Money Laundering and Terrorist Financing Prevention Program

1. Policy Statement

Kaulix Lending Corporation ("the Company") maintains a zero-tolerance policy against money laundering and terrorist financing. The Company shall not be used, directly or indirectly, as a channel for the proceeds of any unlawful activity or for the financing of terrorism. All directors, officers, employees, and agents of the Company are required to comply with this program and all applicable anti-money laundering laws and regulations.

2. Covered Transactions

The following transactions are considered covered transactions and must be reported to the AMLC:

• Single cash transactions involving amounts in excess of Five Hundred Thousand Pesos (PHP 500,000.00) or its equivalent in any other currency.
• Two or more cash transactions within five (5) consecutive banking days totaling more than Five Hundred Thousand Pesos (PHP 500,000.00) or its equivalent, where these transactions appear to be structurally related.
• Any other transaction that is similar or analogous to the foregoing as may be determined by the AMLC.

3. Suspicious Transactions

Suspicious transactions shall be reported to the AMLC regardless of the amount involved. Transactions are considered suspicious when any of the following circumstances exist:

• There is no underlying legal or trade obligation, purpose, or economic justification for the transaction.
• The client is not properly identified or the identification is suspect.
• The amount involved is not commensurate with the business or financial capacity of the client.
• Taking into account all known circumstances, the transaction may be perceived to be structured in order to avoid being the subject of a covered transaction report.
• The transaction deviates from the client's profile or past transactions.
• The transaction is related to an unlawful activity or any offense defined under the AMLA, as amended, or any money laundering offense under any other law.
• Any other transaction that is similar or analogous to the foregoing as may be determined by the AMLC.

4. Customer Due Diligence (CDD)

The Company shall conduct Customer Due Diligence to verify the true identity and assess the risk profile of its clients. CDD measures include:

• Customer Identification — Collecting and verifying the identity of clients using reliable, independent source documents, data, or information (e.g., government-issued IDs).
• Beneficial Ownership — Identifying and verifying the beneficial owner(s) of accounts or transactions, including persons who ultimately own or control the client.
• Purpose and Nature of Relationship — Understanding and obtaining information on the purpose and intended nature of the business relationship.
• Ongoing Monitoring — Conducting ongoing monitoring of transactions to ensure consistency with the Company's knowledge of the client, their business, and risk profile.
• Enhanced Due Diligence (EDD) — Applying enhanced due diligence measures for higher-risk clients, including Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, and those involved in complex or unusual transactions.

5. Know Your Customer (KYC) Requirements

Before establishing a business relationship, the Company shall obtain the following information from individual clients:

• Full legal name and any aliases or name variations.
• Date and place of birth.
• Nationality and citizenship.
• Present and permanent address.
• Contact information (phone number, email address).
• Nature of work, name of employer, or nature of self-employment/business.
• Source of funds and income.
• At least one (1) valid government-issued photo-bearing identification document.
• Tax Identification Number (TIN), if applicable.

6. Record Keeping

The Company shall maintain and safely store all records of transactions and customer identification documents as follows:

• All customer identification documents shall be maintained and safely stored for at least five (5) years from the date the account is closed or the business relationship is terminated.
• Transaction records, including the nature and date of the transaction, the amount involved, and the currency used, shall be maintained and safely stored for at least five (5) years from the date of the transaction.
• Records of Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) shall be maintained and safely stored for at least five (5) years from the date of submission to the AMLC.
• All records shall be sufficient to permit reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal activity.

7. Reporting Obligations

The Company is obligated to file the following reports with the AMLC:

• Covered Transaction Reports (CTRs) — Filed within five (5) working days from the occurrence of the covered transaction.
• Suspicious Transaction Reports (STRs) — Filed within the next working day from the date of determination of suspicious transaction.
• The Company shall not, in any manner, inform the client or any person about the filing of CTRs or STRs, in compliance with the prohibition against tipping off under the AMLA.

Failure to report covered or suspicious transactions is a criminal offense under the AMLA and subjects the responsible officers and employees to penalties.

8. Compliance Officer

The Company shall designate a Compliance Officer who shall be responsible for the effective implementation and enforcement of this MTPP. The Compliance Officer shall have the following functions:

• Oversee the development and implementation of the Company's AML/CTF policies and procedures.
• Ensure the timely filing of CTRs and STRs with the AMLC.
• Coordinate with the AMLC and other relevant authorities on AML/CTF matters.
• Conduct and supervise the Company's AML/CTF training programs.
• Serve as the primary point of contact for all AML/CTF-related inquiries and reports.
• Report directly to the Board of Directors on AML/CTF compliance matters.

9. Employee Training and Awareness

The Company shall implement a comprehensive and ongoing AML/CTF training program covering:

• Identification and reporting of covered and suspicious transactions.
• Customer Due Diligence and KYC procedures.
• Record keeping requirements.
• Red flags and indicators of money laundering and terrorist financing.
• Roles and responsibilities of employees under the AMLA and related regulations.
• Updates on AML/CTF laws, regulations, and typologies.

All employees shall undergo AML/CTF training upon onboarding and on a regular basis thereafter. Training records shall be maintained for audit and regulatory review purposes.

10. Internal Audit and Review

The Company shall conduct regular internal audits to assess the effectiveness of its AML/CTF controls, including:

• Compliance testing of CDD, KYC, and transaction monitoring procedures.
• Review of CTR and STR filing processes to ensure timeliness and accuracy.
• Evaluation of employee training programs and overall AML/CTF awareness.
• Assessment of the Company's exposure to money laundering and terrorist financing risks.
• Identification of deficiencies and implementation of corrective measures.

11. Risk Assessment

The Company shall conduct an institutional risk assessment to identify, assess, and understand its money laundering and terrorist financing risks. The risk assessment shall consider:

• Customer risk — The risk arising from the nature and characteristics of the Company's clients.
• Product/Service risk — The risk arising from the nature of the Company's products, services, and delivery channels.
• Geographic risk — The risk arising from the geographic locations of the Company's operations and clientele.
• Transaction risk — The risk arising from the volume, frequency, and nature of transactions.

The risk assessment shall be updated regularly and shall serve as the basis for implementing risk-based AML/CTF controls.

12. Penalties

Violation of the AMLA and related regulations may result in criminal, civil, and administrative penalties, including but not limited to imprisonment of seven (7) to fourteen (14) years and fines ranging from One Hundred Thousand Pesos (PHP 100,000.00) to Five Hundred Thousand Pesos (PHP 500,000.00) for failure to report covered and suspicious transactions. The Company and its responsible officers may also face sanctions from the SEC and other regulatory bodies.

13. Contact Information

For questions, concerns, or reports related to this MTPP, you may contact us through:

• Company: Kaulix Lending Corporation
• Email: admin@kaulix.com
• Phone: +63 995 427 3478
• Address: Cagayan de Oro City, Misamis Oriental, Philippines

You may also report suspicious activities directly to the Anti-Money Laundering Council (AMLC) through their official channels.