APPROVED

BY ORDER № 29/09-5 of 9/29/2025

Director of "NATIVE APPS" LLC
O. Heits

AML/KYC-POLICY OF THE ORGANIZER OF ONLINE CASINO GAMBLING

1. LIMITED LIABILITY COMPANY NATIVE APPS, EDRPOU Code 43488489, registered office: Ukraine, 04215, Kyiv, Svitlytskoho street, building 35, office 108/4, which operates under the License for the organization and operation of casino gambling on the Internet (hereinafter - the Organizer), issued by the Commission for Regulation of Gambling and Lotteries on 12/22/2022, according to decision № 434 of 12/13/2022 (hereinafter - the License), by this document approves the policy to detect and prevent any activities related to the legalization (money laundering) of income obtained through criminal means or the terrorism financing during the provision of Services (hereinafter referred to as the AML/KYC Policy).
2. Terms and definitions relating to this AML/KYC Policy, apply in understanding and in compliance with the Rules of the Gambling Organizer Limited Liability Company NATIVE APPS (hereinafter - the Rules).
3. AML/KYC Policy is designed to prevent and reduce all possible risks of the Organizer participating in any illegal activity.
4. AML/KYC Policy is fully focused on the ongoing review of Players' financial transactions to prevent money laundering and combat the financing of terrorism in order to minimize and manage risks, both reputational, legal, and regulatory.
5. In its activity, the Organizer is guided by the applicable Laws of Ukraine, in particular, but not exclusively, by the main legislative and normative acts of Ukraine on issues aimed at combating money laundering, financing of terrorism, and financing the proliferation of weapons of mass destruction, namely:

• Law of Ukraine "On State Regulation of Gambling Activities" № 768-1X of 7/14/2020 (with further amendments and additions);
• Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds of Crime, Financing of Terrorism and Financing Proliferation of Weapons of Mass Destruction" № 361-1X of 12/6/2019 (with further amendments and additions);
• Resolution of the Cabinet of Ministers of Ukraine "On Approval of Licensing Conditions in the Organization and Conduct of Gambling" № 1341 of 12/21/2020 (with further amendments and additions);
• Resolution of the Cabinet of Ministers of Ukraine of 7/22/2020 № 622 "On Approval of the Procedure for Establishing a List of Persons Associated with Terrorist Activities or in Relation to Which International Sanctions are Applied" (with further amendments and additions);
• Resolution of the Cabinet of Ministers of Ukraine dated 8/5/2020 № 677 "On the procedure of formation of the list of states (jurisdictions) which do not fulfill or fulfill improperly the recommendations of international, intergovernmental organizations involved in combating money laundering or financing of terrorism or financing the proliferation of weapons of mass destruction" (with further amendments and additions);
• Regulations on the implementation of financial monitoring by primary financial monitoring entities, the activities of which are regulated and supervised by the Ministry of Finance of Ukraine, as approved by the Order of the Ministry of Finance of Ukraine dated 6/7/2024, No. 282;
• Order of the Ministry of Finance of Ukraine dated December 28, 2022, No. 465, “On the Approval of the Criteria for the Risk of Legalizing (Money Laundering) Funds Obtained through Criminal Means, Financing of Terrorism, and Financing the Weapons of Mass Destruction Proliferation” (with further amendments and additions);
• Other regulatory legal acts.

6. AML/KYC Policy is designed to ensure that financial transactions comply with international anti-money laundering and counter-terrorist financing standards. The Organizer shall carry out a thorough analysis of the relevance and compliance of the identification information of the Players while providing the services, in accordance with the regulations of the Applicable Laws of Ukraine as well as when carrying out due diligence.
7. The Organizer is obliged to share information about Players with banking institutions and law enforcement authorities, and other government authorities, as required by the Applicable Laws of Ukraine and is entitled to do so without the prior consent of the Player. By using the Organizer's SuperGra Portal/Mobile Application, the Player consents to such actions. The Organizer keeps all information about the Player and his betting history and payment transactions for five years after the completion of the last financial transaction..
8. For the purposes of identification/verification and due diligence of the Player, the Organizer may use such methods on the SuperGra Portal/Mobile Application as:
1) Using the BankID NBU system in the following order:
- obtain the identification data of the individual using the BankID NBU system;
- obtain a copy of the identification document (copies of the pages of the identification document containing identification data) from the person, which is signed with the Player’s electronic signature (QES);
- verify the identification data contained in the copy of the identification document, the electronic signature, and the identification data obtained through the BankID NBU system for consistency;
2)  Obtain an electronic copy of the e-passport / e-passport for travel abroad / e-residence permit / e-temporary residence permit, generated by the Diya Portal with the application of the remote qualified electronic signature "Diya.Pidpys" ("Diya ID") of the individual and the qualified electronic seal of the technical administrator of the Diya Portal, with the appropriate qualified electronic timestamp that corresponds to the date of the Organizer's identity verification.
9. Upon the Organizer's request, other additional documents/information related to the Player and necessary to perform identification/verification and due diligence of the Player's identity according to the Applicable Laws of Ukraine, should the Organizer deem it necessary to complete due diligence of the Player for anti-money laundering purposes. The process of establishing the Player's data also requires mandatory confirmation of the Player's phone number and email address.
10. Under the terms of Applicable Laws of Ukraine, the Player cannot be persons who:

• have not provided an identification document containing information on the age of the person, in case they are requested by an employee of the Organizer to provide such a document if they have doubts that the person is at the age of 21 or over;
• have provided false information/data/documents to the Organizer and/or its representative, in particular concerning themselves, including surname, name, patronymic, age, place of residence or stay;
• have limited legal capacity and/or are legally incapacitated;
• are included in the Register of persons whose access to gambling establishments and/or participation in gambling is restricted;
• have ludomania (suffer from a gambling addiction problem);
• are directly the founders (participants, shareholders), managers of the Organizer, in which they;
• are the founders and/or hold managerial positions;
• are representatives of the founders (participants, shareholders), managers of the Organizer, in which they are representatives of the founder and hold managerial positions;
• may have and/or have knowledge of the outcome of the Gambling Game;
• directly and/or indirectly (through the involvement of a third party/third parties) may affect the outcome of the Gambling Game or the amount of the payout of the winnings (prize);
• are the chairman, members, and/or officers of the Authorized Body, except in the case of inspections by control procurement;
• are under the influence of alcohol, drugs, or other intoxicants or are in a state of poisoning/intoxication;
• are citizens and/or nationals of a state which has in any way occupied part of the territory of Ukraine or commits aggression against Ukraine, is acknowledged by the Verkhovna Rada of Ukraine as an aggressor state or an occupant state, except those who have a valid permit for temporary or permanent residence in Ukraine;
• included in the list of persons associated with the implementation of terrorist activities or subject to international sanctions, and the list of persons subject to special economic and restrictive measures (sanctions); 
• Other individuals who cannot be Players in accordance with the Applicable Laws of Ukraine and the Rules.

11. The Organizer checks the Players for presence/absence in the following registers, lists, and databases:

• list of persons subject to special economic and restrictive measures (sanctions); 
• list of persons associated with the implementation of terrorist activities or subject to international sanctions, which is formed in accordance with the procedure established by the Cabinet of Ministers of Ukraine and published on the official website of the State Financial Monitoring Service;
• presence/absence in registers of databases (MIA, SMSU, as well as Security Council of UN, European Union, UK, and USA (OFAC));
• whether or not a person is in the Register of persons whose access to gambling establishments and/or participation in gambling is restricted.

12. Payments to the Player from the Game balance is carried out in accordance with the requirements of the Applicable Laws of Ukraine and the Rules. Payments to third parties are prohibited. Internal funds transfer transactions between Players are also prohibited.
13. The Player undertakes to comply with the legal norms, including international norms against illegal money transfers, financial fraud, legalization (laundering) of criminally obtained funds, terrorism financing, and financing the Weapons of Mass Destruction proliferation and not to engage in unlawful actions.
14. The Organizer undertakes to make every effort to avoid direct or indirect complicity in illegal financial activities and any other illegal transactions using the SuperGra Portal/Mobile Application.
15. The Player guarantees the lawful origin, ownership, and right to use the funds deposited in their Game balance.
16. If evidence of suspicious transactions, replenishment the Game balance from dubious sources (e.g. where the sender and account holder details do not match), and/or any activity with indications of fraud (including refunds or cancellation of payments) is detected in the Game balance, the Organizer reserves the right to carry out an internal investigation, analyze financial transactions, block the access to the Client Account, cancel any payments and suspend transactions in the Game balance (including preventing of placing bets, not making payouts etc.) pending completion of an official investigation or operations analysis. The Organizer shall be guided by the provisions of the legislation in force in Ukraine in order to take the necessary decision.
17. The Organizer has the right to request additional information about the Player if the method of payment differs from the method of deposit into the Game balance. The Organizer also reserves the right to block the access to the Client Account during an investigation or financial transactions analysis,  if the Player refuses to provide additional information at the Organizer's request.
18. During the investigation, the Organizer has the right to request additional copies of the Player's identification documents and copies of the bank statements from cards used to deposit the funds into the Game balance, copies of payment documents, and other documents confirming the lawful possession and legal origin of the funds. The Organizer also has the right to demand original documents.
19. The Organizer undertakes to exercise careful control over players classified as acting at high risk.
20. The Organizer's refusal to conduct financial operations of the Player that the Organizer considers suspicious, refusal to establish (maintain) business relations, including by terminating business relations with the Player (including blocking the Client Account) does not constitute grounds for the Organizer's civil liability for failure to fulfill obligations towards the Player.
21. The Organizer is not obliged to inform Players or other persons about measures taken to prevent and combat legalization (money laundering) of funds obtained through criminal means, as well as the financing of terrorism and the proliferation of weapons of mass destruction, except in the following cases:

• while informing Players about the suspension of providing service;
• when refusing to comply with the Player's request or to open a Client account and when requesting documents from the Player.

22. This AML/KYC Policy forms an integral part of the Public Offer Agreement to Participate in the Gambling Game, and/or the Rules of the Gambling Organizer, and/or the Rules of Online Casino Gambling, and/or the Responsible Gambling Rules (Principles), and/or the Privacy Policy, and/or the Terms and Сonditions of the Promotion Policy of the Organizer of Online Casino Gambling, pursuant to which the Player registers and opens a Client Account on the SuperGra Portal/Mobile Application and uses the Organizer's Services.