KYC/KYB Policy

This document contains the Know Your Customer (KYC) and Know Your Business (KYB) policies of Play Media Limited (the “Company”), which outline the principles and procedures for verifying the identity and legitimacy of individuals and legal entities that seek to participate in the Be the Boss Program or otherwise establish a business relationship with the Company.

The Company works with both individuals and legal entities. Where a participant acts in their individual capacity, KYC procedures may apply. Where a participant acts through a company or other legal entity, KYB procedures may apply to verify the entity and, where appropriate, its ownership, control and authorized representatives.

These policies are implemented by the Compliance Director.

Know Your Customer (KYC), Know Your Business (KYB) and Anti-Money Laundering (AML) procedures are used to verify the identity and legitimacy of individuals and legal entities that seek to participate in the Be the Boss Program or otherwise engage with Play Media Limited as business partners, suppliers or service providers.

KYC/KYB procedures aim to ensure that Play Media Limited establishes and maintains relationships with legitimate individuals and entities and that such persons are not involved in illegal activities or otherwise present unacceptable legal, regulatory, sanctions, money laundering, terrorist financing, fraud or other compliance risks.

Acknowledging differing levels of risk exposure, the Company may apply simplified KYC/KYB procedures to lower-risk categories. The nature and extent of verification may vary depending on the type of participant, nature of the relationship, jurisdiction, ownership structure, regulatory status and other relevant risk factors.

The Company reserves the right to escalate any participant to a full KYC/KYB procedure if risk factors emerge. Escalation may occur when screening indicates elevated money laundering or terrorist financing risks, sanctions exposure or adverse media, or where ownership and control structures are complex, opaque or cannot be sufficiently verified.

The Company may apply the following KYC/KYB procedures, as appropriate depending on the nature and risk profile of the participant:

• Registration: The Company may collect relevant information required to establish the relationship. For individuals, this may include name, email address, wallet address, telephone number, country of residence and other relevant contact or identifying information. Where the participant acts through a legal entity, the Company may also request the entity's name, registered address, company identification number and the name and email of its authorized representative.
• Verification: Where verification is required, the participant may be required to provide identification or other relevant documents. For individuals, this may include government-issued identification, proof of address or other verification information. For legal entities, this may include a company registration certificate, register of shareholders, information regarding Ultimate Beneficial Owners (UBOs) and other relevant corporate documents depending on the level of risk exposure. Play Media Limited may request additional information or documents where reasonably required to verify the participant, the nature of the relationship or relevant compliance matters.
• Screening: The participant may undergo a screening process to determine whether the individual, entity or relevant associated persons are subject to sanctions or restrictions, identified as Politically Exposed Persons (PEPs), or subject to adverse media that may affect their eligibility or suitability. The Company may use external sources or databases to conduct screening, including the European Union sanctions list, the United Nations consolidated list or commercially available compliance databases.
• Approval: Where approval is required, the participant must receive approval from Play Media Limited before commencing the relevant relationship or accessing the relevant functionality. Play Media Limited reserves the right to reject any application that does not meet its KYC/KYB criteria or standards or that poses a potential legal, regulatory, compliance or reputational risk.
• Monitoring: The Company monitors participants that have undergone the KYC/KYB process, including through sanctions and PEP screening where appropriate. If a potential match, change in risk profile or other compliance concern is identified, Play Media Limited may conduct additional review, request further information or documentation, or apply enhanced due diligence. Depending on the results of the review and applicable requirements, the Company may restrict, suspend or terminate the relevant relationship.

The Company also requires participants to promptly notify it of any material changes or updates to information previously provided that may affect their eligibility or suitability to participate in the Program or otherwise maintain a relationship with the Company.

Personal Data collected or processed in connection with KYC/KYB procedures is handled in accordance with the Company’s Privacy Policy. Where appropriate, verification or screening may be performed through third-party verification or compliance providers.

Contact: info@playmedialimited.com — bethebossclub.com

The Company monitors the status of participants on the Be the Boss Club platform, where appropriate.

Play Media Limited may suspend or terminate the account of any participant that fails to comply with its KYC/KYB policies and procedures, or that provides false, misleading or fraudulent information or documents.

Play Media Limited monitors and reviews its KYC/KYB policies and procedures at least biannually to ensure that they are effective, efficient and compliant with applicable laws and regulations.

In the interim, Play Media Limited may update or amend its KYC/KYB policies and procedures at any time and will notify participants of any changes or requirements, where applicable.

Contact: info@playmedialimited.com — bethebossclub.com

Play Media Limited is committed to providing adequate and appropriate training for all relevant personnel on its KYC/KYB policies and procedures.

The Compliance Director ensures that relevant personnel understand the purpose, scope and implementation of the policies, as well as the roles and responsibilities of staff involved. The training also covers the applicable legal and regulatory framework governing KYC/KYB requirements, the risks and consequences of non-compliance, and relevant practices for conducting due diligence and verification checks.

Training is tailored to the different levels and functions of staff depending on their exposure and involvement in the KYC/KYB process. Personnel who interact directly with participants, including sales and marketing personnel, may receive more detailed training regarding the collection and verification of information and documents. They are also trained to identify and report suspicious or unusual activities that may indicate fraud, money laundering or other criminal activity.