1. Introduction and Purpose of the Policy

Jadwa Al-Yaqeen Investment L.L.C. (hereinafter referred to as the “Company”) is committed to the highest standards of integrity and transparency in all its investment and asset management activities. This policy has been established to ensure that the Company’s products and services are not used as channels for money laundering, terrorist financing, or any other illicit financial activities. The purpose of this document is to establish a comprehensive framework that complies with applicable local laws and regulations, as well as international recommendations and best practices issued by the Financial Action Task Force (FATF), and the directives of competent regulatory authorities.

2. Scope of Application

This policy applies to all members of the Board of Directors, executive management, and all employees and staff of the Company across all levels. It also extends to branches, subsidiaries (if any), third parties providing services on behalf of the Company, and all clients, including individuals, companies, and institutions benefiting from asset management and investment fund services.

3. Key Definitions

• Money Laundering (ML): Any act involving the concealment or disguise of the illicit origin of funds or proceeds derived from predicate offenses, to present them as originating from legitimate sources.
• Terrorist Financing (TF): The provision, collection, or making available of funds, directly or indirectly, by any means, with the intention that they be used, in whole or in part, to finance a terrorist act or terrorist individuals or organizations.
• Ultimate Beneficial Owner (UBO): The natural person(s) who ultimately owns or controls the client, or the person on whose behalf a transaction is being conducted, including those who exercise ultimate effective control over a legal person or legal arrangement.
• Politically Exposed Persons (PEPs): Individuals who are or have been entrusted with prominent public functions (domestically or internationally), as well as their family members and close associates, due to their higher exposure to bribery and corruption risks.
• Financial Intelligence Unit (FIU): The central independent national authority responsible for receiving, analyzing, and disseminating disclosures of financial transactions suspected of being linked to money laundering or terrorist financing.

4. Company Commitment to AML/CFT

The Company adopts a “Zero Tolerance” policy toward any direct or indirect involvement in money laundering or terrorist financing activities. The Company is committed to implementing a Risk-Based Approach and to providing the human and technological resources necessary to ensure the effectiveness of compliance programs, as well as full cooperation with competent regulatory and security authorities.

5. Know Your Customer (KYC) Procedures

Know Your Customer (KYC) procedures form the cornerstone of this policy. The Company does not establish any business relationship, open any investment accounts, or manage assets without the full completion of KYC forms. These procedures include collecting accurate information about the client’s identity, nature of business, purpose of the business relationship, and sources of funds and wealth, with periodic updates of such data.

6. Customer Due Diligence (CDD)

The Company applies Customer Due Diligence (CDD) measures when establishing a business relationship, executing occasional transactions exceeding set thresholds, upon suspicion, or when there are doubts about the accuracy of client data. These measures include:

• Identifying and verifying the client’s identity using original and reliable documents.
• Understanding the nature of the client’s business and the financial structure of their company.
• Identifying the purpose of the investment or establishment of the investment fund.

7. Enhanced Due Diligence (EDD) for High-Risk Clients

Enhanced Due Diligence (EDD) measures are applied to clients classified as high risk (e.g., PEPs, clients from non-cooperative or high-risk countries, and companies with complex structures). These measures include:

• Obtaining senior management approval before establishing or continuing the business relationship.
• Taking additional measures to verify the actual source of funds and wealth.
• Conducting intensified and ongoing monitoring of these clients’ investment activities.

8. Verification of Client Identity and Ultimate Beneficial Owner

The Company does not rely solely on verifying the direct client but takes reasonable measures to identify the Ultimate Beneficial Owner (UBO) for legal entity clients. Corporate confidentiality barriers are penetrated to identify the natural persons who own a controlling interest (in accordance with applicable legal thresholds) or exercise effective control over the company’s decisions and investment operations, and to verify their identities.

9. Risk Classification and Assessment

The Company relies on an internal assessment of the risks of money laundering and terrorist financing associated with its activities. Clients are classified into (low, medium, and high risk) based on four main factors:

1. Client Risk: Nature of the client’s activity, position, and legal structure.
2. Geographical Risk: Country of residence or source of funds and the extent to which those countries comply with FATF standards.
3. Product and Service Risk: Nature of the investment funds or managed portfolios.
4. Delivery Channel Risk: Face-to-face interactions versus non-face-to-face interactions.

10. Monitoring of Financial and Investment Transactions

All portfolios and investment funds managed by the Company are subject to Ongoing Monitoring. Modern technological systems are used to track investment transactions and the movement of incoming and outgoing funds, ensuring consistency with the available client information and their usual activity patterns. Any complex, unusually large transactions, or those lacking an apparent economic or lawful purpose are thoroughly examined.

11. Reporting Suspicious Transactions

Where there are reasonable grounds to suspect that funds are linked to a crime, money laundering, or terrorist financing, Company employees must immediately report internally to the “Compliance and AML Officer.” The Compliance Officer studies the case, and if suspicion is confirmed, a Suspicious Transaction Report (STR/SAR) is promptly submitted to the authorized Financial Intelligence Unit (FIU) in accordance with applicable legal procedures, without awaiting approval from any other party.

12. Record Keeping and Documentation

The Company retains all client-related records and documents, including identification data, KYC forms, managed account records, business correspondence, and suspicious transaction reports. These records are stored securely to ensure retrieval upon request, for a minimum period as stipulated by law (typically 5 to 10 years) after the end of the business relationship or the execution of an occasional transaction.

13. Sanctions and Compliance with International and Local Lists

The Company is committed to not entering into any investment relationship with individuals or entities listed on local or international sanctions lists. The Company screens client names, UBOs, and related parties and periodically matches them automatically against lists issued by:

• The United Nations Security Council (UNSC).
• Competent regulatory and local authorities in the Syrian Arab Republic.
• Any other international sanctions lists relevant to the Company’s scope of work.

In the event of a positive match, immediate freezing measures are taken, and regulatory authorities are notified without delay.

14. Responsibilities of the Board of Directors and Executive Management

• Board of Directors: Bears ultimate responsibility for approving the AML/CFT policy, ensuring a strong compliance culture within the Company, and reviewing periodic reports submitted by the compliance function.
• Executive Management: Responsible for the effective implementation of this policy, providing the necessary systems and resources to the Compliance Officer, and ensuring the integration of AML procedures into daily asset management operations.

15. Responsibilities of the Compliance Officer (Compliance Officer / MLRO)

The Board appoints an independent Compliance Officer with sufficient authority and access to all data and records. Responsibilities include:

• Developing and updating internal procedures manuals.
• Receiving and investigating internal reports.
• Submitting suspicious transaction reports to the competent authorities.
• Direct communication with regulatory bodies.
• Preparing periodic reports to the Board of Directors on the effectiveness of AML procedures within the Company.

16. Employee Training and Awareness

The Company implements training and awareness programs (at least annually) for all new and existing employees. Training aims to inform them of the latest laws, modern money laundering methods in the investment sector, how to identify suspicious activities, and internal reporting procedures. Records documenting employee attendance of such programs are maintained.

17. Confidentiality and Information Protection

All information related to clients and suspicious transactions is considered strictly confidential. It is strictly prohibited for any employee or official of the Company to “tip-off” or disclose to a client or any third party that their transactions are under investigation or that a suspicious report has been filed against them. Such actions expose the perpetrator to criminal legal liability.

18. Periodic Policy Review

This policy is subject to annual internal review and evaluation, or whenever necessary due to changes in local laws, updates to FATF recommendations, or changes in the Company’s organizational or operational structure. Any proposed amendments are submitted to the Board of Directors for approval.

19. General Provisions

This policy is binding on all relevant parties at Jadwa Al-Yaqeen Investment L.L.C. Any violation or negligence in applying its provisions shall subject the offender to strict internal disciplinary measures, which may include termination of employment, in addition to legal prosecution by competent authorities. The Company affirms that the protection of the financial system and society outweighs any commercial or profit considerations.