Anti-Money Laundering Policy

1Introduction

This policy sets out Taggit Asset Technologies’ commitment to detecting, preventing, and reporting money laundering (ML) and terrorist financing (TF) activities in accordance with South African law, including the Financial Intelligence Centre Act (FICA), and international frameworks such as the FATF (Financial Action Task Force) recommendations. The goal is to ensure that our operations are not exploited for criminal purposes.

2Scope

This policy applies to:

• All Taggit Asset Technologies employees, contractors, and business units.
• All customers, suppliers, resellers, and partners engaged in financial or asset-related transactions with Taggit Asset Technologies.

3Definitions

• Money Laundering (ML): The process of disguising the proceeds of crime to appear as legitimate funds.
• Terrorist Financing (TF): The collection or provision of funds intended to support terrorist activities.

4Policy Statements

Taggit Asset Technologies shall:

• Not knowingly facilitate or be involved in ML or TF activities.
• Conduct due diligence on all clients, partners, and transactions.
• Report suspicious activities to the relevant authorities.
• Maintain comprehensive records of transactions and verifications.

5Customer Due Diligence (CDD)

To comply with standard Customer Due Diligence (CDD) requirements, Taggit will obtain and verify the following for all customers and suppliers:

• Full legal name.
• Company registration or identity number.
• Physical address and contact details.
• Source of funds or payment.
• VAT and tax clearance documentation (where applicable).

In certain instances, Taggit Asset Technologies may require additional information to comply with Enhanced Customer Due Diligence (EDD) requirements. These instances may include, but are not limited to the following:

• Politically exposed persons (PEPs).
• High-risk jurisdictions.
• Complex or large transactions.
• Clients refusing to provide adequate identification.

6Know Your Customer (KYC) Requirements

All new customers must undergo the KYC process before any transaction is concluded. This may include:

• Identity verification.
• Sanctions screening (against UN, EU, and OFAC lists).
• Ongoing monitoring for changes in risk profiles.

7Transaction Monitoring

Taggit shall implement systems to monitor:

• Unusual payment patterns.
• Large cash payments or offshore transactions.
• Refund requests inconsistent with transaction history.
• Transactions involving high-risk jurisdictions.
• Any red flags must be escalated to the Compliance Officer.

8Warranties and Support

• Hardware and tags supplied carry the manufacturer’s warranty only.
• Software is licensed under the applicable end-user license agreement (EULA).
• We will provide reasonable support and training as per the Software Maintenance Agreement (SMA) of each software solution sold.

9Record Keeping

All records of CDD, KYC, and transactions must be:

• Maintained for at least 5 years after the end of a business relationship.
• Securely stored in digital and/or physical formats.

10Reporting Obligations

Suspicious transactions will be reported to:

• Financial Intelligence Centre (FIC) in South Africa.
• Relevant compliance bodies (if operating in foreign jurisdictions).
• Employees must immediately report any suspicion to the Compliance Officer.

11Training and Awareness

Taggit Asset Technologies will:

• Provide annual AML/CFT training to all relevant staff.
• Conduct onboarding sessions for new employees.
• Distribute this policy and update staff on changes.

12Compliance Officer

The Compliance Officer is responsible for:

• Oversight and enforcement of this policy.
• Liaison with authorities and auditors.
• Reviewing red flags and authorizing reports.
• Ensuring up-to-date regulatory compliance.
  • Current Compliance Officer: Craig Beer
  • Email: Cr***@*********co.za
  • Phone: +27 21 830 5330 / +27 82 903 2765

13Review of Policy

This policy shall be:

• Reviewed annually or upon major regulatory change.
• Updated and approved by senior management.