Anti-Money Laundering and Sanctions Policy

1.1 Purpose

This Anti-Money Laundering and Sanctions Policy explains Tool-O's commitment to supporting lawful financial activity and reducing the risk that the Platform may be used for money laundering, terrorism financing, sanctions evasion, fraud or other financial crime.

The purpose of this Policy is to establish principles and procedures that assist Tool-O in maintaining a secure, trustworthy and legally compliant marketplace.

1.2 Objectives

This Policy seeks to:

• support compliance with applicable anti-money laundering and sanctions

laws;

• reduce financial crime risks;

• protect Users and the Platform from unlawful activity;

• promote transparent and legitimate transactions;

• support fraud prevention and detection;

• facilitate cooperation with competent authorities where required by

law;

• maintain the integrity of Platform payment systems.

1.3 Scope

This Policy applies to activities connected with:

• User Accounts;

• identity verification;

• Bookings;

• payments;

• refunds;

• security deposits;

• payouts;

• financial investigations;

• customer due diligence;

• fraud prevention;

• other financial activities conducted through the Platform.

1.4 Guiding Principles

Tool-O seeks to manage financial crime risks in accordance with the following principles:

• legality;

• transparency;

• accountability;

• proportionality;

• risk-based decision making;

• security;

• cooperation with lawful authorities.

1.5 Relationship with Other Policies

This Policy should be read together with the:

• Terms of Use;

• Privacy Policy;

• Platform Integrity Policy;

• Security Policy;

• Trust & Safety Policy;

• all other Platform policies.

1.6 Updates

Tool-O may amend this Anti-Money Laundering and Sanctions Policy from time to time.

The most current version published on the Platform replaces all previous versions.

2.1 General Commitment

Tool-O seeks to take reasonable steps to reduce the risk that the Platform may be used for money laundering, terrorism financing, sanctions evasion, fraud or other unlawful financial activity.

2.2 Risk-Based Approach

Tool-O may apply risk-based measures appropriate to the nature of the Platform, including consideration of:

• transaction patterns;

• Account activity;

• payment behaviour;

• geographic risk;

• fraud indicators;

• other relevant operational factors.

2.3 Identity Verification

Where reasonably appropriate or required by law, Tool-O may request information or documentation to verify the identity of Users before permitting certain Platform activities.

Failure to provide requested information may result in restrictions on Platform access or services.

2.4 Transaction Monitoring

Tool-O may monitor Platform transactions to identify unusual or potentially suspicious activity, including:

• irregular payment patterns;

• repeated failed transactions;

• unusual Booking activity;

• suspected fraud;

• attempted circumvention of Platform processes;

• other indicators of financial crime.

2.5 Sanctions Compliance

Users must not use the Platform in a manner that breaches applicable sanctions laws or trade restrictions.

Tool-O may restrict, suspend or terminate Accounts where it reasonably believes that continued access may result in non-compliance with applicable sanctions requirements.

2.6 Prohibited Financial Activity

Users must not use the Platform to:

• launder money;

• finance terrorism;

• evade sanctions;

• conceal criminal proceeds;

• engage in fraud;

• process unauthorised payments;

• facilitate unlawful financial activity.

2.7 Record Keeping

Tool-O may retain financial and transaction records for periods reasonably necessary to:

• comply with applicable laws;

• investigate fraud;

• support regulatory obligations;

• resolve disputes;

• protect the Platform.

2.8 Cooperation with Authorities

Where required or permitted by applicable law, Tool-O may cooperate with law enforcement agencies, regulators or other competent authorities in relation to suspected financial crime.

2.9 Suspicious Activity

Where Tool-O reasonably identifies potentially suspicious activity, it may:

• request additional information;

• delay or restrict transactions where permitted by law;

• suspend Accounts;

• investigate the matter;

• report the activity where legally required or authorised.

2.10 Ongoing Review

Tool-O may periodically review its anti-money laundering, sanctions and financial crime controls to improve their effectiveness, reflect changes in applicable laws and respond to emerging risks.

3.1 Compliance Program

Tool-O may maintain internal policies, procedures and controls designed to support compliance with applicable anti-money laundering, counter-terrorism financing and sanctions laws.

3.2 Risk Assessments

Tool-O may periodically assess financial crime risks associated with:

• User activities;

• payment methods;

• transaction patterns;

• geographic exposure;

• third-party service providers;

• emerging financial crime trends.

3.3 Customer Due Diligence

Where reasonably appropriate or required by law, Tool-O may undertake customer due diligence measures, including requesting information reasonably necessary to verify a User's identity or assess financial crime risk.

3.4 Enhanced Due Diligence

Where Tool-O reasonably considers that higher financial crime risks may exist, additional verification or information may be requested before certain Platform services are made available.

3.5 Internal Reviews

Tool-O may periodically review financial crime controls, monitoring systems and compliance procedures to identify opportunities for improvement and strengthen risk management.

3.6 Reporting Obligations

Where required by applicable law, Tool-O may report suspicious activities, transactions or other relevant information to competent authorities.

Nothing in this Policy requires Tool-O to notify a User that such a report has been made where doing so would be unlawful.

3.7 Training and Awareness

Tool-O may provide internal guidance or training to personnel responsible for supporting compliance with anti-money laundering, sanctions and financial crime obligations.

3.8 Third-Party Providers

Where payment processing, identity verification or other financial services are provided by third-party providers, Tool-O may rely upon those providers' compliance programs and controls where appropriate and consistent with applicable contractual arrangements.

3.9 Continuous Improvement

Tool-O may periodically update its financial crime controls to reflect:

• legislative changes;

• regulatory guidance;

• technological developments;

• emerging threats;

• operational experience;

• industry best practice.

3.10 Responsible Marketplace

Tool-O is committed to maintaining a marketplace that supports lawful transactions, protects Users from financial crime risks and promotes trust in the Platform through responsible financial governance.

4.1 Governance

Tool-O is responsible for administering this Anti-Money Laundering and Sanctions Policy and may maintain internal governance processes designed to support compliance with applicable financial crime laws and the effective management of financial crime risks.

4.2 Compliance

Tool-O seeks to comply with applicable anti-money laundering, counter-terrorism financing, sanctions, financial crime and related legal obligations.

Nothing in this Policy excludes, restricts or modifies any legal rights or obligations that cannot lawfully be excluded.

4.3 Policy Review

Tool-O may periodically review this Policy to reflect:

• legislative changes;

• regulatory guidance;

• emerging financial crime risks;

• technological developments;

• operational experience;

• evolving industry practices.

4.4 Monitoring and Audit

Tool-O may periodically review and assess the effectiveness of its anti-money laundering, sanctions and financial crime controls to identify opportunities for improvement and strengthen compliance.

4.5 Cooperation

Where required or permitted by applicable law, Tool-O may cooperate with:

• regulators;

• law enforcement agencies;

• financial institutions;

• payment providers;

• government authorities;

• other competent organisations.

4.6 Relationship with Other Policies

This Anti-Money Laundering and Sanctions Policy should be read together with the:

• Terms of Use;

• Privacy Policy;

• Security Policy;

• Platform Integrity Policy;

• Trust & Safety Policy;

• Fraud Prevention Policy (if applicable);

• all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.7 Contact

Questions regarding this Policy or concerns relating to financial crime or sanctions compliance may be directed to Tool-O using the contact details published on the Platform.

4.8 Policy Updates

Tool-O may amend this Anti-Money Laundering and Sanctions Policy from time to time.

The latest version published on the Platform replaces all previous versions.

4.9 Commitment

Tool-O is committed to maintaining a marketplace that supports lawful transactions, protects Users from financial crime risks and promotes compliance with applicable anti-money laundering and sanctions obligations.

4.10 Final Statement

Financial crime undermines trust in online marketplaces.

Tool-O encourages all Users to conduct transactions honestly, comply with applicable laws and cooperate with reasonable measures designed to protect the Platform from money laundering, sanctions violations, fraud and other unlawful financial activities.

END OF ANTI-MONEY LAUNDERING AND SANCTIONS POLICY