Anti-Money Laundering Policy

Introduction

ComponentSource’s business is low risk in relation to money laundering, however in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we have created this anti-money laundering policy which supplements any anti-money laundering training given to employees.

Scope of the Policy

The broad definition of money laundering means that potentially anyone can commit a money laundering offence, including all employees of the Company, all temporary staff and contractors.

Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the low risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.

What is Money Laundering?

1. Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the jurisdiction; entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person; and acquiring, using or possessing criminal property.
2. There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the CFO acting as the Group Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the applicable crime agencies; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.
3. Any employee could potentially be caught by the money laundering provisions, if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. This Policy sets out how any concerns should be raised.

Money Laundering Reporting Officer (MLRO)

1. ComponentSource's CFO will act as MLRO to receive disclosures about money laundering activity and be responsible for anti-money laundering activity within the Company.
2. The MLRO will ensure that appropriate training and awareness is provided to new and existing employees and that this is reviewed and updated as required.
3. The MLRO will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.

Suspicions of Money Laundering

1. All employees must as soon as is practicable report any knowledge of or suspicion of (or where there are reasonable grounds to suspect) suspicious activity to the MLRO in the prescribed form as set out in this policy document.
2. Once the matter has been reported to the MLRO, the employee must follow the directions given to him/her and must NOT make any further enquiry into the matter.
3. The employee must NOT voice any suspicions to the person(s) whom they suspect of money laundering, as this may result in the commission of the offence of “tipping off”. They must NOT discuss the matter with others or note on the file that a report has been made to the MLRO in case this results in the suspect becoming aware of the situation.

Consideration of the Disclosure by the MLRO

1. Once the MLRO has received the report, it must be evaluated in a timely manner in order to determine whether:
   • There is actual or suspected money laundering taking place; or
   • There are reasonable grounds to know or suspect that this is the case; and
   • Whether the MLRO needs to lodge a Suspicious Activity Report (SAR) with one or more national crime agencies.
2. If there is no evidence of money laundering then consent will be given for any on-going or imminent transaction(s) to proceed.
3. Where consent is required from a crime agency for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the crime agency has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the crime agency.
4. All disclosure reports referred to the MLRO and reports made to a crime agency will be retained by the MLRO in a confidential file kept for that purpose, for a minimum of 5 years.
5. The MLRO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.

Customer Identification and Due Diligence

Due diligence is performed on all customers who must provide basic information including full name, address, company registration details.

Enhanced Due Diligence

It may be necessary for the Company to carry out enhanced due diligence where the customer or a transaction involving the customer appears to be “high risk”. This means that there is a higher level of identification and verification of the customer’s identity required. The following non-exhaustive list of situations may indicate a “high risk”:

• a new customer;
• a customer not well known to ComponentSource;
• customers in known high risk industries and/or jurisdictions;
• transactions that are unusual or appear to be unusual for that customer;
• highly complex transaction or payment arrangements;
• the transaction involves a politically exposed person (“PEP”) or an immediate family member or a close associate of a PEP;
• no face to face meetings take place with the customer where this is usually expected.

Customer-dealing employees must assess the money laundering risk for each customer and if you suspect enhanced due diligence is required, you should speak to the MLRO before continuing any engagement with the customer. The MLRO will be required to approve the continuance of the business relationship.

If enhanced due diligence is carried out, the MLRO must:

• obtain additional information on the customer and on the customer’s beneficial owner(s);
• obtain additional information on the intended nature of the business relationship;
• obtain information on the source of funds and source of wealth of the customer and customer’s beneficial owner(s); and
• conduct enhanced monitoring of the business relationship.

This may include but is not limited to the following:

• checking the organisation website to confirm the identity of personnel, its business address and any other details;
• attending the customer at their business address;
• obtaining additional information or evidence to establish the identity of the customer and its beneficial owner(s), including checking publicly available beneficial ownership registers of legal entities such as the registers available at Companies House in the UK and the global Legal Entity Identifier (LEI);
• in the case of a PEP, seek the approval of senior management and establish the source of wealth and source of funds;
• ensure that the first payment is made from a bank account in the customer’s name.

If satisfactory evidence of identity is not obtained at the outset then the business relationship or one-off transaction(s) cannot proceed any further. A report should be filed with the MLRO who will then consider if a report needs to be submitted to one or more crime agencies.

Ongoing Monitoring

Employees should review customers at regular intervals to ensure that the risk level of each customer information and information held on each customer is not only accurate and up to date but is consistent with the knowledge of the customer and its business. Further due diligence may be required if new people become involved at a customer. Any suspicious activity must be reported to the MLRO.

Data Protection

Customer details must be collected in accordance with the relevant data protection legislation. This data can be “processed” to prevent money laundering and terrorist financing.

Record Keeping

Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 5 years from the end of any business relationship with that customer.

CSAMLP 10/2025