AFREX LEGAL INFORMATION

3. Know Your Customer (KYC) and Customer Due Diligence (CDD)

3.1 Risk-Based KYC and CDD Policy

At AFREX, we have adopted a risk-based approach to KYC and CDD procedures. This approach allows us to apply appropriate due diligence measures to individual and institutional customers to establish a reasonable belief in their true identity. Our policy is obligatory for all users on our platform and is enforced across all Company employees, consultants, officers, owners, and directors.

3.2 Risk-Based Verification Tiers

To ensure the proper level of due diligence for our users, we have established risk-based verification tiers. These tiers are tailored to individual user activities and transaction volumes, helping us effectively evaluate and monitor their profiles.

4. Transaction Monitoring

4.1 Ongoing Monitoring

AFREX is committed to ongoing monitoring of transactions on our platform. We scrutinize these transactions to detect any suspicious or unusual activities. Our monitoring includes tracking the source of funds, the purpose of transactions, and evaluating whether they align with the user’s profile and risk level.

4.2 Suspicious Activity Reports (SARs)

Upon detecting any suspicious transactions, we promptly file Suspicious Activity Reports (SARs) as part of our vigilance. Our Chief Compliance Officer, who oversees this process, reviews and investigates any suspicious activities to determine the necessity of filing a SAR. We retain records and supporting documentation for all filed SARs.

5. Compliance Measures

5.1 Cooperation with Law Enforcement and Regulatory Requirements

AFREX actively collaborates with law enforcement requests and complies with local regulatory requirements across all jurisdictions in which we operate.

5.2 Training and Awareness

We prioritize AML compliance through comprehensive training programs for our employees. These programs ensure they are well-informed about AML regulations, policies, and procedures. Our employees are educated about the importance of AML compliance and their role in enforcing it.

5.3 Reporting and Communication

Maintaining an open line of communication with regulatory authorities and law enforcement agencies is essential for us. AFREX reports any suspicious activities and cooperates with investigations as required.

5.4 Review and Updates

This AML Policy is subject to regular review and updates to keep it in alignment with evolving AML regulations and industry standards. Any updates will be communicated to all relevant stakeholders, ensuring our ongoing commitment to the highest AML standards in the digital asset exchange industry.

Conclusion

AFREX is dedicated to upholding the highest AML standards, thereby safeguarding our digital asset exchange platform and the interests of our users. Our commitment to AML compliance is unwavering, and we aim to foster a secure and thriving environment for digital asset exchange while bridging the gap between the digital economy and traditional financial infrastructure.

1. Introduction

AFREX, a leading gateway to the digital asset exchange world, is committed to protecting your privacy. We understand that you may have concerns about how your personal information is collected, used, and shared, and we take these concerns seriously. Our innovative platform facilitates rapid buying and selling of digital assets, offering unlimited opportunities while bridging the gap between the digital economy and the traditional financial infrastructure. This Privacy Policy outlines our practices regarding the collection, use, and protection of your personal information.

2. Information We Collect

When you interact with our website or use our services, AFREX may collect various types of information, including:

1. Personal Information: This may include your name, street address, email address, date of birth, and other governmental verification numbers.
2. Financial Information: We may collect cryptocurrency wallet addresses, fiat or bank account information.
3. Account Information: Text-enabled cellular/wireless telephone numbers and machine or mobile device IDs.
4. Transaction Data: We collect information about your account transactions, trust relationships, and may collect information about your computer or access device for purposes like fraud prevention.
5. Contact Information: When you communicate with our customer support team or respond to surveys, we may collect your name and email address.
6. Other Information: We may gather geo-location data, IP addresses, browser type, and web log information.

3. Minors

AFREX services are not intended for minors, and we do not knowingly collect personal data from individuals under 13 years of age. If we discover that we have collected such information, we will promptly delete it.

4. Cookies and Tracking Technologies

When you visit our website, we, or third parties we engage, may use technologies such as cookies and pixel tags to track your activities. These technologies help us recognize you as a user, customize content and advertising, measure promotional effectiveness, and enhance the security and trustworthiness of our platform.

5. How We Use Your Personal Information

We do not rent or sell your personal data. AFREX collects personal information to:

1. Provide secure and efficient services.
2. Maintain legal and regulatory compliance.
3. Personalize your user experience.
4. Respond to customer support requests.
5. Process transactions and send transaction-related notices.
6. Resolve disputes and troubleshoot problems.
7. Enforce our User Agreement.
8. Conduct marketing communications.
9. Carry out research and development of our services.

We may also share your personal data with third parties such as IT and SMS service providers, financial institutions, and enforcement or court authorities to comply with Anti-Money Laundering, Terrorist Financing, and Transfer of Funds laws, prevent fraud, and protect our rights, property, safety, and the rights, property, or safety of our employees or others.

6. How We Protect and Store Personal Information.

AFREX employs physical, technical, and administrative safeguards to protect your personal data. We update and test our security technology regularly and restrict access to your personal data to employees who require it for providing services. We also train our employees on the importance of privacy and data security. Despite these measures, we cannot guarantee that personal information will be completely immune to breaches.

7. Sharing Personal Information with Other AFREX Users

In order to facilitate transactions, certain aspects of your personal information may be shared with the individuals or entities engaged in the transaction. This sharing encompasses your contact details, transaction history, as well as verification data.

8. Retention of Your Personal Information

We securely store your personal data for the duration required to accomplish the objectives for which it was gathered. This retention period encompasses potential legal, accounting, or reporting responsibilities. Specifically, for compliance with Anti-Money Laundering regulations, we maintain personal data for five years following the termination of our business relationship. Your information is held and managed in accordance with our obligations and relevant laws.

9. Your Rights

You possess certain rights regarding your personal data, including the ability to access, rectify, or request the deletion of your information. Should you have any apprehensions about the way we handle your data, you maintain the option to file a complaint with the relevant data protection authority. We respect your data privacy rights and are committed to addressing them effectively.

10. Links to Other Sites

Within our website, you may find links directing you to external, third-party sites. Please be aware that AFREX lacks control over these third-party websites, and their privacy policies are beyond our authority. We strongly recommend that you review the privacy statements of these external sites before interacting with them after leaving our platform. Your privacy and data security are important, and we want to ensure that you make informed choices when navigating the web beyond our website.

11. Modifications to Our Privacy Policy

As AFREX continues to develop and enhance our services, we may also revise our Privacy Policy to align with these advancements. We retain the discretion to modify this policy at any time, and such modifications will be effective immediately. While we may not provide advance notice of these changes, the most recent version of the revised policy will always be available on our website for your reference. We encourage you to periodically review our Privacy Policy to stay informed about any updates. Your continued use of our services signifies your acceptance of the latest Privacy Policy in effect.

12. Contact Us

If you have any questions, concerns, complaints, or feedback regarding our Privacy Policy, please do not hesitate to reach out to us at support@afrex.app. Safeguarding your privacy is a fundamental commitment for us, and we are dedicated to promptly addressing your inquiries and upholding your trust.

1. Overview

Our Cookie Policy provides insights into the types of cookies we use at AFREX. Our commitment to transparency means we may update this policy as needed due to operational, legal, or regulatory changes.

2. Types of Cookies

Our website uses first-party cookies (set by us) and third-party cookies (set by servers outside our domain) for various purposes. Here’s a breakdown of these cookies:

Cookies and Comparable Tracking Technologies

We and our partners, in adherence to KE & EU regulations, may utilize various tracking technologies, including cookies and similar tools (referred to collectively as “Tracking Technologies”). These technologies automatically gather additional personal data as you engage with our Services. They assist us in customizing your Service experience and aid in content management by providing insights into the effectiveness of content.

a. Cookies

Cookies, small data files stored by websites on your hard drive, enhance our website and Service usability by enabling recognition of your browser and the capture of specific information. We leverage cookies and comparable technologies for various purposes, including:

• Analyzing web traffic through an analytics package
• Determining if you’ve previously visited our Sites
• Testing content on our Sites
• Storing preferences information
• Recognizing return visits to our Sites
• Tracking advertising attribution statistics

Our Sites might employ a ‘load balancer’ to retain an identifier within your browser, ensuring consistent connectivity to the same web server during your visit, thus facilitating smoother browsing. Similarly, session cookies enable our individual web servers to track your progress throughout your visit. These cookies might be set to remember your user details for future correspondence when you submit data through forms like contact pages or comment boxes.

We might use the following third-party cookies:

• Cloudflare: Maintains stable connections and identifies spammers.
• Google Analytics (including Ad tags): Tracks website traffic and aids in user-targeted ads. This helps us analyze site usage and advertisement performance.
• LinkedIn Ads and Twitter Ads: Facilitate user-targeted ads and monitor advertisement performance.

Should you prefer not to allow AFREX to utilize cookies and similar technologies in your browser, you can decline via our cookie consent banner or adjust your browser settings to refuse some or all cookies. Disabling cookies may impact certain features, although you can still use the Website. For guidance on modifying browser settings, refer to the Help menu in your browser or review instructions provided by browsers like Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile, and Android browser.

If you wish to exercise your rights regarding personal data collected through cookies and similar tracking technologies, please refer to the “What are your legal data privacy rights” section below.

The information generated by cookies may be transmitted to Google and Cloudflare. You can find detailed information about their cookie usage via the following links:

– Google Link
– Cloudflare Link
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b. Analytics

Our Site and third-party technology providers utilize analytics services (e.g., Google Analytics) to assess Site usage, compile reports, gather demographic data, analyze performance metrics, and evaluate other Site and Internet usage-related information. These services use cookies and similar technologies to provide us with this data.

To opt out of Google Analytics tracking, click here.

You can also opt out of targeted advertising using the links below:
‍
– Google
– Twitter
– LinkedIn
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Additionally, you may opt out of some of these services via the Digital Advertising Alliance’s opt-out portal at: https://optoutlink, or by visiting the links below: optoutlink

In addition to cookies, we may use web beacons, small graphics files with unique identifiers. They help us track visits, understand user traffic, and measure email campaign success. Web beacons often rely on cookies to work, so disabling cookies can affect their performance.

3. Managing Your Cookies

You can choose to accept or decline our cookies (except Essential Cookies) through the opt-out links in our Cookie Preference Center, located in the website footer and cookie banner. You can also control cookie settings in your browser. For guidance on managing cookies in common browsers, visit ………………..

Please note that disabling certain cookies may affect your website experience and the services we can provide. By continuing to use our website, you agree to our use of cookies as outlined in this Cookie Policy.

Introduction

AFREX, a leading gateway to the digital asset exchange world, is committed to protecting your privacy. We understand that you may have concerns about how your personal information is collected, used, and shared, and we take these concerns seriously. Our innovative platform facilitates rapid buying and selling of digital assets, offering unlimited opportunities while bridging the gap between the digital economy and the traditional financial infrastructure. This Privacy Policy outlines our practices regarding the collection, use, and protection of your personal information.

1. Virtual Currency Risk Warning

1.1 AFREX is dedicated to providing you with exceptional services. Depending on your location and settlement preferences, your contractual relationship and entity are defined as follows: Trading or holding virtual currencies involves significant risk. All currencies, whether virtual or fiat, may experience considerable fluctuations in value, including the possibility of a complete loss of value. Virtual currencies are still evolving, both technologically and financially, leading to highly volatile prices that fluctuate dramatically in short periods. They are susceptible to pricing bubbles or a loss of confidence, potentially resulting in a rapid decline in demand and a subsequent loss in value. Hence, it’s crucial to recognize and acknowledge that losses, including the risk of losing your entire investment, can occur when engaging in virtual currency trading or holding.

1.2 Engaging in virtual currencies should only occur if you possess a thorough understanding of the transactions you’re undertaking and the extent of the risks involved. It’s vital to carefully assess if the transactions align with your personal circumstances and financial position.

1.3 Virtual currencies pose unique risks compared to established currencies. They operate in a decentralized manner, outside the governance of central governments or regulatory bodies and lack backing by valuable commodities like gold. Relying on a trust-based, partially anonymous peer-to-peer network, these currencies currently lack robust regulatory measures, relying on cryptography for security. This means that trading or holding virtual currencies does not afford the guarantees or protections typical of regulated financial services. Additionally, EU law does not provide direct legal recourse for losses resulting from platform failure, cyber-attacks, business failure, or scams related to virtual currency accounts.

1.4 Afrex Technologies Limited will not provide investment advice or recommendations regarding your trading strategy. You are solely responsible for decisions made on our platform, and we do not make personalized recommendations or provide advice on specific virtual currencies or related transactions. We do not discuss tax implications or disclose account composition or any other obligations regarding virtual currency transactions. Your decisions carry inherent risks for which we are not accountable.

1.5 By transacting with our service, you acknowledge the risks of an internet-based virtual currency service, including operational disruptions, hardware or software failures, malicious software threats, or unauthorized access to your account or wallet. Security breaches or compromises may occur, potentially resulting in the loss of virtual currency funds, which might not be recoverable.

1.6 Trading virtual currencies entails the risk of being unable to trade or convert them to fiat currencies for extended periods due to various reasons, exposing you to potential losses during this time.

1.7 Our involvement in a virtual currency network presents inherent vulnerabilities, including unknown risks and protocol changes, for which we disclaim responsibility.

1.8 Afrex Technologies Limited disclaims responsibility for losses or damages arising from user errors, server failure, data loss, platform irregularities, corrupted files, unauthorized access, or third-party activities, including malware, viruses, phishing, and other website attacks

2. Risk Interpretation

This document elucidates the fundamental terms as per AFREX’s Terms of Use, ensuring that you can decipher this risk advisory with complete clarity.

3. AFREX Services

This advisory serves as an informative guide on the risks associated with the utilization of AFREX services. Each AFREX service carries its distinctive set of risks. This notice offers a broad perspective on these risks, although it does not delve into an exhaustive explanation of how these risks might relate to your particular circumstances. It is paramount that you develop a profound awareness of these risks prior to availing yourself of AFREX services.

4. No Personal Advice

AFREX refrains from offering personal guidance regarding our suite of products and services. While we do provide factual information and elucidate transaction procedures, the ultimate decision to employ our services rests entirely with you. AFREX does not dispense investment advice, financial counsel, trading recommendations, or any form of advisory service. The onus lies solely on you to assess the appropriateness of any investment or transaction based on your specific objectives, financial circumstances, and risk tolerance.

5. No Monitoring

AFREX does not assume the role of your broker, intermediary, agent, or advisor. We bear no fiduciary responsibility or obligation with respect to overseeing your financial choices or activities on our platform. Monitoring the alignment of your use of AFREX services with your financial objectives is your responsibility. It is incumbent upon you to gauge the adequacy of your financial resources for your undertakings on our platform and to assess the level of risk entailed by the products and services you employ.

6. No Tax, Regulatory, or Legal Advice

The tax implications of digital assets remain uncertain, and it is your prerogative to ascertain your tax liability and adherence to tax regulations when making use of AFREX services. You are responsible for the declaration and remittance of any taxes that may arise from your engagement with AFREX services. AFREX does not extend legal or tax counsel regarding these transactions. Seek independent advice in relation to your tax status and obligations when participating in digital asset transactions.

7. Market Risks

Trading digital assets is subject to heightened market risk and price volatility. The value of digital assets may undergo substantial and rapid changes without prior notification. Past performance does not serve as a reliable indicator of future outcomes, and there is no guarantee that you will recover your initial investment.

8. Liquidity Risk

Digital assets may exhibit limited liquidity, rendering it challenging or even impossible for you to vend or divest your positions at your desired juncture. This limitation on liquidity can manifest at any time, including periods marked by swift price fluctuations.

9. Fees & Charges

AFREX determines its fees and charges at its discretion. A comprehensive understanding of the relevant costs and charges is pivotal, as these factors significantly influence the returns you accrue from engaging with AFREX services. It is advised to remain apprised of our fees and charges.

10. Availability Risk

AFREX does not furnish guarantees of service availability at specific intervals, and our services may be susceptible to unforeseen service interruptions or network congestion. The ability to conduct transactions, store digital assets, or partake in platform activities as per your preferences may not be feasible.

11. Legal and Regulatory Restrictions

AFREX operates in accordance with various legal stipulations specific to distinct countries, potentially resulting in limitations on our services in certain jurisdictions or regions. Specific functionalities may be unavailable or subject to restrictions in particular areas. Users are obligated to comprehend and adhere to any limitations enforced in their respective jurisdiction.

12. Third-Party Risk

The provision of AFREX services may involve the participation of third parties, such as payment providers, custodians, and banking partners. Users may be subject to the terms and conditions of these third-party entities, with AFREX not assuming liability for any losses that may arise from such interactions.

13. Security Risk

While AFREX maintains a stringent security protocol, the complete elimination of security risks is unattainable. Users bear the responsibility for safeguarding their account passwords and remain accountable for all transactions, whether authorized or not. Transactions involving digital assets are often irreversible, and losses stemming from unauthorized or fraudulent activities may prove unrecoverable.

14. Risks Associated with Digital Assets

Digital assets are inherently susceptible to various risks, including but not limited to system faults, vulnerabilities, hacks, exploits, errors, protocol failures, and unforeseen contingencies. Transactions related to digital assets are typically irreversible, and technological developments or attacks targeting underlying technologies may lead to substantial financial losses.

15. Monitoring Risks

Digital asset markets operate continuously, 24/7, with rapid price fluctuations a common occurrence, even outside regular business hours.

16. Communication Risks

When communicating with AFREX via electronic means, it is essential to acknowledge that electronic communications may experience failures, delays, security vulnerabilities, or misdelivery. Users should exercise caution regarding potential communication risks.

17. Currency Risks

Fluctuations in currency exchange rates have the potential to impact financial gains and losses for users.

18. Legal Risk

Alterations in laws and regulations may exert a significant influence on the value of digital assets. This risk factor is unpredictable and may vary from one jurisdiction to another. Users are encouraged to stay informed about legal developments and requirements specific to their geographical location.

1. Introduction

AFREX, a pioneering digital asset exchange platform, is committed to ensuring the privacy and data protection of its users. This Data Protection Policy outlines our dedication to safeguarding personal and sensitive data while facilitating digital asset transactions. AFREX operates under various licenses, guaranteeing a secure environment for its users across different jurisdictions. This policy is developed and maintained by Afrex Technologies Limited, in collaboration with a trusted Fintech partner.

2. Scope

This policy applies to all data processing activities conducted by AFREX, including but not limited to data collected from users, employees, partners, and any other data subjects.

3. Data Protection Principles

AFREX adheres to the following principles to ensure data protection:

3.1 Lawfulness, Fairness, and Transparency

We collect and process data only for specified, explicit, and legitimate purposes.
Data subjects are informed about data processing activities.
Data collection is fair and transparent.

3.2 Purpose Limitation

Data is collected for defined purposes and not further processed in ways incompatible with these purposes.

3.3 Data Minimization

We collect only the data necessary for the stated purposes.

3.4 Accuracy

We maintain data accuracy and ensure data is kept up to date.

3.5 Storage Limitation

Data is stored for the minimum time necessary for the purposes.

3.6 Integrity and Confidentiality

Data is processed securely and protected from unauthorized access, disclosure, or alteration.

3.7 Accountability and Transparency

AFREX takes responsibility for data protection and is transparent about its data processing activities.

4. Data Collection

AFREX collects data for the following purposes:

1. User registration and authentication.
2. Transaction processing.
3. Regulatory compliance and reporting.
4. Customer support and communication.
5. Marketing and research (with explicit user consent).

5. Data Security

AFREX implements robust security measures, including encryption, access controls, and regular security assessments, to protect data from unauthorized access and breaches.

6. Data Sharing

AFREX may share data with authorized third parties only for the purposes stated in this policy. Data is shared in compliance with applicable laws and regulations.

7. International Data Transfers

AFREX operates internationally and complies with data transfer regulations by ensuring that data is transferred securely and lawfully.

8. User Rights

AFREX respects the rights of data subjects, including the right to access, rectify, erase, or restrict data processing. Data subjects can exercise their rights through our Data Protection Officer.

9. Data Breach Response

In the event of a data breach, AFREX will promptly notify affected parties and relevant authorities in accordance with legal requirements.

10. Data Protection Officer (DPO)

AFREX appoints a Data Protection Officer responsible for overseeing data protection activities and serving as a point of contact for data subjects.

11. Training and Awareness

AFREX provides ongoing data protection training to employees to ensure awareness and compliance with data protection regulations.

12. Policy Review

This Data Protection Policy is reviewed and updated regularly to reflect changes in our operations, legal requirements, and industry best practices.

13. Contact Information

For inquiries, data subject requests, or to contact our Data Protection Officer, please use the following contact information:

Data Protection Officer
Afrex Support
compliance@afrex.app

Conclusion

AFREX is dedicated to maintaining the highest standards of data protection to ensure the privacy and security of all stakeholders. This policy serves as a commitment to safeguarding personal data in our digital asset exchange environment.

Introduction

AFREX is a prominent digital asset exchange platform dedicated to upholding the highest financial ethics standards in its operations. This Financial Ethics Policy is designed to guide employees, partners, and stakeholders towards conducting financial activities with integrity, transparency, and responsibility, thereby enhancing trust and credibility in the digital asset realm. AFREX operates internationally under various licenses, ensuring compliance with global regulatory standards.

This policy applies across all facets of Afrex Technologies Limited (referred to as the “Company”), considering local regulations when applicable. Our products and services are intended solely for lawful purposes and to prevent any unethical utilization of our offerings.

1. Guidelines for Ethical Conduct and Standards

AFREX is dedicated to providing you with exceptional services. Depending on your location and settlement preferences, your contractual relationship and entity are defined as follows: Guidelines for Ethical Conduct and Standards

All Company actions and choices must meet rigorous ethical standards. This commitment seeks to foster trust in the Company among the general public, customers, and stakeholders. At times, this may necessitate the Company to adhere to higher standards beyond those mandated by laws and regulations.

The Company’s corporate culture is anchored in the following fundamental values:

Compliance with pertinent external and internal regulations (emphasizing transparency and propriety) concerning the exchange of gifts and unacceptable benefits to prevent any allegations of bribery or corruption.

The Company is committed to conducting its business to enhance the reputation and credibility of the Company and the Payments Platform by:

Abstaining from engaging in any unlawful, unfair, deceptive, or unethical practices and avoiding the promotion of the Payments Platform to partners, customers, or organizations that resort to such practices.

Presenting the Payments Platform in an equitable and appropriate manner. Partners and customers must refrain from disparaging the Company and the Payments Platform and making assertions about the characteristics or capabilities of the Payments Platform that do not align with those outlined in this documentation. Additionally, partners and customers should not market the Payments Platform through misleading means.

Every action or decision taken within the Company must withstand scrutiny by others.

2. Virtual Currencies and Blockchain Guidelines

Moreover, Afrex adheres to and aligns with the stringent ethical standards established by the Blockchain and Virtual Currencies Working Group. The code of conduct for these ethical standards encompasses the following principles:

a. Legal Protection for Consumers

All member entities abide by legal requirements, particularly European law provisions governing consumer protection in distance contracts and GDPR regulations, alongside specific regulations relevant to their offered products/services.

b. Contractual Safeguards for Consumers

Member entities will employ necessary measures to safeguard consumers through contracts, ensuring:

• Transparent Terms and Conditions (T&Cs) on their platform or in client contracts.
• Clear information about ICOs for investors.
• Smart contracts with explicit enforcement rules and T&Cs.
• Disclosure of risks associated with cryptocurrencies to investors and traders.
• A duty of care towards clients.
• Clearly defined conditions for accessing services.
• Accurate disclosure of their regulatory/licensing status, where applicable.

c. Clarity in Communication

Member entities commit to clear and unambiguous communication with consumers regarding their products and services.

d. Upholding Industry Reputation

Member entities refrain from actions that could tarnish the reputation of the blockchain and virtual currencies industry. They pledge cooperation with regulators when required.

e. Combatting Financial Crimes

Member entities collaborate with other Working Group members to prevent and combat financial crimes related to virtual currencies. This includes measures against money laundering, terrorist financing, fraud, market manipulation, bribery, corruption, tax evasion, and sanctions evasion.

f. Controlled Cash Transactions

Member entities will accept cash for exchanging Euro or other fiat currencies for virtual currencies only when appropriate AML controls are in place to mitigate financial crime risks.

g. Ensuring Quality Assurance

Member entities prioritize systematic security and quality assurance, aligning with their legal obligations.

h. Information Sharing

Each member company disseminates this Code of Conduct to its employees and provides accessibility to anyone requesting a copy. The Code of Conduct is available online.

Afrex establishes policies, instructions, and routines that complement and clarify the principles of this Ethics Policy. Sanctions will be enforced if partners or customers fail to comply, with the policy’s zero-tolerance approach. Afrex conducts a thorough examination of products and services within defined periods to ensure compliance and ethical standards.

3. Guidelines for Ethical Conduct and Standards

a. Methods and Guidelines

AFREX, a company based in Kenya with partners complying with EU regulations, operates in accordance with ethical principles and does not engage with partners or customers involved in selling products or providing services using intrusive, misleading, abusive, or unethical methods. Here are examples of unacceptable methods and practices:

• Selling, distributing, or handling illegal products or services.
• Offering products that promote criminal activities or provide support to illegal actions.
• Dealing with unlicensed copies or products that infringe upon intellectual property rights.
• Providing sexual or pornographic services, including prostitution, live webcam shows, or selling offensive content lacking serious artistic value, such as non-consensual sexual behavior, sexual exploitation of minors, non-consensual mutilation, or bestiality.
• Dealing with illegal substances like drugs or products primarily used for their production or consumption.
• Creating or promoting content related to hate speech, violence, racism, or discrimination.
• Supplying jailbreaking equipment or software.
• Dealing with hacking and cracking materials.

b. Anti-Bribery and Corruption

At AFREX Technologies Limited (‘AFREX’), our commitment is to operate our business activities lawfully, ethically, and with integrity. We maintain a strict policy against any form of bribery or corruption in our operations and partnerships.

We adhere to the highest compliance standards and ensure full compliance with all anti-bribery and corruption laws and regulations across all jurisdictions where AFREX operates. As a Kenyan company aligned with EU regulations, we are governed by Danish Criminal Code legislation and adhere to broader European Union anti-bribery and corruption guidelines.

AFREX prioritizes integrity and would choose to forgo a business opportunity rather than engage in any activity that could be interpreted as a bribe. We expect all our business associates including contractors, suppliers, agents, and counterparts (“Business Partners”) to share a similar zero-tolerance stance towards bribery and corruption.

This commitment to integrity is endorsed by AFREX’s management team and board. We require our Business Partners to commit to mitigating bribery and corruption risks in Denmark, the EU, and internationally. We strictly prohibit all forms of bribery, including facilitation payments

4. Mitigating Bribery and Corruption Risks at AFREX

AFREX manages bribery risks by implementing a robust control framework and staying vigilant regarding higher-risk activities to pinpoint potential areas of concern. This approach aligns with the European Union’s ‘Adequate Procedures’ framework, encompassing the following key principles:

• Risk Evaluation
• Communication and Training
• Leadership Commitment
• Due Diligence
• Monitoring and Assessment
• Tailored Procedures

We anticipate our Business Partners to embrace a similar approach, irrespective of their location, documenting their risk-based controls accordingly. International Business Partners are encouraged to adopt equivalent frameworks to fortify their governance structures against bribery.

5. Key Risk Areas and Mitigation

1. Third-party Intermediaries (TPIs):

Numerous companies engage agents, finders, or consultants to navigate business environments in specific countries. TPIs pose bribery risks due to their close connections with local officials or governments, often facilitating illicit payments.

2. Foreign Public Officials (FPOs):

FPOs present elevated bribery risks, evidenced by documented instances of bribes within the EU and internationally. AFREX employs controls to minimize exposure to this risk, including strict regulations on gifts or hospitality without senior management approval.

3. Overseas Payments:

Transactions involving overseas payments through financial institutions may lead to funds reaching jurisdictions with weaker financial oversight. While many organizations operate in multiple jurisdictions, extra scrutiny is essential for transactions in high-risk areas.

4. Sponsorships and Donations:

AFREX ensures that charitable contributions align with ethical and legal standards. No donations are made to political entities, and sponsorships or charitable acts are not used as potential bribes. Similar expectations are held for Business Partners.

5. Gifts & Hospitality:

AFREX acknowledges customary business exchanges involving gifts or hospitality. However, any offerings perceived as excessive or inducements for preferential treatment are documented in a register for transparency and regular review.

6. Facilitation Payments

A facilitation payment (or grease payment) is a sum of money typically paid to an FPO or another person to expedite a routine or necessary administrative process. It’s generally a small sum used to speed up a process such as goods through customs. Although a facilitation payment is legal in some jurisdictions, European legislation takes precedence and classifies them as a bribe. Facilitation payments must not be paid on Afrex’s behalf unless refusal to pay creates a health and safety situation.

a. Slavery:

AFREX maintains a zero-tolerance policy towards modern slavery and human trafficking, expecting the same commitment from its staff and suppliers.

b. Training:

Business Partners are encouraged to identify employees who might benefit from AFREX’s anti-bribery training module, fostering awareness and compliance among partner personnel.

c. Reporting and Certification:

AFREX promotes transparency and encourages reporting of improper behavior. Business Partners are encouraged to establish similar reporting mechanisms. Suppliers are required to certify compliance with AFREX’s policy, and non-compliance could lead to contract termination.

For inquiries regarding this policy, contact compliance@afrex.app.

7. Scope

This policy applies to all individuals and entities associated with AFREX, including employees, partners, clients, and all stakeholders involved in our digital asset exchange ecosystem.

8. Financial Ethics Principles

AFREX adheres to the following financial ethics principles:

a. Integrity

We maintain the highest level of honesty, accuracy, and fairness in all financial transactions.

b. Transparency

We provide clear, accurate, and complete financial information to stakeholders, ensuring transparency in our financial reporting and operations.

c. Accountability

We take responsibility for our financial decisions, actions, and their consequences, upholding the highest standards of financial accountability.

d. Compliance

We comply with all applicable financial laws, regulations, and industry standards, ensuring our financial activities are both legal and ethical.

e. Conflicts of Interest

We actively identify and manage conflicts of interest within financial transactions to prevent them from compromising the integrity of our financial decisions and actions.

f. Anti-Fraud Measures

We implement strong anti-fraud measures to protect against financial fraud and unauthorized financial activities.

9. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

AFREX is committed to combating money laundering and the financing of terrorism by implementing rigorous AML and CTF procedures. We conduct thorough due diligence on clients and report suspicious financial activities to regulatory authorities as required by law.

10. Internal Controls and Risk Management

AFREX maintains robust internal controls and risk management procedures to ensure the safety and security of financial assets and transactions.

11. Ethical Investment

AFREX is committed to ethical investment practices, making responsible investment decisions that consider environmental, social, and governance (ESG) factors.

12. Whistleblower Protection

AFREX encourages employees to report any unethical financial behavior or potential financial violations through appropriate channels. Whistleblowers will be protected against retaliation, and their concerns will be handled confidentially and professionally.

13. Training and Education

AFREX provides ongoing financial ethics training and education to all employees and stakeholders to ensure that financial ethics principles are well understood and consistently applied.

14. Enforcement and Disciplinary Action

Violations of this Financial Ethics Policy will result in disciplinary actions, which may include warnings, suspensions, or termination of employment or partnerships, as appropriate.

15. Review and Updates

This Financial Ethics Policy is subject to periodic review and will be updated as needed to remain aligned with evolving industry standards and best practices.

16. Contact Information

For inquiries, concerns, or reporting of financial ethical violations, please use the following contact information:

Compliance / Ethics Officer
Steven Matagaro
compiance@afrex.app

Mailing Address
Sharp Center Wambui Rd. next to Golf View, Muthaiga, 00618, Nairobi, Kenya

Conclusion

AFREX is dedicated to conducting its financial operations with unwavering ethical standards. This policy serves as a commitment to maintaining integrity, transparency, and responsibility in the digital asset exchange world, bridging the gap between the digital economy and traditional financial infrastructure.