AML/KYC Policy

Last updated: 5 November 2021

1. INTRODUCTION
   1. Please read this Anti-Money Laundering and Know Your Customer Policy (hereinafter — the “AML/KYC Policy”) carefully before using the doroex.com website (hereinafter referred as “Doroex”, “website”, “site”, “service”) owned and operated by the company Dorofia d.o.o., Registration number/OIB: 81832580887, with registered address Ulica Ivana Meštrovića 35, Sesvete, Zagreb (hereinafter referred as “Doroex”, “us”, “we” or “our”).
   2. Doroex AML/KYC Policy is designated to prevent and mitigate possible risks of Doroex being involved in any kind of illegal activity.
   3. Both international and local regulations require Doroex to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, a proliferation of weapons of mass destruction, corruption, and bribery and to take action in case of any form of suspicious activity from its Customers.

2. KYC PROGRAM
   1. Doroex has implemented a strict Know Your Customer (hereinafter – “KYC”) program to ensure all kinds of Customers (natural or legal persons, or legal structures) are subject to adequate identification, risk rating and monitoring measures. This program has been implemented throughout all business divisions.
   2. KYC includes not only knowing the Customer and entities Doroex deals with (either as a single transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial Owners (hereinafter – “UBOs”), Legal Representatives and Authorised Signatories as appropriate.
   3. The program includes strict identification requirements, name screening procedures and the ongoing monitoring and regular review of all existing business relationships.
   4. Special safeguards are implemented for business relationships with politically exposed persons (PEPs) and clients from countries or industries deemed high risk.

3. IDENTITY VERIFICATION
   1. One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Doroex establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
   2. Doroex’s identity verification procedure requires the Customer (including prospective Customer) to provide Doroex with reliable, independent source documents, data or information (e.g., corporate documents for corporate customers, national ID, international passport, bank statement, utility bill). For such purposes Doroex reserves the right to collect Customer’s identification information for the AML/KYC Policy purposes.
   3. Customers shall provide any and all information requested by Doroex in order to comply with the AML/KYC Policy.
   4. Doroex will take steps to confirm the authenticity of documents and information provided by the Customers. All legal methods for double-checking identification information will be used and Doroex reserves the right to investigate certain Customers who have been determined to be risky or suspicious.
   5. Doroex reserves the right to verify Customer’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular Customer). In addition, Doroex reserves the right to request up-to-date documents from the Customers, even though they have passed identity verification in the past.
   6. Customer’s identification information will be collected, stored, shared and protected strictly in accordance with the Doroex’s Privacy Policy and related regulations.

4. SANCTIONS AND PEPs
   1. Doroex screens applicants against recognised Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists:
      • during the establishment of a business relationship (onboarding stage) when the prospective Customer is submitting the application;
      • on each anti-fraud and AML alerts;
      • regularly by automatic re-check of all Customers;
      • in other cases when Doroex deems it is necessary.

5. TRANSACTION MONITORING
   1. KYC Policy not only requires verifying Doroex’s Customers identity (who they are) but it also requires analysing their transactional patterns (what they do). Therefore, Doroex relies on data analysis as a risk-assessment and suspicion detection tools.
   2. Doroex performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
      • Daily check of Customers against recognized PEP and Sanctions lists (e.g., PEP, UN, EU, OFAC etc.), aggregating transfers data by multiple data points, placing Customers on watch and/or service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
      • Case and document management.
   3. In accordance with the AML/KYC Policy Doroex will monitor all transactions and it reserves the right to:
      • ensure that transactions of suspicious nature are reported to the proper law enforcement agency;
      • request the Customer to provide any additional information and documents;
      • suspend or terminate Customer’s account when Doroex has reasonably suspicion that such Customer engaged in illegal activity.

The above list is not exhaustive and Doroex will monitor Customers’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

6. RISK ASSESSMENT
   1. Doroex, in line with the anti-money laundering and counter terrorist financing requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Doroex is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
   2. Doroex has implemented an ongoing Risk Analysis to assess the level of risk exposure considering Doroex customers, products, services, entities and geographic locations risk and to derive appropriate security measures from this analysis. AML safeguards are derived from the results of the Risk Analysis.

7. PROHIBITED BUSINESS RELATIONSHIPS
   1. Doroex must refuse to open an account/enter into a relationship or has to close an existing account/terminate a relationship, if Doroex cannot form a reasonable belief that it knows the true identity of the Customer and/or ultimate beneficial owners and/or the nature of business or formal requirements concerning the identification of the Customer and/or ultimate beneficial owner are not met.
      In particular, Doroex will not:
      • accept funds/payments that are known or suspected to be the proceeds of criminal activity,
      • enter into/maintain business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists;
      • open and/or maintain anonymous accounts, accounts for shell banks or pay-through accounts;
      • enter into relationships with clients from non-serviced countries or
      • enter into relationships with clients operating in prohibited industries.
   2. It is strictly forbidden to utilise Doroex services in connection to the sale or supply of the following prohibited industries: tobacco products, prescription drugs, drugs and drug paraphernalia, weapons (including without limitation, knives, guns, firearms or ammunition), satellite and cable TV descramblers, material which incites violence, hatred, racism or which is considered obscene, government IDs and licences including replicas and novelty items and any counterfeit products, unlicensed foreign currency exchange intermediary services (such as forex dealers, Binary options), auctions and related services provider, unlicensed or illegal lotteries or gambling services (including without limitation the use of or participation in illegal gambling houses), unregistered charity services, items which encourage or facilitate illegal activities, multi-level marketing, pyramid selling or Ponzi schemes, matrix programmes or other “get rich quick” schemes or high yield investment programmes, goods or services that infringe the intellectual property rights of a third party, un-coded/miscoded gaming, timeshares or property reservation payments, escort services organisation / activities and / or distribution of erotic / pornographic videos and pictures and other related services, cash collection services, detective services provider, debt recovery services. We reserve the right, in our sole discretion, to add categories of prohibited industries. The above list is not exhaustive. Doroex reserves the right, in its sole discretion, to add or change categories of prohibited industries.
   3. At present, Doroex does not provide service to the following countries. This list is subject to change:
      • Afghanistan
      • American Samoa
      • Bahamas
      • Bosnia & Herzegovina
      • Botswana
      • Burundi
      • Cambodia
      • Central African Republic
      • Democratic Republic of the Congo
      • Cuba
      • Egypt
      • Ethiopia
      • Ghana
      • Guam
      • Guinea
      • Guinea-Bissau
      • Guyana
      • Haiti
      • Iran
      • Iraq
      • Laos (Lao PDR)
      • Lebanon
      • Libya
      • Maldives
      • Mali
      • Moldova
      • Montenegro
      • Myanmar (Burma)
      • Nicaragua
      • Nigeria
      • North Korea
      • Pakistan
      • Panama
      • Puerto Rico
      • Russia (Crimea and Sevastopol (Crimea))
      • Samoa
      • Saudi Arabia
      • Serbia
      • Somalia
      • South Sudan
      • Sri Lanka
      • Sudan (and Darfur)
      • Syria
      • Tunisia
      • Trinidad and Tobago
      • Uganda
      • Ukraine Crimea and Sevastopol (Crimea)
      • United States
      • US Virgin Islands
      • Vanuatu
      • Venezuela
      • Yemen
      • Zimbabwe

8. RECORD RETENTION
   1. All data obtained according to Customer identification and AML security measures must be documented.
   2. Records must be kept for a minimum of 5 years, notwithstanding potentially longer retention periods under local civil or commercial law.

9. CONTACT DETAILSIf you have any question in connection to this AML/KYC Policy, please feel free to contact us at info@doroex.com.