Anti-Money Laundering Policies, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction (LA/FT-FPADM) - Thousand S.A.S

Effective Date: 05 – November - 2023

1. Introduction:

1.1 Objective:

The objective of these policies is to prevent and mitigate the risks associated with money laundering, financing of terrorism and financing the proliferation of weapons of mass destruction in the context of Thousand S.A.S operations in Colombia.

1.2 Scope:

These policies apply to all employees, managers and related parties of Thousand S.A.S.

2. Know Your Customer (KYC):

2.1 Client Identification:

Thousand S.A.S will carry out due diligence to identify and verify the identity of each client.

2.2 Continuous Monitoring:

Continuous monitoring processes will be implemented to evaluate customer activity and detect unusual or suspicious patterns.

3. Report of Suspicious Operations:

3.1 Reporting Obligation:

All Thousand S.A.S staff are required to immediately report any suspicious activity.

3.2 Reporting Procedures:

We will establish clear and efficient procedures for submitting reports of suspicious transactions to the competent authorities.

4. Training:

4.1 Training Programs:

Thousand S.A.S will carry out regular training programs for all staff, ensuring that they are informed about the latest trends and regulations regarding LA/FT-FPADM.

5. Due Diligence on Third Parties:

5.1 Risk Assessment:

A third party risk assessment will be conducted to ensure they are not involved in illicit activities.

5.2 Contracts:

Contracts with third parties will include clauses requiring compliance with LA/FT-FPADM policies.

6. Monitoring and Review:

6.1 Continuous Monitoring:

Thousand S.A.S will implement continuous monitoring systems to evaluate the effectiveness of LA/FT-FPADM policies.

6.2 Periodic Reviews:

Periodic reviews of policies and procedures will be carried out to ensure their relevance and effectiveness.

7. Sanctions for Non-Compliance:

7.1 Disciplinary Procedures:

We will establish clear disciplinary procedures for cases of non-compliance with LA/FT-FPADM policies.

7.2 Report to Authorities:

In serious cases of non-compliance, a report will be made to the competent authorities.

8. Regulatory Compliance:

8.1 Compliance Evaluation:

Periodic assessments will be carried out to ensure continued compliance with LA/FT-FPADM regulations.

8.2 Policy Updates:

Policies will be updated in accordance with regulatory changes and industry best practices.

9. Responsibility of Senior Management:

9.1 Commitment of Senior Management:

Thousand S.A.S senior management assumes responsibility for ensuring full compliance with these LA/FT/FPADM policies.