Anti-fraud policy

Anti Fraud Policy

1. POLICY STATEMENT

1.1. BIT2ME creates opportunities for the people and builds trust between them worldwide. BIT2ME is committed to conducting business in accordance with the highest ethical, professional and legal standards. The public, BIT2ME's partners and User's have the right to expect that professional, competent and trustworthy people are employed by BIT2ME.1.2. BIT2ME will comply with the applicable legislation. In accordance with the applicable legislation, BIT2ME has a "zero tolerance" policy towards fraud, corruption, collusion, money laundering, terrorism financing, and other criminal conduct (collectively "Prohibited Conduct") and will thoroughly investigate and seek to take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent actions or other inappropriate actions in all BIT2ME activities and related transactions.1.3. BIT2ME will provide adequate and appropriate resources to implement the Anti-Fraud Policy and will ensure it is communicated and understood.

2. LEGISLATION COMPLIANCE

2.1. The Anti-Fraud Policy has been drafted to comply with the current applicable local and international legislation, including, but not limited to applicable EU legislation.2.2. Adherence to the Anti-Fraud Policy BIT2ME will ensure compliance with all relevant legislation and internal policies.

3. DEFINITIONS

In compliance with the Anti-fraud policy, prohibited conduct includes fraud, corruption, collusion, money laundering, terrorism financing, and other criminal behaviours defined as follows:3.1. Fraud: any act or omission, including a misrepresentation that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.3.2. Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the action of another party.3.3. Collusion: Agreement between two or more parties designed to achieve an improper purpose, including the inappropriate influence of the actions of another party.3.4. Money laundering:

1. The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the fee of such activity to evade the legal consequences of his action.
2. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from a criminal activity or from an act of participation in such activity.
3. The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity.
4. Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions mentioned in the foregoing points.

3.5. Terrorist financing: provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475 / JHA of 13 June 2002 on combating terrorism.3.6. Criminal conduct: conduct, which constitutes an offense in any part of the world or would constitute an offense in any part of the world if it occurred there.

4. KEY RESPONSIBILITIES

4.1. BIT2ME carries out a due diligence on "Know Your Customer" (KYC) policy for all new users and a due diligence on all transactions to detect possible compliance or integrity issues. Such due diligence is carried out in accordance with the requirements of anti-money laundering and counter-terrorism financing regulations, in accordance with KYC terms.4.2. In view of the Anti-fraud policy, BIT2ME is responsible for:

• Ensuring efficient and effective systems, procedures and internal controls are in place to enable the prevention and detection of Prohibited Conduct.
• Ensuring the Anti-Fraud Commissioner identifies Prohibited Conduct risks in their areas of business and that all systems, procedures and internal controls are properly implemented and enforced.
• Ensure that all members of the operational fraud department have the obligation to report any suspicion or internal and external incidents of prohibited conduct.
• Continuous review of it's systems, procedures, and internal controls through risk management processes and audit arrangements.
• Report any suspicion of prohibited conduct to the relevant state authorities.

5. FRAUD DETECTION AND INVESTIGATION

5.1. BIT2ME's Operational Anti-Fraud Department, in particular, the Anti-Fraud Commissioner, is the first line of detection, investigation and protection in preventing Prohibited Conduct through the Users and transactions appraisal process. The Anti-Fraud Commissioner will be responsible for the proper fulfillment of the Anti-Fraud Policy.

1. AuthorityThe Anti-Fraud Commissioner, through the Operational Anti-Fraud Department, working in close collaboration with the Nominated Officer (cf. Know-Your-Customer Policy), shall be responsible for:
   • Receiving reports of alleged or suspected Prohibited Conduct involving BIT2ME, its Users and / or related transactions.
   • Investigating such matters and cooperating directly with the Nominated Officer in order to facilitate the investigations.
   • Report your findings to the BIT2ME management and relevant authorities, as well as any other third parties as necessary.
   For situations requiring an urgent response, the Commissioner for combating fraud may take necessary measures for the investigation, particularly to preserve evidence.
2. IndependenceThe Operational Anti-Fraud Department shall enjoy complete independence in the exercise of its responsibilities. The Anti-Fraud Commissioner shall have full authority to open, pursue, close and report on any investigation on Prohibited Conduct within its remit without prior notice to, the consent of, or interference from any other person or entity.
3. Professional StandardsAll investigations of prohibited conduct carried out by the Operational Department for Combating Fraud will be fair and impartial, with due respect for the rights of Users and the individuals or entities involved. The presumption of innocence applies to those who are allegedly involved in misconduct. Those involved in the Prohibited Conduct investigation (whether the investigated parties or those conducting the investigation) must be aware of their rights and obligations and ensure that they are fully respected.
4. CooperationAll Users are required to cooperate with the Operational Anti-Fraud Department and the Anti-Fraud Commissioner promptly, fully, efficiently and in the manner specified by the Operational Anti-Fraud Department, including by answering relevant questions and complying with requests for information and records.
5. ConfidentialityIn accordance with BIT2ME internal rules on access to information, all information and documents collected and generated during a Prohibited Conduct investigation, not already in the public domain, shall be kept strictly confidential. The confidentiality of the information collected will be respected both in the interests of those concerned and the integrity of the investigation.In particular, during the Prohibited Conduct investigation the confidentiality will be respected in so far as it would not be contrary to the interests of the investigation.The Operational Anti-Fraud Department shall disclose such information and documents only to those persons or entities authorized to receive them or otherwise on a need-to-know basis.

6. MISCELLANEOUS

6.1. BIT2ME will review the Anti-fraud policy to reflect new legal and regulatory developments and ensure good practice.6.2. I WARRANT AND GUARANTEE THAT I HAVE NO INTENTION TO COMMIT ANY OF PROHIBITED CONDUCT ACTS DESCRIBED HEREIN; FURTHERMORE, I CONSENT TO ANY CHECKS DUE TO INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND I AGREE TO COOPERATE FULLY AND PROMPTLY WITH THE ANTI-FRAUD COMMISSIONER WITHIN SUCH INVESTIGATION.