CUSTOMER ACCEPTANCE POLICY

INTRODUCTION

This Customer Acceptance Policy (“Policy”) outlines the acceptable use of and restrictions on FUNDFLEX Group’s (“FUNDFLEX ” Herein) products and services. The lists in this Policy are not exhaustive and where a customer, business sector, country or transaction type is not covered within this policy it may be generally acceptable, but will be considered on a case-by-case basis. From time to time it may be necessary for us to prohibit a customer depending on the particular circumstances. This policy is applicable to FUNDFLEX , registration number BC1415743. FUNDFLEX ’s registered address is BAARERSTRASSE 79, 6300 ZUG SWITZERLAND

DEFINITIONS

For the purpose of this Policy, the following definitions apply:

High Risk or Banned:

Not permitted or accepted by FUNDFLEX under any circumstances.

Medium Risk:

Permitted or accepted only on a case-by-case basis, at FUNDFLEX ’s sole discretion.

Low Risk:

Generally accepted by FUNDFLEX, except where OTHER specific regulatory circumstances arise.

JURISDICTIONS

Low Risk – Permitted Jurisdictions:

EEA region including the following only:

· Austria

· Belgium,

· Bulgaria,

· Republic of Cyprus

· Czech Republic

· Denmark

· Estonia

· Finland

· France

· Germany

· Greece

· Hungary

· Iceland,

· Ireland

· Italy

· Latvia

· Liechtenstein

· Lithuania

· Luxembourg

· Malta

· Netherlands

· Norway

· Poland

· Portugal

· Romania

· Slovakia

· Slovenia

· Spain

· Sweden

· North America: Canada

· Switzerland

· United Kingdom, subjected to the non-solicitation act.

· Australia, subjected to the non-solicitation.

High-Risk / Banned Jurisdictions:

FUNDFLEX is not able to offer services to customers located in any of the below listed prohibited countries. The prohibition also extends to beneficial owners and/or directors located in any of these countries, unless an exception is granted by the FUNDFLEX MLRO:

· Afghanistan

· Albania

· Armenia

· Azerbaijan

· Barbados

· Belarus

· Botswana

· Burkina Faso

· Burundi

· Cambodia

· Croatia

· Central African Republic

· Ghana

· Guinea

· Guinea-Bissau

· Haiti

· Iran

· Cuba

· Democratic People’s Republic of Congo

· Iraq

· Jamaica

· Japan

· Jordan

· Kazakhstan

· Kyrgyzstan

· Libya

· Mali

· Moldova

· Morocco

· Mozambique

· Myanmar

· Nicaragua

· North Korea

· Pakistan

· Palestine

· Senegal

· Panama

· Philippines

· Russia

· Somalia

· South Sudan

· Sudan

· Syria

· Tajikistan

· United States

· Uzbekistan

· Vanuatu

· Venezuela

· Yemen

· Zimbabwe

Customers located in other jurisdictions not specifically covered in sections above may be considered on a case-by-case basis.

TYPE OF LEGAL ENTITY

There are specific forms of customers that are deemed a higher risk. As a result, some customers may be subject to additional due diligence checks. If there is a limit to the amount of information that is publicly available, or where the risk is deemed to be unacceptable, these customers will be prohibited from conducting business with FUNDFLEX .

Permitted Legal Entities

· Limited Liability Companies (‘LTD’)

· Public Listed Companies (‘PLC’)

Prohibited Legal Entities

Customers cannot be accepted where the legal form of the contracting entity is:

· Holding company for a private individual

· Unregistered charity or foundation

· A company with bearer shares

· Dormant Company

· Shell Companies

Restricted Legal Entities

Customers are restricted where the legal form of the contracting entity is:

· Private/Limited Partnerships

· Registered Charity or Foundation – additional due diligence is required

· Sole proprietor/trader – additional due diligence will be required

· A trust – additional due diligence is required to ensure that the trust’s beneficial owners are appropriately identified and verified, and that the trust is not being used as a vehicle to illegally evade the payment of tax

· Private equity funds/special purpose vehicles/sovereign wealth funds or any other legal entity other than a conventional limited liability company or public limited company – any specialist structures other than a normal trading company/PLC fall outside the Compliance Department’s normal onboarding policies and will need to be scoped before any commercials are agreed. Additional time for onboarding is likely to be required

· Micro Enterprises

· Companies pending incorporation or legal registration – proof of application with the relevant authorities must be provided.

BUSINESS SECTORS RISK LEVELS AND ACCEPTANCE POLICY:

Banned Activity & Business Sectors

THE FOLLOWING BUSINESS SECTORS WILL BE REJECTED FOR ONBOARDING WITHOUT CONSIDERATION:

FUNDFLEX does not provide any type of services to the businesses offering the following activities/services:

BANNED Activities and Business Sectors:

· Drugs, Drug Proprietors, and Druggist’s Sundries

· Petroleum and Petroleum Products Wholesale Distributors and Manufacturers

· Drug Stores and Pharmacies Miscellaneous Stores.

· Package Stores – Beer, Wine, and Liquor Miscellaneous Stores.

· Direct Marketing – Insurance Service

· Mail Order Houses Including Catalog Order Stores, Book/Record Clubs (No longer permitted for U.S. original presentments)

· Direct Marketing – Catalog Merchant

· Direct Marketing – Catalog and Catalog and Retail Merchant

· Direct Marketing- Outbound Telemarketing Merchant

· Direct Marketing – Inbound Teleservices Merchant

· Direct Marketing – Continuity/Subscription Merchant

· Direct Marketing – Not Elsewhere Classified

· Fuel – Fuel Oil, Wood, Coal, Liquefied Petroleum

· Any controlled substance including but not limited to tobacco, alcohol, cannabis, drugs or medication, pharma products of any kind and their associated paraphernalia or its location/place of business. Marijuana dispensaries, transportation, distribution, possession or any activity relating to it including payments or financial dealing of any kind.

· Insurance Sales, Underwriting, and Premiums

· Insurance Premiums, (no longer valid for first presentment work)

· Insurance Not Elsewhere Classified (no longer valid for first presentment work)

· Protective and Security Services – Including Armored Cars and Guard Dogs

· Charitable and Social Service Organizations

· Charitable (non-political) organizations that solicit contributions, social service organizations that provide social welfare services, advocacy groups, community organizations, and health agencies. (TCC of T for fundraising performed through non–face-to-face methods such as phone orders.)

· Civic, Fraternal, and Social Associations Associations engaged in civic, social, or fraternal activities. Such associations include alumni associations and clubs, booster clubs, businesspersons clubs, community membership clubs, fraternal lodges, fraternities and sororities, social clubs, veterans’ organizations, and youth associations. The activities of these groups may include political fund-raising.

· Political OrganizationsMembership organizations that promote the interests of a national, state, or local political party or candidate, including political groups organized specifically to raise funds for a political party or individual candidate.

· Religious Organizations Religious organizations that provide worship services, religious training or study, religious activities, and fund-raising. Examples are churches, convents, monasteries, mosques, shrines, synagogues, and temples.

High-Risk Business Sectors

IN MOST CASES THE FOLLOWING BUSINESS SECTORS WILL BE REJECTED FOR ONBOARDING:

· Airlines

· Car Rental

· Hotels/Motels/Inns/Resorts

· Local/Suburban Commuter Passenger Transportation – Railroads, Ferries, Local Water Transportation.

· Ambulance Services

· Taxicabs and Limousines

· Bus Lines, Including Charters, Tour Buses

· Motor Freight Carriers, Moving and Storage Companies, Trucking – Local/Long Distance, Delivery Services – Loca

· Courier Services – Air or Ground, Freight forwarders

· Public warehousing, Storage

· Cruise and Steamship Lines

· Boat Rentals and Leases

· Marinas, Marine Service, and Supplies

· Airlines, Air Carriers Not Listed Elsewhere

· Airports, Airport Terminals, Flying Fields

· Travel Agencies and Tour Operations

· Package Tour Operators (for use in Germany only)

· Toll and Bridge Fees

· Transportation Services Not Elsewhere Classified

· Telecommunications Equipment including telephone sales

· Fax services, Telecommunication Services

· Computer Network Services

· Telegraph services

· Money Orders – Wire Transfer

· Cable and other pay television (previously Cable Services)

· Electric, Gas, Sanitary and Water Utilities

· Motor vehicle supplies and new parts

· Computers, Computer Peripheral Equipment, Software

· Precious Stones and Metals, Watches and Jewelry

· Diamonds

· All Precious Metals – e.g. gold and silver

· (Must be regulated under local AML regulation. Merchants must provide an AML policy and must be capable of producing CDD/EDD information relating to their customers on request.

· Direct customer Pay-Ins approved only on a case-by-case basis. All Belgian diamond dealers are subject to the following:

· All traders with diamond trading activities (traders dealing in loose diamonds, as well as diamond brokers and polishers) are obliged to register with the Licensing Service of the Federal Public Service Economy

· Duty-Free Store Retail stores.

· Discount Stores Retail stores.

· Department Stores Retail stores.

· Variety Stores Retail stores.

· Miscellaneous General Merchandise Retail stores.

· Grocery Stores, Supermarkets Retail stores.

· Meat Provisioners – Freezer and Locker Retail stores.

· Candy, Nut, and Confectionery Stores Retail stores.

· Dairy Products Stores Retail stores.

· Bakeries Retail stores.

· Miscellaneous Food Stores – Convenience Stores and Specialty Markets Retail stores.

· Car and Truck Dealers (New and Used) Sales, Service, Repairs, Parts, and Leasing

· Automobile and Truck Dealers (Used Only)

· Automobile Supply Stores

· Automotive Tire Stores

· Automotive Parts, Accessories Stores

· Service Stations (with or without ancillary services)

· Automated Fuel Dispensers

· Boat Dealers

· Recreational and Utility Trailers, Camp Dealers

· Motorcycle Dealers

· Motor Home Dealers

· Non-Fungible Tokens (NFTs); Cryptocurrency Mining

· Miscellaneous Auto Dealers

· Miscellaneous Apparel and Accessory Shops Clothing Stores.

· Furniture, Home Furnishings, and Equipment Stores, (Except Appliances) Miscellaneous Stores.

· Computer Software Stores Miscellaneous Stores.

· Caterers Service Providers.

· Eating places and Restaurants Miscellaneous Stores.

· Drinking Places (Alcoholic Beverages), Bars, Taverns, Cocktail lounges, Nightclubs and Discotheques Miscellaneous Stores.

· Fast Food Restaurants Miscellaneous Stores.

· Digital Goods: Media, Books, Movies, Music Miscellaneous Stores.

· Digital Goods: Games Miscellaneous Stores.

· Digital Goods: Applications (Excludes Games) Miscellaneous Stores.

· Digital Goods: Large Digital Goods Merchant Miscellaneous Stores.

· Used Merchandise and Secondhand Stores Miscellaneous Stores.

· Antique Shops Miscellaneous Stores.

· Pawn Shops and Salvage Yards Miscellaneous Stores.

· Wrecking and Salvage Yards Miscellaneous Stores.

· Antique Reproductions Miscellaneous Stores.

· Bicycle Shops – Sales and Service Miscellaneous Stores.

· Watch, Clock, Jewelry, and Silverware Stores

· Hobby, Toy, and Game Shops

· Leather Goods Stores

· Direct Marketing – Travel Related Arrangements Services

· Artist’s Supply and Craft Shops Miscellaneous Stores. (predominantly Retailers).

· Art Dealers and Galleries Miscellaneous Stores. (Retailers).

· Stamp and Coin Stores – Philatelic and Numismatic Supplies

· Religious Goods Stores

· Orthopedic Goods Prosthetic Devices

· Cosmetic Stores

· Pet Shops, Pet Foods, and Supplies Stores

· Miscellaneous and Specialty Retail Stores

· Financial Institutions – Merchandise and Services Such merchandise and services may include checks and other financial products, promotional merchandise, loan fees, and financial counselling service fees. (May be used in the authorization message in some cryptocurrency transactions).

· Non-Financial Institutions – Foreign Currency, Money Orders (not wire transfer) and Travelers Cheques. (Also, Non-Fiat Currency (eg, cryptocurrency), Account Funding (Not Stored Value Load), Debt Repayment). Quasi-Cash Merchant. Identifies the purchase, with a Mastercard or Maestro card, of travellers cheques, foreign currency, or money orders, or the use of a Mastercard card to open or fund a deposit account, at a location other than a Mastercard customer financial institution location. This type of industry may also be used to identify transactions in which a merchant accepts a Mastercard or Maestro card for payment of existing debt, such as a private label card or vehicle loan. In addition, this industry type must be used to identify transactions involving the purchase of CRYPTOCURRENCY.

· Security Brokers/Dealers Merchants that buy, sell, and broker securities, stocks, bonds, commodities, and mutual funds. Forex.

· Real Estate Agents and Managers – Rentals Fees charged by merchants engaged in the rental and management of residential and commercial properties, such as real estate agents, brokers, and managers, and apartment rental services. Such fees may include management fees, real estate rental commissions, and real estate rental payments.

· Timeshares Retailers that sell, lease, and rent timeshare real estate and arrange timeshare condominium exchanges.

· Dating and Escort Services Merchants that provide dating and escort services, including computer and video personal introduction and matchmaking services.

· Tax Preparation Service Merchants that exclusively provide income tax return preparation services without auditing, accounting, or bookkeeping services.

· Miscellaneous Personal Services Not Elsewhere Classified Personal Service Providers (merchants that do not fall under any other industries, eg animal boarding, bathhouses, house sitting services, maid services, animal grooming and kennels, real estate agent, brokers, body piercing and tattooing, and others).

· Consumer Credit Reporting Agencies Business Services.

· Computer Programming, Integrated Systems Design and Data Processing Services

· Computer Maintenance and Repair Services Not Elsewhere Classified

· Management, Consulting, and Public Relations Services

· PPIs; Tax refund services (Must come from an acquirer – no direct customer payments.

· Car Rental Agencies/Companies Not Elsewhere Classified or Not Listed herein

· Truck and Utility Trailer Rentals

· Motor Home and Recreational Vehicle Rentals

· Automobile Parking Lots and Garages

· Automotive Body Repair Shops

· Paint Shops – Automotive

· Automotive Service Shops

· Car Washes

· Motion Pictures and Video Tape Production and Distribution Wholesale producers and distributors of educational and industrial films and videos for exhibition & sale, including TV commercials and training films.

· Motion Picture Theaters Merchants that operate movie theatres, including drive-in theatres. Such merchants sell tickets and refreshments, and may or may not offer advance ticket reservations via the phone.

· DVD / Video Tape Entertainment Rental Stores Industry: Amusement and Entertainment.

· Dance Halls, Studios and Schools Industry: Amusement and Entertainment.

· Theatrical Producers (except Motion Pictures), Ticket Agencies Industry: Amusement and Entertainment.

· Bands, Orchestras, and Miscellaneous Entertainers Not Elsewhere Classified Industry: Amusement and Entertainment.

· Billiard and Pool Establishments Industry: Amusement and Entertainment.

· Contract for Differences (CFDs) Industry: Amusement and Entertainment.

· Commercial Sports, Athletic Fields, Professional Sport Clubs, and Sport Promoters Industry: Amusement and Entertainment.

· Non-profit associations and foundations .

· Adult content, production or activities associated or facilitating adult activities including but not limited to Industry: Amusement and Entertainment.

· Online gaming, gambling betting and Video Amusement Game Supplies Industry: Amusement and Entertainment.

· Video Game Arcades/Establishments Industry: Amusement and Entertainment.

· Betting / Gambling (including Lottery Tickets, Casino Gaming Chips, Off-track Betting and Wagers at Race Tracks) Industry: Amusement and Entertainment. Gambling.

· Amusement Parks, Carnivals, Circuses, Fortune Tellers Industry: Amusement and Entertainment.

· Membership Clubs (Sports, Recreation, Athletic), Country Clubs, and Private Golf Courses Industry: Amusement and Entertainment.

· Aquariums, Sea-aquariums, Dolphinariums Industry: Amusement and Entertainment.

· Recreation Services Not Elsewhere Classified Industry: Amusement and Entertainment.

· Doctors and Physicians Not Elsewhere Classified Industry: Professional Services and Membership Organizations.

· Dentists and Orthodontists Industry: Professional Services and Membership Organizations.

· Claims Institutions Industry: Professional Services and Membership Organizations.

· Chiropractors Industry: Professional Services and Membership Organizations.

· Optometrists and Ophthalmologists Industry: Professional Services and Membership Organizations.

· Opticians, Opticians Goods and Eyeglasses Industry: Professional Services and Membership Organizations.

· MarketPlaces

· Must be selling general marketplace goods

· Must have strong controls around selling prohibited/restricted goods, including the following:

– Intellectual property right violation

– Animals and wildlife

– Stolen property

– Police related items

– Mailing lists and personal information

– Government, transit, and shipping-related items

– Government documents, IDs, and licences

– Hazardous, restricted, or regulated materials

– Human remains and body parts

– Lock picking devices

– Embargoed goods and prohibited countries

– Encouraging illegal activity

– Firearms, weapons, and knives

– Drugs and drug paraphernalia RESTRICTED:

– Adult items

– Alcohol

– Selling art, artifacts, cultural heritage, and grave-related items

– Authographed items

– Credit and debit cards

– Digitally delivered goods

– Gift cards

– Coupons

– Medical drugs, devices, and healthcare

– Personal relationships and services

– Real estate

– Product safety

– Event tickets

– Slot machines

– Stamps

– Currency and coins

– Stocks and other securities

– Travel

– Used cosmetics

· Podiatrists and Chiropodists Industry: Professional Services and Membership Organizations.

· Nursing and Personal Care Facilities Industry: Professional Services and Membership Organizations.

· Hospitals, Doctors, Nurses or any other services involving medical services. Industry: Professional Services and Membership Organizations.

· Medical and Dental Laboratories Industry: Professional Services and Membership Organizations.

· Medical Services and Health Practitioners Not Elsewhere Classified Industry: Professional Services and Membership Organizations.

· Dealing, exchanging, hedging or holdings of precious metals or commodities included but not limited to gold, silver, oil, gas etc. or holding such commodities through a third party or as a part of an investment portfolio.

· Business and Secretarial Schools Business and secretarial schools that offer general business training such as business machine operation, office procedures, word processing, stenographic, and other clerical skills. Such schools offer a training certificate but do not offer.

· Adult/Dating

· Subscription-based dating websites where users may message, chat and/or arrange interactions with other genuine users

· Merchants offering webcams or any other interactive services with models (Must have clear policy and controls about age limits, human trafficking, escorting and prostitution prevention.).

· Schools and Educational Services Not Elsewhere Classified Merchants that offer educational courses and services that are not described by another more specific industry. Such merchants include schools that teach music, drama, art, cooking, modelling, karate schools, automobile driving instruction, traffic safety, flying instruction, and sewing or knitting instruction.

· Child Care Services Merchants that provide child care services, including nannies, nursery schools, and daycare centres. These merchants typically care for infants and preschool children, but may also care for older children, and may or may not provide educational programs.

· Collection Agencies Customers must be well established, reputable and with a history of trading

· Membership Organizations Not Elsewhere Classified Industry: Professional Services and Membership Organizations. Organizations or associations that are not described by another, more specific industry. Examples include historical clubs, labour unions, poetry clubs, art councils, and tenant or condominium associations.

· Testing Laboratories (non-medical) Industry: Professional Services and Membership Organizations. Merchants that provide non-medical testing services to other businesses. Examples of such services include automobile testing, calibration, and certification, food testing, forensic testing, product and pollution testing, and industrial X-ray inspection services.

· Architectural – Engineering and Surveying Services Merchants that provide professional architectural, engineering, and land, water, and aerial surveying services. Included are home and building designers, ship, boat, and machine engineers and designers, and architectural engineers.

· Accounting, Auditing, and Bookkeeping Services Merchants that provide accounting, bookkeeping, billing, payroll and other related auditing services, including Certified Public Accountants (CPAs). Such merchants also may provide income tax preparation services in addition to accounting and auditing services.

· Professional Services Not Elsewhere Defined Merchants engaged in traditional professions that offer highly specialized services, and often require employees to obtain advanced or specialized education or training to provide the services. Examples of such merchants include mortgage brokers, research firms, financial planners, graphic designers, guest speakers and lecturers, court stenographers, real estate appraisers, research firms, and auction houses.

Medium Risk Activities & Business Sectors:

IN MOST CASES THE FOLLOWING BUSINESS SECTORS WILL BE APPROVED OF SUBJECTED TO RESTRICTIONS OR CONDITIONS FOR ONBOARDING:

FUNDFLEX may be able to provide payment services to customers that form part of the verticals outlined below. The provision of these services will be on a case-by-case basis. As such, additional checks may need to be carried out before a decision is made and are subject to MLRO approval:

· Advertising, Marketing and Media Buying Services. Business Services.

· Commercial Photography, Art and Graphics

· Quick Copy, Reproduction and Blueprinting Services

· Cleaning and Maintenance, Janitorial Services

· Employment Agencies, Temporary Help Services

· Equipment Rental and Leasing Services, Tool Rental, Furniture Rental, and Appliance Rental

· Tire Re-treading and Repair Shops Repair Services.

· Electronics Repair Shops

· Furniture, Furniture Repair, and Furniture Refinishing Merchants that reupholster, repair, and refinish furniture, including restorers of antique furniture.

· Pharmaceuticals

· Licensed merchants who sell prescription drugs online – selling of drugs online must come from an acquirer licensed and regulated by the state regulator of a UK/EEA country.

· Elementary and Secondary Schools Industry: Professional Services and Membership Organizations.

· Colleges, Junior Colleges, Universities, and ProfessionalSchools Industry: Professional Services and Membership Organizations.

· Computing/Information Technology; Data Processing; Integrated Systems Design Services

· The following list includes the Business Sectors in general permitted under this Policy:

Any vertical/business sector not covered in any part of this policy needs to be referred to MLRO for approval.

· AISPs/PISPs

◦ Account Information Service Providers and Payment Information Service Providers

· Contract for Differences (CFDs)/FX Brokers:

◦ Brokers licensed and regulated within UK/EEA, Switzerland and Japan only

· Electronic Money Issuers (EMI):

◦ Regulated and adequately licensed EMIs within UK/EEA jurisdictions.

· Entertainment Services

◦ Services within the entertainment sector such as restraurants, bars, and is not included in the High-Risk/Banned list.

◦ Telecom operators including fixed-network services and mobile services regulated within UK/EEA.

· Financial Services

◦ Money Service Business (including currency exchange, money remittance) Payment Institutions (including electronic communication network operators offering payment services, non-bank credit card issuers, merchant acquiring firms)

◦ Must be adequately licensed within UK/EEA jurisdictions

· Gambling and Gaming

◦ Licensed and regulated gambling operators within a reputable jurisdiction (UK/EEA)

◦ Introducer to third party business for commission.

· Payment Service Providers (non-EMI)

*EEA licensed PSPs which are able to hold/control customer funds

· Retail

◦ Sale of merchandise that is not included in the Prohibited/Restricted list.

◦ The above lists are subject to change from time to time.

Low Risk Activities & Business Sectors:

IN MOST CASES THE FOLLOWING BUSINESS SECTORS WILL BE APPROVED FOR ONBOARDING:

All industries and business sectors that are not specifically mentioned as Banned, High or Medium Risk in the previous sections of this policy.

TRANSACTIONS:

Prohibited Transactions By Country

FUNDFLEX provides customers the ability to make and receive cross-border payments, however there are a number of countries that due to regulatory reasons and partner restrictions, FUNDFLEX is unable to facilitate payments to or from: