the Precious Metals and Stones Sector
• Egmont Group financial intelligence standards
• Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) directives
• United Nations Convention Against Transnational Organized Crime
• Applicable national anti-money laundering legislation in jurisdictions of operation
• LBMA Responsible Gold Guidance (for gold trading activities)
• Kimberley Process Certification Scheme requirements (for diamond trading activities)

The Company applies Customer Due Diligence (CDD) to all prospective counterparties before entering into any commercial relationship or executing any transaction. The level of due diligence is calibrated to the assessed risk of the customer and transaction.

Standard CDD includes:

• Verification of identity using government-issued documentation
• Verification of legal entity using certificate of incorporation, constitutional documents and ownership registers
• Identification and verification of beneficial owners holding 25% or greater interest
• Screening of all parties against OFAC, UN, EU and national sanctions lists
• PEP screening and adverse media checks
• Verification of source of funds and source of wealth for high-value transactions

Enhanced Due Diligence (EDD) is applied where the customer is a PEP, is resident in a high-risk jurisdiction, or where the transaction exhibits characteristics associated with elevated ML/TF risk. EDD involves senior management approval, deeper source-of-funds investigation and enhanced ongoing monitoring.

All transactions are subject to ongoing monitoring to detect patterns or activities inconsistent with the known profile of the customer. The Company applies both automated and manual monitoring procedures. Indicators that may trigger enhanced scrutiny include:

• Transactions structurally designed to remain below reporting thresholds (smurfing)
• Payment originating from or directed to a jurisdiction subject to FATF enhanced monitoring
• Requests to deviate from standard payment channels or to pay cash
• Unusual urgency or pressure to complete a transaction without standard documentation
• Transactions inconsistent with the customer's stated business profile or financial capacity
• Third-party payments without clear legitimate explanation
• Requests for cargo to be redirected to an undisclosed or unusual final destination

Where any employee or representative of the Company forms a suspicion — or has reasonable grounds to suspect — that a transaction involves proceeds of crime or is connected to money laundering or terrorism financing, they are required to report this immediately to the designated Compliance Officer.

The Compliance Officer is responsible for evaluating the internal report and, where appropriate, filing a Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit (FIU) in the applicable jurisdiction. No transaction subject to an STR assessment will proceed until the Compliance Officer has provided written clearance.

The Company operates a zero-tolerance policy with respect to dealing with sanctioned individuals, entities, vessels or jurisdictions. All counterparties — including buyers, sellers, freight agents, banks and intermediaries — are screened prior to engagement and on an ongoing basis against:

• United Nations Security Council Consolidated Sanctions List
• OFAC Specially Designated Nationals (SDN) List
• European Union Consolidated Sanctions List
• UK HM Treasury Financial Sanctions List
• Applicable national sanctions registers

Any positive match — or any transaction with a nexus to a sanctioned jurisdiction — is immediately frozen and referred to the Compliance Officer. No funds or assets will be released pending resolution.

The Company maintains comprehensive records of all customer identification documentation, transaction records and STRs for a minimum period of five (5) years from the date of the transaction or the end of the customer relationship, whichever is later. Records are stored securely and are available for production to regulatory authorities upon lawful request.

All employees with client-facing, transaction-processing or management responsibilities receive mandatory AML training upon commencement of employment and on an annual basis thereafter. Training covers recognition of ML/TF red flags, internal reporting procedures and the legal obligations of employees under applicable legislation.

Failure to comply with this policy — including failure to report a suspicion, facilitating a transaction in breach of this policy, or tipping off a customer — will result in immediate disciplinary action, up to and including termination of employment or contractual engagement. The Company will cooperate fully with law enforcement and regulatory authorities in any investigation arising from non-compliance.

This policy is reviewed annually by the Compliance Officer and Board of Directors, or more frequently where required by changes to applicable legislation, regulatory guidance or the Company's risk profile. The current version supersedes all previous versions.