AML Policy

1. Introduction and Purpose

CODEGENIX LTD. ("Vertex," "we," "our," or "us"), Company Number: 16808123, is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering Policy ("AML Policy") outlines our procedures and controls to ensure compliance with applicable laws and regulations.

This policy applies to all users of the Vertex platform, including buyers, specialists, and any third parties involved in transactions on our platform.

2. Our Approach

Our programme follows the anti-money-laundering, counter-terrorist-financing and sanctions laws that apply to us and to the people who use our platform, together with internationally recognised standards for preventing financial crime.

It is risk-based: the checks we apply are proportionate to the risk a customer, a transaction or a country presents, and we review the programme whenever the rules or our risks change.

3. Know Your Customer (KYC) Procedures

We apply appropriate customer due diligence measures in accordance with applicable laws and regulations. The extent and nature of verification depends on the risk assessment of each customer relationship and transaction type.

Partners (specialists) are verified before they can take paid work: after their application is approved they give their full legal name, date of birth, country of residence and ID type and number, and upload a passport or national ID and a proof of address. A person on our team checks these documents. What we collect and why is listed in our Privacy Policy.

4. Transaction Monitoring

4.1 Ongoing Monitoring

We continuously monitor transactions for suspicious activity, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with expected user behavior
• Rapid movement of funds
• Transactions with high-risk jurisdictions
• Multiple accounts or identity concerns

4.2 How Payments Are Reviewed

Every card payment attempt is reported to our team as it happens, so that unusual patterns can be spotted and looked into by a person. We do not use an automated fraud-scoring system.

5. Risk-Based Approach

5.1 Risk Assessment

We apply a risk-based approach to customer due diligence, considering:

• Customer type and business relationship
• Geographic risk factors
• Transaction type and value
• Delivery channel and payment method

5.2 Enhanced Due Diligence

For higher-risk customers or transactions, we apply enhanced due diligence measures, including additional documentation requirements, senior management approval, and ongoing enhanced monitoring.

6. Suspicious Activity Reporting

6.1 Internal Reporting

All employees and contractors are trained to identify and report suspicious activity.

6.2 External Reporting

Where the law requires it, we report suspicious activity to the competent authorities, and we cooperate with lawful requests from them.

7. Sanctions Compliance

We do not accept new sign-ups from Russia, Belarus, Iran, North Korea, Syria or Cuba.

We enforce this by refusing sign-ups from an IP address located in one of these countries or with an email address on a Russian, Belarusian, Iranian, North Korean, Syrian or Cuban domain (or a Russian or Belarusian free-mail provider), and by refusing payments with a billing address in one of these countries.

We do not screen individual users or transactions against sanctions lists of named persons or entities. If we learn that an account belongs to a sanctioned person, we will close it.

8. Record Keeping

We keep customer identification records, transaction records, internal reports and training records for as long as the law requires, and no longer. The periods that apply to your personal data are set out in our Privacy Policy (section 6, Data Retention).

9. Staff Training

All relevant staff receive AML training that covers:

• Legal obligations and consequences of non-compliance
• Recognition of suspicious activity
• Internal reporting procedures
• Customer due diligence requirements

Training is provided upon hiring and refreshed annually, with additional training for role changes or regulatory updates.

10. User Obligations

By using Vertex, you agree to:

• Provide accurate and truthful information during registration and verification
• Promptly update any changes to your personal information
• Not use the platform for money laundering or any illegal purpose
• Cooperate with any verification or investigation requests
• Not circumvent or attempt to circumvent our AML controls

Failure to comply may result in account suspension, termination, and reporting to relevant authorities.

11. Account Restrictions

We reserve the right to:

• Request additional verification at any time
• Delay, block, or refuse transactions that appear suspicious
• Suspend or terminate accounts that fail verification or pose compliance risks
• Report suspicious activity to authorities without prior notice to the user

12. Policy Updates

This AML Policy is reviewed and updated at least annually or when there are significant regulatory changes. Users will be notified of material changes via email or platform notification.