UPDATED AS OF 20 OF February 2024

ICM Capital Anti-Money Laundering (AML) and Know Your Client (KYC) Policy

1. Company Policy

It is the policy of ICM Capital AG (hereinafter referred to as “the company”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the law and implementing regulations within the company’s existing projects.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Although cash is rarely deposited into securities accounts, the securities industry is unique in that it can be used to launder funds obtained elsewhere and to generate illicit funds within the industry itself through fraudulent activities. Examples of types of fraudulent activities include insider trading, market manipulation, Ponzi schemes, cybercrime, and other investment- related fraudulent activity.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.

Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable regulations and authorized body rules and will be reviewed and updated regularly to ensure appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.

2. AML Compliance Person Designation and Duties

The company has designated a compliance officer as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the company’s AML/CFT program. A compliance officer shall be appointed by the company’s director or board of directors. The compliance officer has a working knowledge of the implementing regulations and is qualified by experience, knowledge, and training. The duties of the AML Compliance Person will include monitoring the company’s compliance with AML/CFT obligations, overseeing communication and training for employees, and any other duties decided by the director. The AML Compliance Person will also ensure that the company keeps and maintains all of the required AML/CFT records and will ensure that Suspicious Activity Reports are filed with the state authorities when appropriate. The AML Compliance Person is vested with full responsibility and authority to enforce the company’s AML program. The company will provide the authorized body with contact information for the AML Compliance Person, including (1) name; (2) title; (3) mailing address; (4) email address; (5) telephone number; and (6) facsimile (if any). The company will promptly notify the authorized body of any change in this information and will review, and if necessary update, this information within 30 business days after the end of each calendar year. The annual review of authorized body information will be conducted by the compliance officer and will be completed with all necessary updates being provided no later than 30 business days following the end of each calendar year. In addition, if there is any change to the information, the compliance officer will update the information promptly, but in any event not later than 30 days following the change.

3. Giving AML Information to the authorized body and Financial Institutions Authorized body Requests

ICM Capital will respond to an authorized body request concerning accounts and transactions by immediately searching our records to determine whether ICM Capital maintains or has maintained any account for, or has engaged in any transaction with, each individual, entity, or organization named in the Request. ICM Capital understands that ICM Capital has limited time from the transmission date of the request to respond to a Request.

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