AXN SPORTS LTD

1. Policy Statement and Purpose

AXN Sports Ltd (the Company) takes a zero-tolerance approach to money laundering and terrorist financing. The purpose of this policy is to:

• Set out the responsibilities of AXN Sports Ltd and its staff in ensuring compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations.
• Provide guidance on recognizing and reporting suspicious activities.
• Establish a risk-based approach to due diligence and compliance.

2. Application of this Policy

This policy applies to all employees, directors, contractors, and business partners of AXN Sports Ltd. Non-compliance may result in disciplinary action, including termination of employment.

3. Governance and Responsibilities

• Money Laundering Reporting Officer (MLRO): A designated MLRO is responsible for implementing this policy, ensuring compliance, and reporting suspicious activities.
• Board and Senior Management: Oversee AML/CTF measures and ensure they are integrated into business processes.
• Employees: Must comply with this policy, complete training, and report any suspicious activities.

4. Risk Assessment

AXN Sports Ltd will conduct risk assessments to identify vulnerabilities and implement appropriate controls. This includes evaluating customers, transactions, and business relationships for potential AML/CTF risks.

5. Customer Due Diligence (CDD)

A risk-based approach to CDD will be applied:

• Standard CDD: Identification and verification of customers before establishing a business relationship.
• Enhanced CDD: Additional scrutiny for high-risk customers, such as Politically Exposed Persons (PEPs) or transactions involving high-risk jurisdictions.
• Ongoing Monitoring: Regularly reviewing customer transactions to detect unusual activity.

6. Suspicious Activity Reporting (SAR)

Employees must report any suspicious transactions or behaviors to the MLRO. The MLRO will assess and, if necessary, submit a Suspicious Activity Report (SAR) to the appropriate authorities.

7. Record Keeping

Records will be maintained for at least five years, including:

• Customer identification documents.
• Transaction records.
• Internal and external reports related to AML/CTF compliance.

8. Staff Training and Awareness

All employees will receive regular training on AML/CTF obligations and the latest regulatory updates.

9. Compliance Monitoring and Review

The MLRO will conduct periodic reviews to ensure policy effectiveness and compliance. Updates will be made as necessary to reflect regulatory changes.

10. Non-Compliance and Consequences

Failure to comply with this policy may lead to disciplinary action, including termination of employment, and legal penalties.

11. Approval and Implementation

This policy has been approved by the company Director and is effective as of 01/02/2025. It will be reviewed annually or as required by regulatory changes.