TMDS CZ s.r.o. COMPLIANCE POLICY

At TMDS CZ s.r.o. (“TMDS”), we are committed to conducting business with integrity, professionalism, and full adherence to all applicable laws, including those related to anti-bribery, anti-corruption, anti-money laundering(AML), and counter-terrorism financing (CTF). This policy reflects our commitment to ethical conduct, legal compliance, and robust corporate governance, particularly in high-risk sectors such as international oil and fuel trading.

This policy is designed to:

• Define clear rules of conduct to prevent financial crime and unethical behavior
• Ensure alignment with legal frameworks including:
  • EU AML Directives
  • Czech AML Act (Act No. 253/2008 Coll.)
  • FATF Recommendations
  • UK Bribery Act
  • U.S. Foreign Corrupt Practices Act (FCPA)
  • ISO 37301 and ISO 37001 standards
• Embed a culture of compliance, transparency, and accountability across all TMDS activities and relationships

This policy applies to:

• All TMDS employees, executives, and directors
• Contractors, consultants, and representatives 
• Business partners, counterparties, and third parties acting on behalf of or in cooperation with TMDS (also referred to as "agents")

4.1 Anti-Bribery and Corruption (ABC)

TMDS enforces a zero-tolerance approach to all forms of bribery and corruption.

• No employee or agent may offer, promise, give, request, or accept bribes, facilitation payments, or improper benefits
• All gifts, hospitality, and donations must be:
  • Reasonable in value and nature
  • Properly documented
  • Approved in advance where required
  • Logged in the TMDS Gifts and Hospitality Register
• TMDS complies with international anti-corruption laws, including the UK Bribery Act and the FCPA
• Dealings with politically exposed persons (PEPs) or public officials are subject to additional scrutiny and Enhanced Due Diligence (EDD)

4.2 Anti-Money Laundering and Counter-Terrorism Financing

TMDS will not tolerate the use of its operations for laundering criminal proceeds or financing terrorism.

  4.2.1 Customer Due Diligence (CDD) & Know Your Counterparty (KYC)

• We conduct risk-based due diligence on clients, suppliers, and partners prior to any business engagement
• This includes verification of:
  • Legal existence and ownership structure
  • Ultimate Beneficial Owner (UBO)
  • Source of funds
  • Sanctions screening and adverse media checks

  4.2.2 Enhanced Due Diligence (EDD)

• Applied in high-risk scenarios, such as:
  • Transactions involving high-risk jurisdictions
  • Offshore structures or intermediaries
  • Clients with cash-intensive or opaque operations
  • Involvement of PEPs or sanctioned persons/entities

  4.2.3 Transaction monitoring

• TMDS maintains accurate, complete, and transparent records of all business transactions
• Red flags such as unusual payment structures, round-tripping, or third-party payments are escalated and reviewed by the Compliance Officer

  4.2.4 Reporting suspicious activity

• Any suspicious activity must be reported immediately and confidentially to the Compliance Officer
• The Suspicious Activity Reporting (SAR) process is governed by Czech and EU AML laws
• TMDS will report any suspicion to the Financial Analytical Office (FAÚ) if legally required

5.1 Compliance Officer

• Responsible for oversight and continuous improvement of TMDS’s compliance framework
• Maintains internal registers, monitors regulatory developments, and manages investigations and reporting

5.2 Whistleblowing and non-retaliation

• TMDS maintains a secure whistleblowing channel
• Individuals reporting concerns in good faith are protected from retaliation

5.3 Internal controls and monitoring

• Regular internal audits, risk assessments, and control reviews are conducted
• Findings are escalated to senior management and acted upon promptly

• All employees and relevant third parties must complete mandatory compliance training during onboarding and at regular intervals thereafter
• Training includes:
  • Identifying and responding to bribery or AML risks
  • Reporting obligations and escalation protocols
  • Sanctions, export control, and jurisdictional risks

Training content is tailored to employee roles and operational risk exposure.

• Employees found to have violated this policy may face:
  • Disciplinary action up to and including termination
  • Criminal referral or civil proceedings where applicable
• Third parties who breach this policy or fail to maintain equivalent standards may have their contracts terminated without liability to TMDS

• This policy is reviewed annually or as required by changes in law, business activity, or risk exposure
• All updates are approved by senior management and communicated to relevant stakeholders

TMDS operates in a highly regulated, high-risk sector. We reaffirm our unwavering commitment to operating in full compliance with law, rejecting corruption in all forms, and maintaining transparent and verifiable business practices.

Contact:
For questions, reporting, or clarifications regarding this policy, contact:
Compliance Officer – TMDS CZ s.r.o.
Email: compliance@tm-ds.cz

Last review: 12 May 2025