AML/CFT Policy

This is the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy and Procedures adopted by Northgaze Limited as required by the Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA) and the Terrorism (Prevention and Prohibition) Act, 2022 (TPPA).

Northgaze will actively prevent and take measures to guard against being used as a medium for money laundering and terrorism financing. To these ends:

• Identities of all new and potential clients will be verified to a reasonable level of certainty.
• A risk-based approach will be taken to monitoring potential clients' affairs.
• Any suspicious activity will be reported and recorded.
• The Legal Officer acts as the Money Laundering Reporting Officer (AML/CFT Compliance Officer).

Money Laundering: Engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds. This occurs in three stages: Placement, Layering, and Integration.

Terrorist Financing: An attempt to conceal either the origin of funds or their intended use for criminal purposes. Legitimate sources can be used to fund terrorist operations.

The Company has designated an AML/CFT Compliance Officer with full responsibility for the program. Responsibilities include:

• Monitoring potential client identity verification.
• Reporting suspicious transactions to the National Financial Intelligence Unit (NFIU).
• Overseeing employee training on implementation and compliance.
• Maintaining required AML records.

Northgaze has established a KYC policy to verify identities using recognized online verification agencies (e.g., CRC Credit Bureau).

Enhanced Due Diligence (EDD) is performed for high-risk customers, including PEPs, cross-border transactions, and non-resident customers.

Northgaze takes a risk-based approach. We actively decline high-risk clients identified by:

• Complex unusually large or one-off transactions.
• Ownership structures designed to conceal beneficiaries.
• Jurisdictions with high levels of corruption or crime.
• Unusual patterns with no apparent economic purpose.

Suspicious Transaction Reports (STRs) will be made to the NFIU as soon as knowledge or suspicion arises.

We report funds suspected to be derived from criminal activities including corruption, fraud, tax crimes, terrorism financing, and racketeering.

Record-Keeping: Identity checks are maintained for 5 years after termination of relationship. STR records are also kept for 5 years from filing.

Training: All affected employees are provided with training regarding MLPPA and TPPA, and how to identify suspicious transactions.