Anti-Money Laundering and Counter-Terrorist Financing Policy

1. Introduction and Commitment

MAXNAM SOLUTIONS LTD. ("MAXNAM," "the Company," "we," "us," or "our") maintains a strict commitment to the prevention of money laundering, terrorist financing, and other financial crimes. The Company prohibits the use of its products, services, and accounts for any unlawful purpose, including money laundering, terrorism financing, fraud, or any transaction involving individuals or entities subject to international sanctions.

Compliance with applicable anti-money laundering and counter-terrorist financing legislation ("AML/CTF") is mandatory and forms a foundational element of the Company's operational framework and strategic objectives. MAXNAM operates in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and its regulations, as well as applicable provincial requirements within Ontario.

The Company maintains rigorous and transparent standards and continuously enhances its internal processes to ensure full adherence to all relevant AML/CTF legal and regulatory obligations.

MAXNAM reserves the right, in accordance with applicable law, to decline any customer, transaction, or business relationship that does not align with the requirements of this Policy or applicable AML/CTF legislation.

2. Compliance With Applicable AML/CTF Laws and Regulations

Pursuant to AML/CTF requirements, customers are obligated to provide MAXNAM with accurate, current, and complete information and documentation necessary to establish and verify their identity, as well as the identity of any payers or payees involved in monetary transactions processed through their account with the Company.

MAXNAM may, at its discretion, request additional information or documentation relating to the customer's identity or beneficial ownership, any monetary transaction or other operation conducted through the customer's account, and any counterparty or third party involved in those transactions.

Failure to provide the requested information may result in the rejection of the relevant transaction or the suspension of the business relationship, as permitted by applicable law.

3. Monitoring for Suspicious Activity

The Company's AML/CTF framework encompasses comprehensive due diligence on customers and beneficial owners, ongoing monitoring of account activity, and internal reporting mechanisms for suspicious transactions.

At various stages of the business relationship, MAXNAM may request further details regarding transactions executed through a customer's account, including information about the parties involved in those transactions. If the customer fails to provide a satisfactory or timely response, MAXNAM reserves the right to refuse any associated payments or transactions, subject to applicable AML/CTF legislation.

All suspicious transactions shall be reported to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in accordance with statutory obligations.

4. Prohibited Conduct

MAXNAM maintains zero tolerance for deliberate or grossly negligent violations of AML/CTF laws, regulations, or internal policies; repeated inadvertent or recurring breaches of AML/CTF compliance requirements; the use of an account for money laundering, terrorist financing, fraud, or other illicit schemes; facilitation of business activities that may be construed as tax evasion or tax offenses; and refusal to provide sufficient information or documentation to demonstrate compliance with this Policy.

The Company seeks to conduct business exclusively with reputable customers who use their accounts and the Company's services for legitimate purposes and whose identities can be reliably established and verified. MAXNAM may suspend or terminate a business relationship where required by applicable AML/CTF legislation or where this Policy has been violated.

5. Sanctions Compliance

MAXNAM maintains no risk appetite for establishing or maintaining a customer or counterparty relationship with any natural person or legal entity designated on sanctions lists or otherwise prohibited by applicable law.

• United Nations Security Council Sanctions List (UN).
• Consolidated List of European Union Financial Sanctions (EU).
• Sanctions lists administered by the United States Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons List (SDN).
• Any other sanctions list applicable under Canadian law or international obligations.

5.1 Enhanced Due Diligence

The Company applies heightened scrutiny to monetary transactions or operations involving entities domiciled in countries identified as non-cooperative by the Financial Action Task Force (FCTF) or its regional bodies. Transactions originating from or destined for such jurisdictions are subject to enhanced due diligence measures.

6. Reporting and Record-Keeping

In compliance with Canadian AML/CTF legislation, MAXNAM retains all records relating to customer identification, transaction details, and suspicious activity reports for the minimum period prescribed by law.

The Company cooperates fully with law enforcement agencies, FINTRAC, and other competent authorities in the investigation and prevention of money laundering and terrorist financing activities.

7. Policy Review and Amendments

This Policy is reviewed periodically to ensure its continued effectiveness and alignment with evolving legal and regulatory requirements. Any material amendments are communicated to affected parties as required by law.

8. Contact Information

For any questions, concerns, or requests regarding this Anti-Money Laundering and Counter-Terrorist Financing Policy, please contact MAXNAM SOLUTIONS LTD. at aml@maxnam.com.