Anti-fraud policy

1. POLICY STATEMENT

1.1. PAYNEX creates opportunities for people and builds trust between them around the world. PAYNEX is committed to conducting business in accordance with the highest ethical, professional and legal standards. The public, partners and users of PAYNEX have the right to expect that PAYNEX will hire professional, competent and reliable employees.

1.2. PAYNEX will comply with applicable laws. In accordance with applicable laws, PAYNEX has a zero-tolerance policy towards fraud, corruption, collusion, money laundering, terrorist financing and other criminal activities (collectively referred to as ‘Prohibited Activities’) and will conduct thorough investigations and take disciplinary and/or legal action. measures against individuals who commit, participate in, or facilitate fraudulent or other illegal activities in all PAYNEX activities and related transactions.

1.3. PAYNEX shall provide appropriate and adequate resources for the implementation of the Anti-Fraud Policy and shall ensure that it is communicated and understood.

2. COMPLIANCE WITH LEGISLATION

2.1. The anti-fraud policy has been developed in accordance with applicable local and international legislation, including, but not limited to, applicable EU legislation.

2.2. Adherence to PAYNEX’s Anti-Fraud Policy will ensure compliance with all relevant laws and internal policies.

3. DEFINITIONS

In accordance with the Anti-Fraud Policy, prohibited conduct includes fraud, corruption, collusion, money laundering, terrorist financing, and other criminal activities, defined as follows:

3.1. Fraud: any act or omission, including misrepresentation, which knowingly or recklessly deceives or attempts to deceive another party for financial or other gain or to evade liability.

3.2. Corruption: directly or indirectly offering, giving, receiving, or requesting anything of value with the intent to improperly influence the actions of another party.

3.3. Collusion: an agreement between two or more parties aimed at achieving an unlawful objective, including unlawfully influencing the actions of another party.

3.4. Money laundering:

Converting or transferring property, knowing that such property has been obtained through criminal activity or participation in such activity, with the aim of concealing or disguising the illegal origin of the property or assisting any person involved in such activity to evade the legal consequences of their actions.
Concealing or disguising the true nature, source, location, disposition, movement, rights in relation to, or possession of property, knowing that such property is derived from criminal activity or participation in such activity.
Acquiring, possessing, or using property, knowing at the time of receipt that such property was obtained through criminal activity or participation in such activity.
Participation, conspiracy to commit, attempts to commit, and aiding, abetting, counselling, or assisting in the commission of any of the acts mentioned in the preceding paragraphs.

3.5. Financing of terrorism: the provision or collection of funds by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, to commit any of the offences within the meaning of Articles 1 to 4 of Council Framework Decision 2002/475/ JAI of 13 June 2002 on combating terrorism.

3.6. Criminal conduct: conduct that is a crime anywhere in the world or that would be a crime anywhere in the world if it had occurred there.

4. MAIN RESPONSIBILITIES

4.1. PAYNEX conducts appropriate Know Your Customer (KYC) checks on all new users and appropriate checks on all transactions to identify potential compliance or integrity issues. Such due diligence is conducted in accordance with anti-money laundering and counter-terrorist financing regulations under the terms of KYC.

4.2. In accordance with its anti-fraud policy, PAYNEX is responsible for:

Ensuring that effective and efficient systems, procedures and internal controls are in place to prevent and detect prohibited activities.
Ensuring that the Anti-Fraud Commissioner identifies risks of prohibited conduct in his areas of activity and that all systems, procedures and internal controls are properly implemented and applied.
Ensuring that all members of the operational fraud prevention team are required to report any suspicions or incidents of prohibited behaviour, both internal and external.
Continuous review of its systems, procedures and internal control mechanisms through risk management processes and audits.
Report any suspicions of prohibited conduct to the relevant government authorities.

5. FRAUD DETECTION AND INVESTIGATION

5.1. The PAYNEX Anti-Fraud Department, specifically the Anti-Fraud Commissioner, is the first line of detection, investigation, and defence to prevent prohibited behaviour through the user and transaction assessment process. The Anti-Fraud Commissioner will be responsible for ensuring proper compliance with the Anti-Fraud Policy.

Powers

The Anti-Fraud Commissioner, through the Anti-Fraud Department, working in close cooperation with the authorised officer (see the Know Your Customer Policy), is responsible for:
Receiving reports of suspected prohibited activities involving BIT2ME, its users and/or related transactions.
Investigating such cases and cooperating directly with the designated officer to assist in investigations.
Reporting their findings to PAYNEX management and the relevant authorities, as well as any other third parties, if necessary.

In situations requiring immediate action, the Anti-Fraud Commissioner may take the necessary measures to investigate, in particular to preserve evidence.
Independence

The Anti-Fraud Operations Department will have complete independence in the performance of its duties. The Anti-Fraud Commissioner shall have full authority to open, conduct, close and report on any investigation into prohibited conduct within his or her competence, without prior notification, consent or interference from any other person or organisation.
Professional standards

All investigations of prohibited conduct conducted by the Fraud Prevention Operations Department will be fair and impartial, with due respect for the rights of Users and the individuals or organisations involved. The presumption of innocence applies to those who are alleged to have committed wrongful acts. Individuals involved in an investigation of prohibited conduct (whether they are the subject of the investigation or conducting the investigation) should be aware of their rights and responsibilities and ensure that they are fully respected.
Cooperation

All users must cooperate with the Fraud Operations Department and the Fraud Commissioner promptly, fully, effectively, and in the manner prescribed by the Fraud Operations Department, including responding to relevant questions and complying with requests for information and records.
Privacy

In accordance with PAYNEX’s internal rules on access to information, all information and documents collected and generated during the investigation of prohibited conduct that has not yet been made public will be kept strictly confidential. The confidentiality of the information collected will be maintained in the interests of both the parties concerned and the integrity of the investigation.

In particular, during the investigation of prohibited conduct, confidentiality will be maintained to the extent that it does not conflict with the interests of the investigation.

The Anti-Fraud Operations Department will disclose such information and documents only to persons or organisations authorised to receive them, or in other cases where this is necessary.

6. OTHER

6.1. PAYNEX will review its Anti-Fraud Policy to reflect new changes in legislation and regulations and to ensure best practice.

6.2. I GUARANTEE THAT I DO NOT INTEND TO COMMIT ANY OF THE PROHIBITED ACTIONS DESCRIBED HERE; FURTHERMORE, I AGREE TO ANY INVESTIGATION IN ACCORDANCE WITH THE ANTI-FRAUD POLICY AND AGREE TO COOPERATE FULLY AND IMMEDIATELY WITH THE ANTI-FRAUD COMMISSIONER IN THE CONTEXT OF THIS INVESTIGATION.