Anti-fraud Policy

Last update: April 2025

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1. POLICY STATEMENT

CARPATHIAN FORGE is committed to conducting business inaccordance with the highest ethical, professional and legal standards. Thepublic, CARPATHIAN FORGE’s partners and Users’ have the right to expect thatprofessional, competent and trustworthy people are employed by CARPATHIAN FORGE.

CARPATHIAN FORGE will comply with applicable legislation. Inline with applicable legislation CARPATHIAN FORGE has a ‘zero tolerance’ policytowards fraud, corruption, collusion, money laundering, financing of terrorismand other criminal conduct (jointly “Prohibited Conduct”) and will thoroughlyinvestigate and seek to take disciplinary and/or legal action against those whoperpetrate, are involved in, or assist with fraudulent or other improperactions in all CARPATHIAN FORGE activity and related transactions.

CARPATHIAN FORGE will provide adequate and appropriateresources to implement the Anti-Fraud Policy and will ensure it is communicatedand understood.

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2. LEGISLATION COMPLIANCE

The Anti-Fraud Policy has been drafted to comply with thecurrent applicable local and international legislation, including, but notlimited to applicable EU legislation.

Adherence to the Anti-Fraud Policy CARPATHIAN FORGE willensure compliance with all relevant legislation and internal policies.

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3. DEFINITIONS

In pursuance of the Anti-Fraud Policy, Prohibited Conductincludes fraud, corruption, collusion, money laundering, financing of terrorismand other criminal conduct defined as follows:

A. Fraud: any act or omission, including a misrepresentationthat knowingly or recklessly misleads, or attempts to mislead, a party toobtain a financial or other benefit or to avoid an obligation.

B. Corruption: offering, giving, receiving, or soliciting,directly or indirectly, anything of value to influence improperly the action ofanother party.

C. Collusion: arrangement between two or more partiesdesigned to achieve an improper purpose, including influencing improperly theactions of another party.

D. Money laundering: (a) the conversion or transfer ofproperty, knowing that such property is derived from criminal activity or froman act of participation in such activity, for the purpose of concealing ordisguising the illicit origin of the property or of assisting any person who isinvolved in the commission of such activity to evade the legal consequences ofhis action; (b) the concealment or disguise of the true nature, source,location, disposition, movement, rights with respect to, or ownership ofproperty, knowing that such property is derived from criminal activity or froman act of participation in such activity; (c) the acquisition, possession oruse of property, knowing, at the time of receipt, that such property wasderived from criminal activity or from an act of participation in suchactivity; (d) participation in, association to commit, attempts to commit andaiding, abetting, facilitating and counselling the commission of any of theactions mentioned in the foregoing points

E. Terrorist financing: provision or collection of funds, byany means, directly or indirectly, with the intention that they should be usedor in the knowledge that they are to be used, in full or in part, in order tocarry out any of the offences within the meaning of Articles 1 to 4 of CouncilFramework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.

F. Criminal conduct: conduct, which constitutes an offencein any part of the world or would constitute an offence in any part of theworld if it occurred there.

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4. KEY RESPONSIBILITIES

CARPATHIAN FORGE performs a “Know-Your-Customer Policy”(KYC) due diligence on all new Users and a due diligence on all transactions inorder to detect possible compliance or integrity concern. Such due diligence isperformed in accordance with the requirements of the money laundering andterrorist financing activities regulations, pursuant to the terms of KYC.

In view of the Anti-Fraud Policy CARPATHIAN FORGE isresponsible 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;
• ensuring     all members of the operational anti-fraud department have a duty to report     any internal and external suspicions or incidents of Prohibited Conduct;
• reviewing     continuously its systems, procedures and internal controls through risk     management processes and audit arrangements;

• reporting     any suspicions regarding Prohibited Conduct to the relevant state     authorities.

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5. FRAUD DETECTION AND INVESTIGATION

CARPATHIAN FORGE’s Operational Anti-Fraud Department, inparticular, the Anti-Fraud Commissioner, is the first line of detection,investigation and protection in preventing Prohibited Conduct through the Usersand transactions appraisal process. The Anti-Fraud Commissioner will beresponsible for the proper fulfillment of the Anti-Fraud Policy.

(a) Authority

The Anti-Fraud Commissioner, through the OperationalAnti-Fraud Department, working in close collaboration with the NominatedOfficer (cf. Know-Your-Customer Policy), shall be responsible for:

• receiving     reports of alleged or suspected Prohibited Conduct involving CARPATHIAN     FORGE, its Users and/or related transactions;
• investigating     such matters and cooperating directly with the Nominated Officer in order     to facilitate the investigations;
• reporting     its findings to the CARPATHIAN FORGE management and relevant authorities,     as well as any other third party on a need-to-know basis.

For situations requiring an urgent response, the Anti-FraudCommissioner may take any necessary measures required for the investigation,notably to preserve evidence.

(b) Independence

The Operational Anti-Fraud Department shall enjoy completeindependence in the exercise of its responsibilities. The Anti-FraudCommissioner shall have full authority to open, pursue, close and report on anyinvestigation on Prohibited Conduct within its remit without prior notice to,the consent of, or interference from any other person or entity.

(c) Professional Standards

All Prohibited Conduct investigations conducted by theOperational Anti-Fraud Department shall be fair and impartial, with due regardto the rights of the Users and persons or entities involved. The presumption ofinnocence applies to those alleged to have engaged in misconduct. Thoseinvolved in the Prohibited Conduct investigation (be those under investigationor those conducting the investigation) should be aware of their rights andobligations and ensure they are fully respected.

(d) Cooperation

All Users are required to cooperate with the OperationalAnti-Fraud Department and the Anti-Fraud Commissioner promptly, fully,efficiently and in the manner specified by the Operational Anti-FraudDepartment, including by answering relevant questions and complying withrequests for information and records.

(e) Confidentiality

In accordance with CARPATHIAN FORGE internal rules on accessto information, all information and documents collected and generated during aProhibited Conduct investigation, not already in the public domain, shall bekept strictly confidential. The confidentiality of the information collectedwill be respected both in the interests of those concerned and the integrity ofthe investigation.

In particular, during the Prohibited Conduct investigationthe confidentiality will be respected in so far as it would not be contrary tothe interests of the investigation.

The Operational Anti-Fraud Department shall disclose suchinformation and documents only to those persons or entities authorized toreceive them or otherwise on a need-to-know basis.

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6. MISCELLANEOUS

CARPATHIAN FORGE will review the Anti-Fraud Policy toreflect new legal and regulatory developments and ensure good practice.

I WARRANT AND GUARANTEE THAT I HAVE NO INTENTION TO COMMITANY OF PROHIBITED CONDUCT ACTS DESCRIBED HEREIN; FURTHERMORE, I CONSENT TO ANYCHECKS DUE TO INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND I AGREE TOCOOPERATE FULLY AND PROMPTLY WITH THE ANTI-FRAUD COMMISSIONER WITHIN SUCHINVESTIGATION.

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