OWODAILY LIMITED

ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM POLICY AND (AML/CFT POLICY)

1. SCOPE AND PURPOSE OF THIS POLICY

The objectives of this AML/CFT Policy (“The Policy”) is to ensure OwoDaily Limited (“The Company”), identifies and mitigates compliance risks in fulfilment of AML/CFT obligations under applicable laws such as : Money Laundering Prohibition Act, 2011 (as amended), Terrorism Prevention Act, 2013, and other relevant laws and directives.

This policy outlines security measures the Company has adopted; its policies, practices, and procedures that must be observed, to promote professional standards among employees, contractors and business partners, and prevent the Company from being used for criminal activities.

Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal proceeds may take any form, including money or money’s worth, securities, tangible property and intangible property.

Terrorism Financing is defined as providing, distributing or collection of legitimate or illegitimate funds, directly or indirectly, intended to be used, for the commission or promotion of terrorist acts.

This Policy is aimed to prevent any organization or individual from using Owodaily Limited for money laundering or terrorist financing activities, and the company’s corresponding action in cases of attempt.

2. OUR POLICY

2.1 CUSTOMER DUE DILIGENCE (CDD)

2.2 Know Your Customer (KYC)

To prevent Money Laundering, the Company will implement KYC procedure to identify their clients and ascertain relevant information before carrying out any businesses or transaction with them.

The Company will not establish a business relationship with any individual or entity, until the identity of a potential customer is satisfactorily established. This KYC procedure shall apply to:

a) Any entity that is a business partner of OwoDaily

b) Any entity that is a partner of OwoDaily, for the purpose of the cash back program

c) Any entity connected with a financial transaction, which can pose significant reputational or other risks to OwoDaily.

d) Subscribed users who are using the OwoDaily platform to transact with businesses

In carrying out its CDD activities and responsibilities, the Company shall:

a) Obtain the necessary documents and information from every client, on their identity and nature of business activities (those listed above)

b) Verify their identity and that of their beneficial owners, using reliable, independent source documents, data, or information

c) Maintain a record of client information and update same as frequently as practicable

d) Carry out continuous KYC update, beyond the account creation stage for users.

e) Report any and all suspicious transactions to the appropriate regulatory authority, which may be indicative of money laundering activities, Carry out enhanced due diligence for high-risk customers, business partners and transactions including Politically Exposed Persons (PEP), cross border transactions and business relationships and any other businesses, activities or professions as may be prescribed by regulatory authorities

f) Conduct independent verification of the legal status of incorporated entities and sole Proprietorships with the Corporate Affairs Commission.

Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the designated OwoDaily Chief Compliance department or commercial department.

2.3 HIGH RISK CUSTOMERS

The following are categorized as high risk customers:

a) Persons refusing to comply with the KYC requirements and provide the required information or documentation; or

b) Entities whose shareholder/control structure cannot be determined.

a) Persons indicating possible involvement in criminal activities, based on available information about them;

b) Persons with businesses in which the legitimacy of activity or source of funds cannot be reasonably verified;

c) Organizations that are required by regulation to obtain registration by the Special Control Unit against Money Laundering (SCUML).

2.4 COMPLIANCE OFFICER

OwoDaily Limited shall designate a compliance officer, whose responsibilities shall include:

a) Developing an AML/CFT Compliance Program and processes for the company

b) Considering internal reports of money laundering;

c) Reporting suspicions of money laundering to the responsible authorities; and

d) Acting as key liaison with the money laundering authorities.

e) Training the business and its employees on money laundering;

f) Submitting reports to the Special Control Unit Against Money Laundering (SCUML)

g) Advising on proceed after a report of suspicion on money laundering has been raised.

2.5 SUSPICIOUS TRANSACTIONS REPORTING

Owodaily employees and partners shall exercise due diligence in identifying and reporting any suspicious transaction to the Company’s compliance officer. The compliance officer may make reasonable enquiries within Owodaily Limited to obtain additional information to confirm these suspicions. After this assessment, the compliance officer will determine whether or not it is necessary to file an official report to the appropriate money laundering regulatory authorities.

Suspicious transactions shall include:

a) Transactions belonging to entities considered to be terrorist organizations

b) Transactions which are structured to avoid reporting and record keeping requirements

c) Altered or false identification or inconsistent information or any transaction involving criminal

A report on suspicious activity should contain, at least, the following information, which will be confirmed by the compliance officer:

• Identity of the person raising the suspicion;

• Date of the report;

• Who is suspected of money laundering or terrorist financing activities;

• Other individuals involved otherwise;

• Deliverance of facts;

• What is suspected and why; and

• Any possible involvement of OwoDaily Limited.

2.6 TRAINING

OwoDaily Limited is committed to compliance and all employees and contractors are required to complete mandatory compliance training, including provisions on anti-money laundering, to be organized by the Company.

Training encompassing applicable AML/CFT laws and recent trends in money laundering and terrorist financing activities as well as OwoDaily Limited policies and procedures. Trainings on AML/CFT shall be carried out as per regulatory requirement. Trainings shall be conducted using either of the following means:

• Engagement of an external facilitators/training outfits to train relevant staff.

• In house sessions organized for all staff by the compliance officer.

2.7 REVIEWS

The Compliance Officer shall undertake the review of the AML/CFT Policy annually, except in certain situations where new AML/CFT Regulations are introduced which would necessitate an earlier review/update of the Policy. The Board of Directors is saddled with the overall responsibility to approve the AML/CFT Policy and other updates or amendments to same.