The politics of anti-Money Laundering and combating the Financing of Terrorism - PLD-FT

The Stregu incorporation LTDA shall, by means of this Policy, a compliance program and adherence to the laws and regulations of the PLD-CFT regulations, by means of a series of actions, in order to ensure the proper identification, qualification, and knowledge of customers, suppliers, partners, and employees, including the capture, update, store, and validate account information, and procedures that are specific to the identification of the Final Beneficiaries, and monitoring of events and transactions that are suspect.

We reject is any process which seeks to disguise the nature and source of the money that is associated with illegal activity. The only conduct business with reputable third parties, including professional advisors, and business partners who are engaged in lawful activities, and whose resources are to be from the legitimate source.

Money-laundering and the financing of terrorism, and its facilitation are strictly forbidden in any form, or by their context. Your violation of any laws, it may bring about severe civil and criminal penalties to those involved.

We have adopted the following procedures to mitigate the risk of money laundering and the financing of terrorism, in accordance with the business and the people involved.

This is the Policy of the anti-Money Laundering and combating the Financing of Terrorism (“the Policy”) is intended to establish, in accordance with the current legislation, guidelines, to ensure that the procedures and ongoing monitoring mechanism to combat and mitigate the risks related to money-laundering and the financing of terrorism , the protection of the business of the Stregu incorporation LTD. (“Stregu inc.”), in accordance with the regulations of the Central bank and the international best practices, the regulation of the Central Bank of Brazil, and the rules for arrangement and payment institutions.

This Policy applies to all officers, employees, as defined in the Code of Ethics and code of Conduct Stregu inc., our business partners, vendors and service providers.

PLD: the Prevention of Money Laundering.

CFT: Combating the Financing of Terrorism.

KYC: Know your Customer – a Term in the English language that means to “Know your Customer”).

KYE: Know-Your-Employee – End-in English it means “Know your Employee”,

KYP: "Know Your Partner", a Term in English that means “to get to Know your Partner.”

KYS: "Know Your Supplier – the word in the English language that means to “Know your Supplier”.

MONEY LAUNDERING: THE term “money laundering” is the practice of criminal activities, which are aimed to make illegal money in a lawful, or in other words, it is the process by which the target is transformed resources are earned in illegal activities, on with the source that is apparently legal to conceal or disguise the nature, source, location, disposition, movement or ownership of property, rights, or values arising out of, directly or indirectly, in violation of criminal cases.

Counter-TERRORIST FINANCING: Is the reunion of the funds and/or funds to conduct terrorist activities. These funds are from donations, or to gain a diverse range of activities may be lawful or illegal, such as drug trafficking, prostitution, organised crime, smuggling, extortion, kidnapping, frauds, etc.

A PERSON EXPOSED to a POLITICALLY: it IS considered to be a Person is Exposed to Politically (PEP), is the one who plays, or has played in the last five years earlier, in Brazil or in countries, territories and dependencies to be foreigners, jobs, employment, or public offices are relevant to you.

In compliance with the Policy, the PLD/CFT, they are made up of the following rules:

The Prevention Of Permanent
Get to know your Client – KYC.
We have adopted internal procedures that make it possible to identify from the customer's home up to their final recipients, in the attempt to understand the purpose and the nature and consistency of your business that you want.

The personal data of the customers deserve your attention. They must have been collected for the purpose of identifying the customer and high-quality information, and to update on a regular basis, thus providing a baseline of the data is safe and secure.

The more skilled you are with the information that is collected and stored, the better it will be for the identification of the risk of occurrence, of something illicit, providing greater security for the transaction.

Please note that your identification and monitoring of the WBS is done in the most correct and as per the provisions of the law.

The ultimate beneficiary is the one person who benefits directly or indirectly to the success of the company and/or the name of the transaction that is being carried out. The identification of the Beneficiaries of the End-of-a Legal entity, it is an extremely important part of the process of KYC.

All the information that is collected and stored in the register's internal will allow you to get to know the structure of the ownership and control of the business, and this information will be kept up to date, in the case of people who have the power to lead, influence, use, or benefit of the legal entity customer to the practice of money laundering or financing of terrorism.

For the mitigation of the risks that are associated with PLD/CFT, the Stregu inc. use of the system that performs the classification of the customer through the procedure in an analysis of the risks and the flow of the transaction has already been approved.

Get to know your co-worker – KYE
The Stregu inc. has rules, procedures, and internal controls to get to know your co-worker from the check up their actions with regard to customers, suppliers and business partners, as criminals may try to disrupt the employees of the organization, for the purpose of the practice of illegal acts.

Get to know your Partner, KYP, and get to Know your Supplier – KYS
The Stregu inc. has internal procedures that are used to identify and accept partnerships, vendors, and service providers, in order to prevent the fulfillment of the contract with the parties, ineligible, or suspected of involvement in illegal activities, as well as to ensure that they have appropriate procedures in place for the PLD/CFT, where applicable.

Training
Through the training courses that are suitable for the industry, the culture, the PLD/CFT is disclosed to the administrators, supervisors, and other employees of the Stregu, inc., with the aim of improving the understanding of the topic, and to raise the level of attention refers to the practice illegal, as well as to empower the entire organization to identify, prevent, and report evidence for the occurrence of money laundering and the financing of terrorism.

Processes and Controls
The monitoring and analysis of the transaction.
The Stregu inc. it has a built-in desk for risk analysis, which analyzes and monitors all of the transactions made by the customer, in order that the atypical cases, or suspected to be identified and prosecuted immediately.

Depending on the level of risk associated with the customer, and the evaluation of the Industry in Compliance, it can be applied to the monitoring of a reinforced, up to a re-evaluation of the risk to be undertaken.

The communication to the market conditions of the transaction is suspected.
All the transactions in the field, or with a suspicion of money laundering or terrorist financing, they should be reported to the Board of Control of Financial Activities (COAF), in accordance with the provisions of laws and regulations.

New Products And Services
In the creation and implementation of new products and / or services, Stregu inc. conducts a rigorous review of the proceedings of the PLD/CFT.

Improvement and Evaluation of the Policy, the PLD/CFT
The Industry's Compliance officer is the area that is responsible for improving this Policy periodically in order to adapt to the built-in controls, with respect to the PLD/CFT. It is also responsible for the annual assessment of the effectiveness of this Policy in relation to the procedures and internal controls, and submit a report on the follow-up to the top of the Stregu, inc.

Direction
Senior management is responsible for:

• By agreeing to this Policy, changes, and updates:
• Implement and monitor compliance with this Policy;
• To inform the competent authorities of any transactions on the grounds of money laundering and the financing of terrorism;

Compliance
The industry's Compliance officer is responsible for:

• To co-ordinate the development of routines and tools of control, aimed at the support of the current legislation and regulations, as well as to evaluate the effectiveness of this policy;
• To ensure compliance with all laws, rules, and regulations, and internal policies that govern it comes up with PLD/CFT.
• Establishing training and education programmes in the framework of the employees.
• Responsible for coordinating all activities related to the PLD/CFT.

Legal
The legal counsel is responsible for:

• For services to the law enforcement authorities and judicial authorities, when necessary;
• Support and assist the industry in Compliance, in the procedures necessary for the treatment of the issues and to report to the organs, agencies, and authorities in general.

Contributors
All contributors are responsible for:

• By complying with the requirements of this policy on the prevention of money laundering and the financing of terrorism;
• Reporting to the Compliance and any recurrence of the evidence for the illicit practices;
• Take part in the training, capacity-building workshops and seminars to update the PLD/CFT.

Internal Audit
The internal audits are carried out to verify the compliance with, and adherence to Policy, and other rules;

The ombudsman's office/reporting Channel
In order to receive the complaints of the indications of unlawful acts relating to the activities of the Stregu, inc., we provide a channel for the ombudsman's office, which has a scope of the complaints and allegations, investigate, and resolve complaints and requests.