Anti-fraud policy

1. POLICY STATEMENT

1.1. BIT2ME creates opportunities for people and generates trust among them worldwide. BIT2ME is committed to conducting business in accordance with the highest ethical, professional, and legal standards. The public, partners, and users of BIT2ME have the right to expect that BIT2ME hires professional, competent, and reliable individuals.

1.2. BIT2ME will comply with applicable legislation. In accordance with applicable legislation, BIT2ME has a "zero tolerance" policy towards fraud, corruption, collusion, money laundering, terrorist financing, and other criminal conduct (collectively "Prohibited Conduct") and will thoroughly investigate and seek to take disciplinary and/or legal action against those who perpetrate, are involved in, or assist with fraudulent actions or other inappropriate actions in all BIT2ME activities and related transactions.

1.3. BIT2ME will provide adequate and appropriate resources to implement the Anti-fraud Policy and will ensure that it is communicated and understood.

2. LEGAL COMPLIANCE

2.1. The Anti-fraud Policy has been drafted to comply with current local and international legislation, including, among others, applicable EU legislation.

2.2. Adherence to BIT2ME's Anti-fraud Policy will ensure compliance with all relevant laws and internal policies.

3. DEFINITIONS

In compliance with the Anti-fraud Policy, prohibited conduct includes fraud, corruption, collusion, money laundering, terrorist financing, and other criminal behaviors defined as follows:

3.1. Fraud: any act or omission, including a misrepresentation that knowingly or recklessly deceives, or attempts to deceive, a party to obtain a financial or other benefit or to avoid an obligation.

3.2. Corruption: offering, giving, receiving, or soliciting, directly or indirectly, anything of value to improperly influence the action of another party.

3.3. Collusion: an agreement between two or more parties designed to achieve an improper purpose, including the improper influence of the actions of another party.

3.4. Money laundering:

The conversion or transfer of property, knowing that such property is derived from a criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of their action.
The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from a criminal activity or from an act of participation in such activity.
The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from a criminal activity or from an act of participation in such activity.
Participation, association to commit, attempts to commit, and aiding, abetting, facilitating, and advising on the commission of any of the actions mentioned in the previous points.

3.5. Terrorist financing: the provision or collection of funds, by any means, directly or indirectly, with the intention that they are used or in the knowledge that they will be used, in whole or in part, to carry out any of the offenses within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/JHA of 13 June 2002 on combating terrorism.

3.6. Criminal behavior: behavior that constitutes a crime anywhere in the world or that would constitute a crime anywhere in the world if it occurred there.

4. KEY RESPONSIBILITIES

4.1. BIT2ME conducts due diligence of "Know Your Customer" (KYC) policy on all new users and due diligence on all transactions to detect potential compliance or integrity issues. Such due diligence is carried out in accordance with the requirements of anti-money laundering and terrorist financing regulations, in accordance with the terms of KYC.

4.2. In view of the anti-fraud policy, BIT2ME is responsible for:

Ensuring that there are efficient and effective internal systems, procedures, and controls to allow the prevention and detection of Prohibited Conduct.
Ensuring that the Anti-fraud Commissioner identifies the risks of prohibited conduct in their business areas and that all internal systems, procedures, and controls are implemented and applied appropriately.
Ensuring that all members of the operational anti-fraud department have the obligation to report any suspicion or internal and external incident of prohibited conduct.
Continuous review of its internal systems, procedures, and controls through risk management processes and audit arrangements.
Reporting any suspicion of prohibited conduct to the relevant state authorities.

5. FRAUD DETECTION AND INVESTIGATION

5.1. The BIT2ME Operational Anti-Fraud Department, in particular, the Anti-fraud Commissioner, is the first line of detection, investigation, and protection to prevent Prohibited Conduct through the User and Transaction Assessment Process. The Anti-fraud Commissioner will be responsible for the proper compliance with the Anti-fraud Policy.

Authority
The Anti-fraud Commissioner, through the Operational Anti-fraud Department, working closely with the Nominated Officer (cf. Know Your Customer Policy), will be responsible for:
- Receiving reports of alleged prohibited conduct related to BIT2ME, its users, and/or related transactions.
- Investigating such matters and cooperating directly with the Nominated Officer to facilitate investigations.
- Reporting their findings to BIT2ME management and relevant authorities, as well as any other third party as necessary.
For situations requiring an urgent response, the Anti-fraud Commissioner may take the necessary measures for the investigation, especially to preserve evidence.
Independence
The Operational Anti-Fraud Department will enjoy full independence in the exercise of its responsibilities. The Anti-fraud Commissioner will have full authority to open, pursue, close, and report on any investigation into Prohibited Conduct within their competence without prior notice, consent, or interference from any other person or entity.
Professional Standards
All investigations of prohibited conduct carried out by the Operational Department for Fraud Combat will be fair and impartial, with due respect for the rights of Users and the persons or entities involved. The presumption of innocence applies to those who are allegedly guilty of misconduct. Those involved in the investigation of Prohibited Conduct (whether they are being investigated or conducting the investigation) must be aware of their rights and obligations and ensure that they are fully respected.
Cooperation
All users must cooperate with the Operational Department against fraud and the Anti-fraud Commissioner promptly, completely, efficiently, and in the manner specified by the Operational Department against fraud, including answering relevant questions and complying with requests for information and records.
Confidentiality
In accordance with BIT2ME's internal rules on access to information, all information and documents collected and generated during an investigation of Prohibited Conduct, which are not yet public domain, will be kept strictly confidential. The confidentiality of the information collected will be respected both in the interest of those concerned and in the integrity of the investigation.
In particular, confidentiality will be respected during the investigation of prohibited conduct to the extent that it is not contrary to the interests of the investigation.
The Operational Department for Fraud Combat will disclose such information and documents only to those persons or entities authorized to receive them or otherwise as necessary.

6. MISCELLANEOUS

6.1. BIT2ME will review the Anti-fraud policy to reflect new legal and regulatory developments and ensure good practice.

6.2. I GUARANTEE THAT I HAVE NO INTENTION OF COMMITTING ANY ACT OF PROHIBITED CONDUCT DESCRIBED HERE; FURTHERMORE, I CONSENT TO ANY CHECKS DUE TO THE INVESTIGATION UNDER THE ANTI-FRAUD POLICY AND AGREE TO COOPERATE FULLY AND IMMEDIATELY WITH THE ANTI-FRAUD COMMISSIONER WITHIN SUCH INVESTIGATION.