Introduction:

Our Company (referred to as either “the Company”, “We”, “Us” or “Our”) refers to XUNICORN PROTECH PRIVATE LIMITED (Xunitee) with its office located at S-2223, 2nd floor, Block No. 2, Janapriya Hanumareddy complex, Sy.No.5, Hoodi (V), K R Puram Hobli, Bangalore, KA 560048 India. Our Company is committed to preventing money laundering and the financing of terrorism. We have implemented this Anti Money Laundering (AML) Policy to ensure compliance with all applicable laws and regulations, including but not limited to the Prevention of Money Laundering Act, 2002, Rules and Regulations under PMLA, 2005, Foreign Exchange Management Act (FEMA) ,1999, Benami Transactions (Prohibition) Act, 1988 and the Income Tax Act, 1961.

Scope:

This AML Policy applies to all employees, contractors, agents, and representatives of our company, as well as any third-party service providers that may handle customer information or transactions.

Policy Objectives:

To prevent our company from being used to facilitate money laundering and the financing of terrorism.

To comply with all applicable laws and regulations, including but not limited to the Prevention of Money Laundering Act, 2002 and Rules and Regulations under PMLA, 2005.

To maintain a culture of compliance with AML laws and regulations.

Procedures:

Customer Due Diligence (CDD): Our company will perform customer due diligence (CDD) on all customers to verify their identity and assess the risk of money laundering or terrorist financing. This may include obtaining government-issued identification, verifying information against public databases, and conducting additional risk-based due diligence as needed.

Suspicious Activity Reporting: Our employees, contractors, agents, and representatives are required to report any suspicious activity to the designated AML compliance officer. This includes, but is not limited to, transactions that are unusual for a customer, transactions that appear to have no legitimate purpose, and transactions that involve the movement of funds to or from high-risk jurisdictions.

Record Keeping: Our company will maintain accurate and complete records of all transactions, customer information, and suspicious activity reports in accordance with applicable laws and regulations.

Training: Our employees, contractors, agents, and representatives will receive training on AML laws and regulations, as well as our company’s AML policies and procedures. Training will be provided on a regular basis and updated as necessary to reflect changes in the law or in our company’s AML policies.

Independent Review: Our AML program will be reviewed regularly by an independent third-party to ensure that it is effective and compliant with applicable laws and regulations.

Sanctions Screening: Our company will screen all transactions and customers against lists of sanctioned individuals and entities maintained by government agencies.

Risk Assessment: Our company will periodically assess the risks associated with our products, services, customers, and geographic locations to ensure that our AML program remains effective and up-to-date.

Cooperation with Law Enforcement: Our company will cooperate with law enforcement agencies in any investigation related to money laundering or the financing of terrorism.

Penalties for Non-Compliance:

Employees, contractors, agents, and representatives who violate this AML Policy may face disciplinary action, up to and including termination of employment or contract. Our company may also face penalties, fines, and reputational harm as a result of non-compliance with AML laws and regulations.

This Anti Money Laundering Policy constitutes a binding agreement between our company and all employees, contractors, agents, and representatives, and is subject to change at any time without notice. If you have any questions or concerns, please contact our designated AML compliance officer.