AML & SANCTIONS POLICY

Anti Money Laundering, Criminal Activity, Tax Evasion and Sanctions Policy

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Trillium Group Limited is aware of the risk of third parties exploiting us to engage in money laundering or financing of entities under sanction.

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1. We do not assist, support, participate in or permit money laundering or terrorist financing or entities under sanction.

2. We do not accept money or other assets if we know or suspect that they derive from any kind of criminal activity. We do not knowingly deal with criminals, suspected criminals, or the proceeds of crime.

3. We do not facilitate the acquisition, ownership or control of criminal proceeds or other assets deriving from criminal activity nor do we assist others in concealing criminal proceeds or assets.

4. We do not tolerate tax evasion of any kind and we do not knowingly or wilfully facilitate tax evasion. We implement procedures to prevent the facilitation of tax evasion by our people and others acting on our behalf.

5. We do not facilitate the acquisition, ownership or control or financing or proceeds or any business activity associated with nations, companies and individuals that are under sanction imposed by the USA, Europe, UK, and other nations.

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To manage our money laundering risk/sanctions exposure and ensure compliance, Trillium Group Limited implements several controls and processes. These include:

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1. Conducting know your counterparty (KYC) and due diligence procedures to determine the background and identity of our counterparties; and

2. Implementing controls in respect of payments we make and receive using a risk-based approach to ensure that they are consistent with the requirements of this policy; and

3. We require employees/associates to be alert to any unusual or suspicious arrangements which could expose us to the risk of money laundering or the facilitation of tax evasion or the breaking of sanctions rules, and to report such arrangements to Compliance; and

4. We require employees/associates to undergo annual training to fully understand procedures & due dilligence responsibilities to prevent the risk of money laundering or the facilitation of tax evasion or the breaking of sanctions rules,

5. Reporting to appropriate authorities of any infringement or suspicious activity connected with any of the above.

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This policy applies to all employees, directors, and officers, as well as contractors/associates under Trillium Group Limited’s direct supervision, working for a Trillium Group Limited office or asset directly or indirectly controlled or operated by Trillium Group Limited.

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We actively assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with the intent of this policy and we will take action as per the policy above if any JV is discovered to be facilitiating any of the above.