Anti-Money Laundering and Anti-Bribery Policy

SOAX LTD — Anti-Money Laundering, Counter-Terrorist Financing, and Anti-Bribery Policy.

This Anti-Money Laundering and Anti-Bribery Policy (the "Policy") forms part of, and is incorporated by reference into, the SOAX Terms of Use. Capitalised terms used but not defined here have the meanings given to them in the ToU.

1. Introduction and Purpose

1. This Anti-Money Laundering and Anti-Bribery Policy (the "Policy") reflects the commitment of SOAX LTD, a company incorporated in England and Wales under registered number 11828506 ("SOAX", "we", "us" or "our"), to conduct its business lawfully, ethically and with integrity, and to maintain high standards of conduct across its operations and business relationships.

2. SOAX operates a web access infrastructure platform (the "Platform"). It is not a financial institution and does not operate in a sector subject to supervision under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. SOAX and all persons acting on its behalf nonetheless remain bound by the criminal prohibitions on money laundering, terrorist financing, bribery and corruption that apply to businesses generally, and SOAX has adopted this Policy as part of its broader commitment to responsible governance and the prevention of financial crime.

3. This Policy sets out the standards that SOAX observes, the standards it expects of those with whom it does business, and the consequences that may follow where those standards are not met.

2. Scope

1. This Policy applies to:

1. SOAX and all of its directors, officers, employees and contractors when acting on its behalf (“Personnel”); and

2. all clients, customers, suppliers, partners, agents, intermediaries and other third parties with whom SOAX has, or proposes to have, a business or contractual relationship (“Business Partners”).

1. Capitalised terms used but not defined in this Policy have the meaning given to them in the SOAX Terms of Use.

3. Our Commitment

1. SOAX has a zero-tolerance approach to money laundering, terrorist financing, bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate.

2. SOAX will not offer, give, solicit or accept any bribe, improper payment or other improper advantage, and will not knowingly engage in, facilitate, or allow its Platform or services to be used for, money laundering, terrorist financing or any other financial crime.

3. SOAX is committed to complying with all applicable laws relating to financial crime in each jurisdiction in which it operates, and to implementing and maintaining effective and proportionate systems and controls to prevent and detect such conduct.

4. Legal and Regulatory Framework

1. This Policy reflects SOAX’s obligations under, among others:

1. the Bribery Act 2010, including the corporate offence of failing to prevent bribery;

2. the Proceeds of Crime Act 2002;

3. the Terrorism Act 2000;

4. the Criminal Finances Act 2017, including the corporate offences of failing to prevent the facilitation of UK and foreign tax evasion;

5. the Sanctions and Anti-Money Laundering Act 2018 and applicable sanctions measures; and

6. any other anti-money laundering, counter-terrorist financing, anti-bribery, anti-corruption, sanctions and economic crime laws applicable to SOAX or its business.

1. Where SOAX does business internationally, it also has regard to comparable laws of other jurisdictions, including the U.S. Foreign Corrupt Practices Act 1977, to the extent applicable.

5. Anti-Bribery and Anti-Corruption

1. A bribe is a financial or other advantage offered, promised, given, requested, agreed to be received or accepted in order to induce or reward the improper performance of a function or activity, or to improperly influence a person in their official or business capacity. Bribery may be direct or indirect, including through a third party acting on a person’s behalf.

2. SOAX and its Personnel must not, directly or indirectly:

1. offer, promise, give, request, agree to receive or accept any bribe;

2. make or accept any facilitation or “grease” payment (an unofficial payment to secure or expedite a routine action); or

3. engage in any other corrupt conduct, whether involving a public official, a private individual or an organisation.

1. Gifts and hospitality are permitted only where they are reasonable and proportionate, given or received openly and in good faith, not intended to improperly influence any decision, and compliant with applicable law and SOAX’s internal procedures. Cash or cash-equivalent gifts must never be offered or accepted.

2. SOAX maintains internal procedures appropriate to the size and nature of its business that are designed to prevent bribery and corruption, including in its dealings with Personnel and Business Partners.

6. Anti-Money Laundering and Counter-Terrorist Financing

1. Money laundering is the process by which the proceeds of crime are converted into assets that appear to have a legitimate origin. Terrorist financing is the provision or collection of funds intended to be used, in whole or in part, for terrorist purposes.

2. SOAX will not knowingly enter into or maintain a business relationship, or process any transaction, that involves the proceeds of crime, the financing of terrorism, or any attempt to disguise the origin, ownership or control of funds or assets.

3. SOAX applies risk-based measures appropriate to its business, which may include verifying the identity of clients and their beneficial owners (KYC/KYB), assessing the purpose and intended nature of the relationship, monitoring for unusual or suspicious activity, and screening against applicable sanctions and watchlists, in accordance with its KYC/KYB Policy and related internal procedures.

4. SOAX may refuse to enter into, may suspend, or may terminate any relationship or transaction where it identifies a money laundering, terrorist financing, fraud or other financial crime risk, or where it is unable to satisfy itself as to the legitimacy of a client, a transaction or a source of funds.

7. Sanctions

1. SOAX is committed to complying with all applicable economic and trade sanctions, including those administered by the United Kingdom (OFSI), the European Union, the United Nations and the United States (OFAC).

2. SOAX will not make its Platform or services available to any person, entity or jurisdiction where to do so would breach applicable sanctions. Further detail is set out in the Terms of Use and the KYC/KYB Policy.

8. Obligations of Business Partners

1. SOAX requires all Business Partners, including its clients and suppliers, to comply with this Policy and with all applicable anti-money laundering, counter-terrorist financing, anti-bribery, anti-corruption and sanctions laws.

2. Each Business Partner is responsible for ensuring that its own directors, officers, employees, agents and representatives comply with this Policy and with the laws referred to in Clause 8.1 in connection with any dealings with SOAX.

3. In connection with its relationship with SOAX, each Business Partner must not engage in any conduct that would breach such laws or that would cause SOAX to be in breach of them, and must not use the Platform or services to facilitate any such conduct.

4. SOAX may require a Business Partner to provide such information, declarations, documentation or assurances as SOAX reasonably considers necessary to comply with this Policy and applicable law, and to verify ongoing compliance.

9. Breach and Consequences

1. Compliance with this Policy is a condition of any business or contractual relationship with SOAX.

2. Where SOAX determines, acting reasonably, that a Business Partner is in breach of this Policy or of any applicable financial crime, bribery or sanctions law, or where SOAX reasonably suspects such a breach, SOAX may, without liability and in addition to any other rights or remedies available to it:

1. suspend or restrict the relevant person’s access to the Platform or services, in whole or in part;

2. decline to enter into, or terminate with immediate effect, any contract or business relationship; and/or

3. take any other step that SOAX considers necessary to comply with applicable law or to protect its legitimate interests.

1. Any breach of this Policy by Personnel is treated as a serious matter and is dealt with in accordance with SOAX's internal procedures.

2. No action taken by SOAX under this Section shall constitute a breach of any agreement with SOAX or give rise to any refund, compensation, damages, service credit or other remedy, except to the extent required by mandatory applicable law.

10. Reporting, Disclosure and Cooperation with Authorities

1. SOAX respects the confidentiality of client information and does not disclose it to law enforcement agencies, regulators or other authorities on a voluntary or unrestricted basis. SOAX will report or disclose information relating to a client, a transaction, a relationship or suspected conduct to a court, regulator, law enforcement body or other governmental or competent authority only where, and to the extent that, it is required to do so by applicable law or by a valid and binding legal request, such as a court order, warrant or other lawful and enforceable demand issued by an authority with jurisdiction to compel disclosure. This includes any reporting or disclosure obligations to which SOAX may be subject under applicable anti-money laundering, counter-terrorist financing or sanctions laws.

2. Where SOAX makes, or is considering making, such a report or disclosure, applicable law may prohibit SOAX from notifying the person concerned, or any other party, of the fact that a report or disclosure has been or may be made, of its content, or of the existence of any related investigation or request. In those circumstances SOAX will comply with such legal restrictions and may be unable to provide any explanation for any related suspension, restriction or termination of a relationship.

3. Nothing in this Policy requires SOAX to act, or to refrain from acting, in any manner that would cause it to breach any applicable law.

11. Raising Concerns

1. Business Partners are encouraged to raise any concern about actual or suspected money laundering, terrorist financing, bribery, corruption or other financial crime connected with SOAX as soon as possible.

2. Concerns may be raised by contacting SOAX at support@soax.com. SOAX will treat such reports confidentially so far as reasonably practicable and consistent with applicable law, and will not tolerate retaliation against any person for raising a concern in good faith.

12. Governance and Review

1. Responsibility for this Policy rests with SOAX’s management. SOAX will review this Policy periodically and update it as necessary to reflect changes in its business, the law or applicable best practice.

2. SOAX may amend this Policy from time to time. The version published on the Site is the current version and supersedes any earlier version.

13. Contact

Questions about this Policy may be directed to:

SOAX LTD The Charter Building, Uxbridge, England, UB8 1JG Email: support@soax.com

Effective Date: 1 June 2026