� Money Laundering (ML): The process of disguising the illegal origin of proceeds of crime.

� Terrorist Financing (TF): The provision or collection of funds, from legitimate or illicit sources, with the intention or knowledge that they are to be used for terrorist acts.

� Customer Due Diligence (CDD): The process of identifying and verifying a customer's identity and assessing their risk profile.

� Enhanced Due Diligence (EDD): Additional measures applied to higher-risk customers, transactions, or business relationships.

� Politically Exposed Person (PEP): An individual entrusted with prominent public functions, both foreign and domestic, and their immediate family members and close associates.

� Suspicious Transaction: A transaction that is inconsistent with a customer's known business, profile, or which has no apparent lawful purpose.

� Designated Non-Financial Business and Profession (DNFBP): The category under which the Company falls, requiring registration and compliance with SCUML.

The Company conducts an annual enterprise-wide ML/TF/PF risk assessment to identify, understand, and mitigate risks specific to our sector. Key risk factors considered include:

� Customer Risk: (e.g., PEPs, customers from high-risk jurisdictions, cash-intensive businesses).

� Product/Service Risk: (e.g., high-value stone transactions, international wire transfers, trade-based money laundering).

� Geographic Risk: (e.g., countries with weak AML/CFT regimes, conflict zones where "blood minerals" may originate).

� Channel/Delivery Risk: (e.g., use of intermediaries, non-face-to-face business relationships).

5.1 Mandatory Identification & Verification: Before establishing a business relationship or conducting a significant transaction,the Company will:

� Identify and verify the customer's legal identity using reliable, independent source documents (e.g., Certificate of Incorporation, National ID, International Passport, Tax Identification Number).

� Identify and verify the Beneficial Owner(s) (individuals who ultimately own or control the customer).

� Understand the nature of the customer's business and the intended purpose of the relationship.

5.2 Ongoing Due Diligence: All customer information will be kept up-to-date.Transactions will be monitored to ensure they are consistent with our knowledge of the customer.

5.3 Enhanced Due Diligence (EDD): EDD measures will be applied to higher-risk categories,including but not limited to:

� Politically Exposed Persons (PEPs).

� Customers from high-risk jurisdictions.

� Complex, unusually large, or unusual patterns of transactions with no clear economic purpose.

� Requests for payment in large amounts of cash. EDD may include obtaining additional information,seeking senior management approval, and conducting more frequent monitoring.

5.4 Simplified Due Diligence (SDD): May be applied to customers presenting a lower risk,as defined by our risk assessment and in accordance with the law.

7.1 Internal Reporting Obligation: Any employee who suspects or has reasonable grounds to suspect that a transaction,funds, or activity is linked to ML/TF must immediately file an internal Suspicious Activity Report (SAR) with the designated Compliance Officer.

7.2 External Reporting to SCUML: The Compliance Officer is responsible for reviewing all internal SARs and,where appropriate, filing a Suspicious Transaction Report (STR) with SCUML and the Nigerian Financial Intelligence Unit (NFIU) within 24 hours of forming the suspicion, without tipping off the subject.

7.3 Prohibition of "Tipping Off": It is an offense to inform a customer or third party that a STR has been filed or that an investigation is underway.

All employees will receive regular, mandatory AML/CFT training upon induction and annually thereafter. Training will cover:

� Relevant Nigerian AML/CFT laws and this policy.

� Red flag indicators specific to the precious stones/minerals trade.

� CDD and EDD procedures.

� The process for internal and external reporting.

The Company appoints a Compliance Officer ([Name/Position, e.g., The Internal Auditor, Sadiq Lawan]) who is responsible for:

� The day-to-day implementation of this policy.

� Acting as the central point for all AML/CFT matters.

� Liaising with SCUML, NFIU, and other relevant authorities.

� Ensuring STRs are filed promptly.

� Organizing employee training.

� Conducting the annual ML/TF risk assessment.