Anti-Money Laundering (AML) Policy

This Anti-Money Laundering (AML) Policy sets out TauKen Group Ltd.'s commitment to preventing money laundering, terrorist financing, and financial crime across all jurisdictions in which it operates. The policy establishes the principles, procedures, and responsibilities required to detect, report, and mitigate illicit financial activity, in accordance with the laws of the Republic of Kazakhstan and the United Kingdom.

TauKen Group Ltd. complies with the following legislation:

Under Kazakhstan Law:

• Law of the Republic of Kazakhstan "On Combating the Legalisation (Laundering) of Proceeds from Crime and the Financing of Terrorism" (2009)
• Criminal Code of the Republic of Kazakhstan (2014)
• Tax Code and Financial Monitoring Agency regulations

Under UK Law:

• Proceeds of Crime Act 2002 (POCA)
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• Terrorism Act 2000
• Sanctions and Anti-Money Laundering Act 2018

Where legal obligations differ, TauKen Group Ltd. will apply the stricter standard.

This policy applies to:

• All employees, directors, and officers of TauKen Group Ltd. and its subsidiaries.
• Contractors, consultants, and third-party agents acting on behalf of the Group.
• All business units engaged in financial transactions, procurement, investment, or client onboarding.

Money Laundering: The process of concealing the origins of illegally obtained money by transferring it through legitimate businesses or financial systems.

Terrorist Financing: The provision or collection of funds intended to support terrorist activities.

Suspicious Activity: Any transaction or behaviour that raises concerns about legality, legitimacy, or ethical compliance.

5.1 Risk-Based Approach

TauKen Group Ltd. adopts a risk-based approach to AML compliance, identifying and assessing risks associated with clients, transactions, jurisdictions, and delivery channels.

5.2 Customer Due Diligence (CDD)

All clients, suppliers, and partners must undergo CDD prior to engagement. This includes:

• Verification of identity and legal status
• Assessment of beneficial ownership
• Screening against sanctions lists and politically exposed persons (PEPs)

Enhanced Due Diligence (EDD) is applied to high-risk entities, cross-border transactions, and complex corporate structures.

5.3 Record-Keeping

All AML-related records, including CDD documentation, transaction logs, and internal reports, must be retained for a minimum of:

• 5 years under Kazakhstan law
• 6 years under UK law

Records must be stored securely and made available to authorised regulators upon request.

5.4 Monitoring and Reporting

TauKen Group Ltd. monitors financial activity for suspicious patterns, including:

• Unusual payment structures
• Cash-intensive transactions
• Rapid movement of funds across borders

Suspicious Activity Reports (SARs) must be submitted to:

• The Financial Monitoring Agency of Kazakhstan
• The UK's National Crime Agency (NCA), via the Suspicious Activity Reporting system

Employees must report concerns immediately to the Group Compliance Officer.

6.1 Board of Directors

The Board is responsible for approving AML policies, overseeing compliance, and ensuring adequate resources are allocated to AML functions.

6.2 Group Compliance Officer

The Compliance Officer is responsible for:

• Implementing AML procedures
• Conducting internal audits and risk assessments
• Liaising with regulators and law enforcement
• Maintaining training records and reporting logs

6.3 Employees

All employees must:

• Complete annual AML training
• Understand red flags and reporting obligations
• Cooperate with internal investigations and audits

TauKen Group Ltd. provides mandatory AML training to all employees, covering:

• Legal obligations under Kazakhstan and UK law
• Identification of suspicious activity
• Reporting procedures and whistleblower protections

Training is refreshed annually and tailored to role-specific risks.

TauKen Group Ltd. complies with international sanctions regimes, including:

• United Nations Security Council sanctions
• UK Office of Financial Sanctions Implementation (OFSI)
• Kazakhstan's national sanctions lists

No business shall be conducted with sanctioned individuals, entities, or jurisdictions. All counterparties are screened prior to engagement.

Employees who report suspected money laundering or financial crime are protected under:

• Article 6 of Kazakhstan's AML Law
• The UK Public Interest Disclosure Act 1998

TauKen Group Ltd. prohibits retaliation and ensures confidentiality throughout the reporting process.

Failure to comply with this policy may result in:

• Disciplinary action, including termination
• Civil or criminal liability under applicable law
• Contract termination for third-party breaches

All breaches are investigated by the Compliance Officer and reported to the Board and relevant authorities.

This policy is reviewed annually by the ESG & Compliance Committee and updated to reflect changes in law, regulation, and operational risk. Amendments are approved by the Board of Directors and communicated to all stakeholders.