Introduction and Scope

Ludo Australia Pty Ltd ("Ludo," "we," "our," or "us") recognises the inherent risk of our products and services being exploited for money laundering and terrorism financing. We are committed to complying with Australian law and other applicable regulations to identify, manage, and mitigate these risks. Failure to adhere to these laws and regulations could result in significant penalties and damage to our reputation.

Our AML/CTF Policy:

• Is designed to ensure compliance with legislative obligations.
• Applies to all business divisions and employees, including third-party providers, both in Australia and overseas.

Definitions

• Money Laundering: The act of disguising the origins of illegally obtained funds.
• Terrorism Financing: The act of providing financial support to terrorist activities.

Customer Identification

Before engaging in any designated services, customers are required to provide proof of identity. The types of customers we deal with include:

• Personal
• Sole Traders
• Domestic and Foreign Companies
• Partnerships
• Trusts
• Associations
• Registered Co-operatives
• Government Bodies

Suspicion

Employees are trained to identify and report any suspicious activities that may indicate money laundering or terrorism financing.

Key AML/CTF Principles

• Comply with AML/CTF legislation in the countries we operate in.
• Strive to meet international standards.
• Work in conjunction with governmental bodies.
• Make decisions based on ML/TF risk appetite and corporate social responsibility.
• Maintain and comply with an AML/CTF program.

Policy Roles and Responsibilities

Ludo Company Directors and Senior Management oversee the AML/CTF policy. All employees must comply with this policy and undergo role-specific training.

Monitoring and Reporting

We report to our payment acquiring partner for:

• Electronic transfers into or out of Australia.
• Any suspicious activities.