COMPLIANCE POLICY ON PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING (AML/CTF)

Document No: AIZ-AML-001
Version: 1.0
Effective Date: October 1, 2025
Approved by: Board of Directors
Prepared by: Compliance Officer

1. Objective
The purpose of this policy is to prevent money laundering at Aizona Precious Metals Inc. (“the Company”).
and national and international legislative provisions aimed at preventing the financing of terrorism
to ensure that activities are carried out properly, and the principles to be applied within this scope,
The goal is to define responsibilities and control mechanisms.

2. Scope
The policy applies to all business units, employees, board members, business partners, representatives, and
It includes suppliers. All individuals and entities within the scope are subject to the terms of this policy.
They are obliged to follow the rules.

3. Legal Basis
• Law No. 5549 on the Prevention of Money Laundering
• Measures Regulation
• Regulation on the Compliance Program for Obligors
• MASAK Circulars and Guidelines
• FATF Recommendations
• OECD and EU AML/CTF Standards

4. Fundamental Principles
Aizona is fully committed to the following principles:
1. Know Your Customer (KYC)
2. Risk-Based Approach (RBA)
3. Suspicious Transaction Report (STR/SAR)
4. Record Retention (10 years)
5. Appointment of the Integration Officer and Assistant
6. Education and Awareness
7. Internal Audit and Control Mechanism
8. Harmonization in International Transactions

5. Detection of Suspicious Transactions
Examples of suspicious transaction types include: high-value transactions that don't match the customer profile, and transactions with unclear funds.
unexplained transfers, transactions made on behalf of third parties, precious metal trading
Suspicion of unregistered sources. If detected, the Compliance Officer is informed and MASAK STR is notified.
Notifications are made through the system.

6. Education and Awareness
All personnel are familiar with AML/CTF regulations, suspicious transaction indicators, KYC procedures, and MASAK (Financial Crimes Investigation Board).
They are trained on notification obligations. The training sessions are recorded and kept for at least 5 years.

7. Sanctions and Disciplinary Measures
Employees who act contrary to policy will face disciplinary action, including warnings, dismissal, or termination.
Procedures are implemented. Serious violations are reported to MASAK and the relevant authorities.

8. Policy Review
The policy is reviewed by the Compliance Officer at least once a year or in case of legislative changes.
It is reviewed and updated with the approval of the Board of Directors.

9. Entry into force
This policy came into effect with the Board of Directors' decision dated [dd.mm.yyyy] and applies to all
It is binding in the activities.

APPENDICES
APPENDIX-1: KYC / Customer Acceptance Form
APPENDIX-2: Suspicious Transaction Reporting Procedure
APPENDIX-3: Job Description of the Compliance Officer
Appendix 4: Training Participation Registration Form
Appendix 5: Internal Audit Checklist