AML Policy

MEASURES AGAINST MONEY LAUNDERING AND TERRORIST FINANCING

1. Home

The Save Ukraine Endowment Fund (hereinafter referred to as the "Endowment Fund") is a legal entity whose main purpose is to collect donations intended to assist the State of Ukraine, citizens of the State of Ukraine andresidents of the territory of the State of Ukraine and to provide them to those in need. The Endowment Fundmainly provides humanitarian aid, but also supports Ukraine's defence. To this end, the Endowment Fundprovides, in particular but not exclusively, food, medicine, hygiene supplies, fuel, clothing and other equipment or funds. At the same time, the Endowment Fund supports projects related to the above purpose.

Since the Endowment Fund collects funds, it may be obliged under Act No. 253/2008 Coll., on Certain Measures against the Legalization of Proceeds from Crime and the Financing of Terrorism (hereinafter referredto as "ZAML") to identify and control the clients from whom it accepts donations or concludes business (collectively, conducts Business) and thereby effectively prevent the legalization of proceeds from crime and thefinancing of terrorism (hereinafter referred to as "money laundering") through the Endowment Fund.

2. Obligation to identify and control

The Endowment Fund is an obliged person under the ZAML only if it accepts a donation in cash, if any, in theamount of EUR 10,000 (or its equivalent in another currency) or more, pursuant to Section 2(2)(c) or (d) of the ZAML.

In the case of receipt of a cash donation in excess of EUR 10,000 (or its equivalent in another currency) in cash, the Endowment Fund is obliged to carry out client identification in accordance with the ZAML. If the cash donation exceeds EUR 15,000 (or its equivalent in another currency), the Endowment Fund will carry out client identification and verification.

3. Method of identification and control

The Endowment Fund is always required to identify the client if it is

suspicious business
a cash transaction where it is clear that the value of the transaction exceeds EUR 10 000

4. Definition of certain terms Identification data

in the case of a natural person: all names and surnames, birth number and, if not assigned, date of birth and sex, place of birth, permanent or other residence and nationality;

in the case of a natural person who is an entrepreneur: all names and surnames, birth number and, if not assigned, date of birth and sex, place of birth, permanent or other residence and nationality, business name, distinctive supplement or other designation, registered office and identification number;

for a legal entity:

the basic identification data of the legal entity, which are the business name or name including a distinctive supplement or other designation, the registered office and the legal entity identification number or similar number assigned abroad,
data to identify and verify the identity of a natural person who is a member of its statutory body,

basic identification data of the legal person who is a member of its statutory body and data to establish and verify the identity of the natural person who is a member of the statutory body of that legal person or who has been authorised by that legal person to represent it in the statutory body.

in the case of a trust fund: the designation and identification details of its trustee, to the extent of the above identification details.

Client or supported person

A natural or legal person with whom the Endowment Fund conducts Business. (e.g. accepting a cash donation, accepting a cash payment, providing cash support). Clients can be supporters, donors, clients and supported persons.

Legalization of proceeds of crime

an act intended to conceal the illicit origin of any economic advantage resulting from a criminal activity in order to give the appearance of a lawfully obtained financial benefit; the act consists, for example, of:

in the conversion or transfer of property knowing that it is the proceeds of crime, for the purpose ofconcealing or disguising its origin or for the purpose of assisting a person who engages in such activity to escape the legal consequences of his or her conduct;
in concealing or disguising the true nature, source, location, movement or disposition of the property or a change in the rights relating to the property, knowing that the property is the proceeds of crime;
in the acquisition, possession, use or disposal of property knowing that it is the proceeds of crime, or;
in a criminal conspiracy of persons or any other form of collaboration for the purpose of the conduct referred to in the above points.

It is irrelevant whether the aforementioned conduct occurred or is to occur in whole or in part in the Czech Republic or abroad.

Financing terrorism

the collection or provision of funds or other property knowing that it will be used, even in part, to commit an offence of terrorism, a terrorist attack, participation in a terrorist group, support and promotion of terrorism or the offence of threatening to commit a terrorist act or an offence intended to enable or facilitate thecommission of such an offence, or to support a person or group of persons preparing to commit such an offence; or
conduct leading to the provision of a reward or compensation to the perpetrator of an offence of terrorism, terrorist attack, participation in a terrorist group, support for and promotion of terrorism, or an offence of threatening to commit an act of terrorism, or an offence intended to enable or facilitate the commission ofsuch an offence, or a person close to the perpetrator, or the raising of funds for such a reward or compensation; or
financing the proliferation of weapons of mass destruction, which means the collection or provision of funds or other property knowing that it will be used, even in part, by a proliferator of weapons of massdestruction or used to support the proliferation of such weapons in violation of the requirements of international law.

It is irrelevant whether the aforementioned conduct occurred or is to occur in whole or in part in the Czech Republic or abroad.

Shop

Any conduct of the Fund acting in the capacity of an obligated person under the ZAML with a client if suchconduct is directed to the disposition of that client's property or to the provision

of service to the client. (e.g. acceptance of a gift in cash, receipt of a payment in cash, provision of support in cash) The Endowment Fund acts in the capacity of an obliged person only in the case of a transaction or gift in cash with a value of EUR 10,000 or more.

Politically exposed person

a natural person who holds or has held in the last 12 months a significant public office of national or regional importance - see Annex 5 for a list of such persons, or a natural person who holds or has held a similar office in another state, in a body of the European Union or in an international organisation,
a natural person who is or has been in the last 12 months a person close to the person referred to in the first point,

During this period, it shall also apply to the same extent to a client who is a legal person whose beneficialowner is a politically exposed person and to a person known to the Endowment Fund to be acting for the benefit of a politically exposed person.

Identity card

an identity card, passport, driving licence, or other document issued by a public administration authority, whichshows the name and surname, date of birth and from which the form is clearly visible, or other information enabling the person presenting the document to be identified as its authorised holder.

In the case of a foreign person, only an identity card, passport or a foreigner's residence permit is acceptable proof of identity.

For the purpose of proving the identity of the client, an identity document that is damaged beyond the usual levelof wear and tear (missing pages, glued, overwritten, illegible), an identity card bearing the owner's likeness, the appearance of which does not correspond to its actual actual form, or is so indistinct or damaged, cannot beaccepted, that it is not possible to identify the person with a sufficient degree of probability, a document from which it is not possible to determine unambiguously which authority issued it, as well as a document which, forother reasons, raises doubts as to its authenticity, and a document which is found in the database of invalid documents - https://application.mvcr.cz/neplatne-doklady. In case of doubt about the authenticity of the ID card, the Endowment Fund is obliged not to carry out the Trade. Following this, the Endowment Fund must assess whether the conditions for reporting a suspicious trade are not met.

The real owner

For the purposes of this Internal Regulation, beneficial owner means:

the beneficial owner according to the Act on the registration of beneficial owners (hereinafter referred to as "ZESM"), i.e.
any natural person who ultimately owns or controls a legal person or legal arrangement
in the case of a corporation, any natural person who, directly or indirectly through another person or legal arrangement:
- has an interest in the corporation or a voting interest of more than 25%,
  - is entitled to a share of the profits, other own resources or the liquidation balance of more than 25%,
  - exercises a controlling influence over a corporation or corporations which individually or collectively hold a greater than 25% interest in the corporation; or
exercises decisive influence in the corporation by other means
- Decisive influence in a corporation is exercised by one who, at his own discretion,whether or not and on the basis of what legal fact, can

directly or indirectly through another person or legal arrangement, bring about that the decision of the highest body of the corporation conforms to his will.

Decisive influence in a business corporation is exercised by the controlling person in accordance with the law governing the legal relations of business corporations.
Decisive influence in a corporation other than a commercial corporation, ahousing or social cooperative or an investment fund in the legal form of a joint-stock company with variable share capital is exercised by any natural person whois a member of its statutory body or a person in a similar position or a personrepresenting a legal person in that body.
is in the top management of the business corporation (the person who ensures the day-to-day management of the company or a direct member of the statutory body) and theconditions pursuant to Section 5(1) of the MESM are met;
in the case of a foundation, institute, charitable company or legal arrangement, any natural person who exercises a decisive influence therein
- Decisive influence in foundations, institutes and public benefit corporations is exercised by those who, at their own discretion, regardless of whether and on the basis of what legal fact, can directly or indirectly through another person or legal arrangement, make the decision of the statutory or other governing body conform to their will.

Decisive influence over the administration of a legal arrangement is exercised by the person who, at his own discretion, regardless of whether and on the basis of what legal fact, can directly or indirectly, through another person or the legal arrangement, make the decisions of the trustee conform to his will.
- in the case of a foundation, any natural person who:
  - is its founder,
    - is a member of its administrative or supervisory board or its auditor or a person in a similar position;
- in whose personal support, according to the foundation's founding legal act, its purpose lies.
in the case of an institute or charitable company, any natural person who is its
- founder,
  - a director or member of its administrative or supervisory board or a person in a similar position,
in the case of a trust fund, any natural person who is
- its founder,
- his trustee,
  - authorised to supervise the administration of the legal arrangement and who may appoint or remove the defendant,
to his victims,
- from the circle in whose interest the trust fund was established or is administered, if he is not a defendant,

Country of origin:

natural person, each State of which that person is a national , and at the same time any other States in which heor she is registered to reside for more than 1 year or to reside permanently, if known to the institution,
of a natural person engaged in business, the State referred to in point 1. and at the same time the State in which he is established

a legal person that is subject to obligations under Section 24a of the ZAML or equivalent obligations under the law of another State, the State in which it has its registered office,
a legal person that is not subject to obligations under section 24a of the ZAML or equivalent obligationsunder the law of another State, the State in which it has its registered office and, at the same time, all States in which it has a branch or place of business
of the trust, the State under the law of which the trust is established and any State of which the trustee orperson in a similar capacity is a national or in which the trustee has his or her registered office, and at thesame time, so far as known to the institution, any other State in which the trustee or person in a similar capacity is registered for more than 1 year or for permanent residence.

5. Obligation to identify clients

The Endowment Fund is always obliged to identify the client if it is

suspicious business,
a transaction where it is clear that the cash value of the transaction exceeds EUR 10 000.

6. Methods of performing client identification

Face-to-face identification (first identification within the meaning of Section 8(1) of the ZAML)

The Endowment Fund identifies clients if the value of a cash transaction is EUR 10,000 or more or if it is a suspicious transaction.

The first identification of a client who is a natural person is made by the Endowment Fund in the client's physical presence.

In the case of a transaction valued at EUR 15,000 or more, the Endowment Fund will inquire about the source (origin) of the funds used in the transaction and, if applicable, the intended purpose of the transaction. This information must then be recorded by the authorised officer of the transaction.

6.2. Identification of the natural person

The identification of the natural person is carried out by recording and verifying the client's identification data(i.e. all names and surnames, birth number and, if none has been assigned, date of birth and sex, place of birth, permanent or other residence and nationality; if a natural person is an entrepreneur, also his/her business name, distinctive supplement or other designation, registered office and identification number) and records the type, number of the identity card, the State or authority issuing it and the period of its validity, while verifying that theperson's appearance matches the image on the identity card.

As part of the identification of the client, the authorised officer shall also ascertain and record whether the client is not a politically exposed person or a person against whom the Czech Republic applies international sanctions under the MLCBI.

If the client is represented by a legal representative or guardian, the identification of the legal representative orguardian is similarly carried out. The legal representative shall provide identification data of the represented person, the guardian shall also provide the relevant court decision.

6.3. Identification of the legal entity

When a Trade of EUR 10,000 or more is made, the Endowment Fund is identified as a legal entity The identification of the legal entity is made as follows. Endowment Fund:

Verifies and records from the document of existence of the legal entity the Identification data of thelegal entity (business name or name including distinctive addition or further designation, registered office, identification number or similar number assigned abroad);

identify the natural persons (e.g. the statutory body or a member thereof) who act on behalf of the legal entity in concluding the given Transaction with the Endowment Fund by recording and verifying from the Identity Card, if any, the Identification Data of the natural person (i.e. full name, birth number and, if notassigned, date of birth and sex, place of birth, permanent or other residence and nationality) and record thetype, number of the Identity Card, the state or authority issuing it, if applicable, and the period of validity of the Identity Card, while verifying that the person's likeness matches the representation on the Identity Card;
for natural persons who are members of the statutory body of the legal entity, but do not act within the scope of the Trade in question, the data to establish and verify their identity are ascertained and recorded. These data are those that can be obtained from available sources, typically the commercial register, i.e. in particular name, surname, date of birth and address. The same procedure is applied to the Beneficial Owners of a legal entity.

If the statutory body, its member or controlling person of the client is another legal entity, it shall be identified in the same way as the client itself.

As part of the client identification, the authorised worker will also determine and record whether:

the client, the natural person acting on behalf of the client in a given Trade and its beneficial owner, if known to the Endowment Fund, is not a politically exposed person or a person against whom the Czech Republic applies international sanctions under the Act on the Implementation of International Sanctions.
another person in the ownership structure or management structure of the client, if known to the Endowment Fund, is not a person against whom the Czech Republic applies international sanctions under the Act on the Implementation of International Sanctions.

Getting a copy of the ID card

When identifying a natural person (a client or a person acting in a given Shop ), whose country of origin is the Czech Republic, the identification data is obtained in priority by taking a copy of the relevant parts of the identity card, from which the identification data can be obtained, as well as the type and number of the identitycard, the state or authority that issued it and the period of its validity. When identifying a natural person (a client or a person acting in a given Trade) whose country of origin is not the Czech Republic, the identification data isobtained in priority by obtaining a copy of the relevant identity card.

In the event that the individual does not give the Endowment Fund consent (even implied consent is sufficient)to make a copy of the identity card, the authorised employee of the Endowment Fund conducting the identification shall make a copy of the identification data to such an extent that the authorised employee, in addition to the identification data of the individual, shall also record information about the identity card, i.e. the type of identity card, the number of the identity card, the state or authority that issued it and the period of itsvalidity. A copy (scan) of the identity card shall be made in written form in such a way as to ensure that therelevant identification data is legible and can be retained for the period laid down in this Internal Regulation andshall contain a copy of the image of the identified natural person in such quality as to enable verification of the conformity of the image.

7. Common provisions on client identification Politically exposed person

As part of the identification process, the employee in charge of concluding and controlling contracts determines whether the client or the natural person acting on behalf of the client in a given Trade is a politically exposed person. This fact is ascertained by the Endowment Fund from the donor's declaration as to whether or not he orshe is a Politically Exposed Person. The donor is advised by the Fund

as to what persons may be considered Politically Exposed Persons and the obligation to notify the Endowment Fund of this fact.

The Endowment Fund does not rely solely on the client's declaration and verifies the information from the client through, for example:

the national list of politically exposed persons (see annex),
self-investigation (e.g. using open sources of information),
Use of a system to screen and locate "at risk" clients based on information from public sources.

If the donor declares himself/herself to be a Politically Exposed Person and the authorized employee verifies this fact, the Endowment Fund will conduct an identification and verification check on the client. Monitoringconsists of checking the frequency and volume of donations, the existence of structuring.

The execution of a transaction with an identified politically exposed person is subject to the approval of the Board of Directors, which will be recorded in the client's card in the information system.

Identification of the client's proxy

If the donor is represented on the basis of an authorisation pursuant to Section 8(4-6) or Section 11(7) of theZAML, the identification of the agent is carried out in the same manner as the identification of the client andfurthermore by presenting an authorisation pursuant to Section 8(4-6) or Section 11(7) of the ZAML issued by the client, which contains the officially certified signatures of the agent and the principal.

Sanctioned entity

As part of the identification process, the Endowment Fund also ascertains whether the client or the natural person acting on behalf of the client in a given Transaction is on the list of sanctioned persons and persons suspected of cooperation and support for terrorism, as well as whether they are on this list and whether they come from a state subject to international sanctions.

If the Endowment Fund suspects that the Client is not acting on his/her own behalf or that he/she is representing that he/she is acting for a third party, the Endowment Fund will ask the Client to provide a power of attorney or reject the Trade.

8. Method of carrying out client checks

The Endowment Fund is obliged to carry out a client check:

before the trade takes place
1. at the latest when it is clear that it will reach a value of EUR 15,000
2. with an identified politically exposed person,
  1. with a person established in a country which, on the basis of a designation by the European Commission or for any other reason, is to be considered a high-risk country (i.e. persons who have a nationality, permanent or temporary residence, registered office, branch or organisational unit in a high-risk country under this Regulation),
prior to the execution of a transaction with the characteristics of a suspicious transaction, irrespective of the threshold of such transaction,

Where a payment is divided into several separate transactions, the value of the transaction or payment is the sum of the transactions if they are related.

The Client shall provide the Endowment Fund with the information necessary for the audit, including the submission of relevant documents. According to the ZAML, the Authorised Officer may make copies or extractsof the documents submitted and process the information thus obtained to fulfil the purpose

of the ZAML. In the event that the Client refuses to provide cooperation, the Endowment Fund shall refuse to carry out the Transaction.

As part of the client audit, the Endowment Fund identifies and evaluates:

information on the source of the funds or other assets involved in the transaction;
whether the customer does not appear on the list of sanctioned persons and persons suspected of cooperation and support for terrorism, as well as whether he/she does not appear on this list, and whetherhe/she does not come from a state against which international sanctions are applied (see Annex 2 of this Internal Regulation);
in the context of Trading with a Politically Exposed Person, also reasonable measures to establish the origin of their assets (the origin can be established through an affidavit, tax return or extract from the Central Register of Notifications).

The Endowment Fund shall ascertain the above information to the extent necessary to assess the potential risk of money laundering and terrorist financing depending on the type of client and the type and scope of the service provided.

The above information is gathered from the information provided by the client at the time of closing whenverifying the transaction and, where applicable, the Endowment Fund's inquiries of the client.

9. Enhanced client identification and control

In enhanced identification and control, the Endowment Fund shall, to the extent necessary to effectively manage the identified risk, go beyond the measures applied in client identification and control:

obtain additional documents or information on the origin of the funds
verifies documents or information obtained from multiple trusted sources,
obtains the consent of a member of its statutory body, Enhanced identification and control will always apply:

prior to the execution of a trade related to a high-risk third country
before doing business with a politically exposed person
when the client or business poses an increased risk of money laundering or terrorist financing.
if the Endowment Fund has information indicating that the client has acted unlawfully in the last 5 years, if this unlawful conduct may have resulted in the laundering of proceeds of crime or the financing of terrorism, or if this unlawful conduct raises concerns about the subsequent laundering of proceeds of crime or the financing of terrorism

10. Suspicious Trade Report

If a Company employee evaluates a client's trade as suspicious, he or she will immediately notify his or hersupervisor, the Compliance Officer and the Company's Board of Directors by email, telephone or in writing.

In his/her report, he/she shall state:

identification details of the company employee reporting the suspicious transaction;
the identification details of the client to whom the notification relates, or the identification details of the person acting on behalf of the client to whom the notification relates;
a description of the subject matter and material circumstances of the customer's transaction; a description of what makes the transaction suspicious; details of the related transactions; a description of the cash or other means of payment used and other circumstances of the cash payment; the timing of the transaction; the account numbers in which the funds in respect of which the notification is made are concentrated; the numbers of any accounts into or out of

which the funds have been or are to be transferred, including the identification of the owners of the disposition, if known to the participant;

the current date.

An internal suspicious trade report containing details of the client and their trades will be sent by the employeewithout delay to a member of the Board of Directors who will confirm receipt of the internal suspicious trade report, e.g. by telephone, e-mail or fax, to enable a comprehensive assessment of whether it is a suspicious trade. A template for the internal report is attached as Annex 3 to these Internal Rules.

If the Company's employee does not assess the client's trade as suspicious in terms of the presence of the features listed in Annex 1 to this Internal Regulation, but for any other reason the employee considers the trade to be risky, he/she shall record this in the register of risky trades kept by the Company and shall immediately inform the Compliance Officer and a member of the Board of Directors of this record and the reasons for it.

In the event that there are obvious facts that a suspicious trade is involved and a company employee fails toreport a suspicious trade, this will be considered a serious violation of the company's internal regulations.

In the event that a member of the Board of Directors, in cooperation with the Compliance Officer, evaluates atrade as suspicious, the member of the Board of Directors shall report the suspicious trade to the FAU withoutundue delay. If the circumstances of the case so require, in particular if there is a risk of default, the Member shall report the suspicious trade immediately after the discovery of the suspicious trade.

A Suspicious Trade Notice shall be submitted in writing using the form on the FAU website1 , by data mail, ororally on the record at a location designated by prior arrangement with FAU. A member of the Board of Directorsshall always verify the receipt of the Suspicious Trade Notice at FAU. The Suspicious Trade Notice shall include a copy of all documents referenced in the Notice and related to the subject matter of the Notice that are in the Company's possession.

A model of the FAU notification is attached as Annex 2 to this Internal Regulation.

11. Archiving obligation

The Endowment Fund shall ascertain and store all information relating to the identification and control of the client, verify the validity and completeness of the data, and update it where necessary.

The following information and documents shall be retained by the Endowment Fund for a period of 10 years from the date of identification and verification:

Client identification and other data obtained in the course of identification;
information and copies of documents submitted for identification and control;
an indication of who made the identification of the client and when; in the case of representation of the client, the original or a certified copy of the authorisation under the ZAML or the number of the court decision appointing the guardian;
information and copies of documents obtained during the client's inspection;
other information and documents related to the Business;
information about the findings made during the review of the Client and during the review of the Trades and correspondence relating to the Trades;
records of all steps taken in the identification and control of the client, including information on any difficulties associated with these steps,
assessing the facts relating to the submission of a suspicious transaction report.

1 https://formulare.financnianalytickyurad.cz/fas/FormService/filler.open?name=FAU-OPO.fo

The 10-year period begins on the first day of the calendar month following the calendar month in which the last transaction within the Trade was made.

The Endowment Fund archives the above data in a manner and to the extent that ensures the transparency of individual Transactions and the procedures associated with them.

The Endowment Fund also archives the approval and decision-making processes and assessments related to thesubmission of a Suspicious Trade Report, as well as information about the findings made during the review ofthe Client and the review of Trades and correspondence related to Trades, to ensure that these processes can be reconstructed.

The Endowment Fund is obliged to provide the requested documents and information at any time upon requestof the FAU or any other authorised control body. The information shall be provided through a member of the statutory body of the Endowment Fund.

12. Duty of confidentiality

The Endowment Fund and its employees are obliged to maintain the confidentiality of the facts that have cometo their attention in connection with the suspicious transaction. This obligation applies both to third parties and to the persons to whom the information relates.

The duty of confidentiality of an employee of the Endowment Fund does not cease upon termination of theiremployment or other contractual relationship with the Endowment Fund or upon their transfer to another job. The disclosure of such information to state authorities and other entities shall not be considered a breach of the duty of confidentiality in cases where the law so provides.

13. Final principles against money laundering

No business objective is a reason for accepting unwanted clients or for overlooking client conduct that is in the nature of suspicious business.

Employees shall not advise or otherwise assist persons who seek to violate or circumvent generally binding regulations for the purpose of laundering the proceeds of crime or financing terrorism.

All personal data collected in the course of the Endowment Fund's activities are processed in accordance with legal regulations and the Personal Data Protection Policy published on the website https://www.saveukraine.cz/.

On behalf of the Endowment Fund Save Ukraine,

Oleksandr Veremeyenko

Chairman of the Board

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