[et_pb_section fb_built=”1″ theme_builder_area=”post_content” _builder_version=”4.27.4″ _module_preset=”default”][et_pb_row _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content”][et_pb_column _builder_version=”4.27.4″ _module_preset=”default” type=”4_4″ theme_builder_area=”post_content”][et_pb_button button_text=”RETURN TO HOMEPAGE” _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content” button_url=”https:\/\/kyron.com.pa\/us” hover_enabled=”0″ sticky_enabled=”0″][\/et_pb_button][\/et_pb_column][\/et_pb_row][et_pb_row _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content”][et_pb_column _builder_version=”4.27.4″ _module_preset=”default” type=”4_4″ theme_builder_area=”post_content”][et_pb_text _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content” hover_enabled=”0″ sticky_enabled=”0″]<\/p>\n
MONEY LAUNDERING PREVENTION POLICIES AND FIGHT
TO THE FINANCING OF TERRORISM
KYRON DIGITAL SA
PRIVATE INTERNAL POLICY
AND CONFIDENTIAL
Type : POLICY
Title of document \/ Matters: Prevention of Fight the Washing Money
and Terrorism Financing and Policy Antibribery
and Anti-Corruption
Area Responsible: Risk & Compliance
Last update: 01\/04\/2025
INDEX
1. INTRODUCTION AND SCOPE ………………………………………………………………………………………………………… 3
2. CONCEPT OF WASHING OF MONEY ……………………………………………………………………………………………… 3
3. FINANCING TO THE TERRORISM …………………………………………………………………………………………………. 5
4. REGULATION ………………………………………………………………………………………………………………………………….. 5
5. COMPLIANCE KYRON DIGITAL SA ……………………………………………………………………………………………….. 6
6. ACTIONS OF PREVENTION ……………………………………………………………………………………………………………. 7
7. KNOW YOUR CUSTOMER (\u201c KNOW YOUR CLIENT ) AND REGISTRATION ………………………………. 7
8. PEOPLE POLITICALLY EXPOSED ………………………………………………………………………………………………….. 9
9. KNOW YOUR PARTNER ( \u201cKNOW YOUR PARTNER ) – KYP ………………………………………………………. 10
10. RESEARCH REPUTATIONAL ………………………………………………………………………………………………… 11
11. BANKS AND BANKS CORRESPONDENTS INTERNATIONAL …………………………………………….. 11
12. TREATMENT OF OCCURRENCES AND SITUATION MONITORING ATYPICAL …………………. 11
13. COMMUNICATION TO THE UAF ………………………………………………………………………………………….. 11
14. POLICY ANTI-CORRUPTION AND ANTI-BRIBERY …………………………………………………………….. 12
15. ADMINISTRATION PUBLIC ………………………………………………………………………………………………….. 13
16. PROVISIONS GENERAL …………………………………………………………………………………………………………. 15
17. CONSIDERATIONS FINALS …………………………………………………………………………………………………… 16
1. INTRODUCTION AND SCOPE
This Policy sets out the rules and procedures to be observed by KYRON DIGITAL SA , with
regard to the company’s operations in Panamanian territory, and individuals who
collaborate directly or indirectly with the company, in the Money Laundering and
Terrorism Financing Prevention and Combat Program for the illicit activities covered by
Law 23\/2015 and other regulations on the subject.
KYRON DIGITAL SA., as a company operating in the financial services\/payment
technology sector, recognizes itself as an obligated party under the terms of article 3 of
Law No. 23 of April 27, 2015 of the Republic of Panama, and undertakes to fully comply
with the legal obligations provided for the prevention of money laundering, financing of
terrorism and the proliferation of weapons of mass destruction, including the
implementation of internal policies, due diligence processes, monitoring of operations
and reporting of suspicious activities to the Financial Analysis Unit (UAF).
This Policy is reviewed periodically, end of to achieve to the best practices of performance
in the market, through:
\u2713 Regular review of Average Search and themes involving the sector of payments;
\u2713 Revision regular alerts and reports about the application of law;
\u2713 Attention the changes of alerts of terror and of regimes of sanctions like this
that occur;
\u2713 Revision of the guidelines nationals of rules, policies, laws and procedures, of
infra and supra-legal standards.
It is the responsibility of any individual\/institution that has a direct or indirect
relationship with KYRON DIGITAL SA to know and comply with all obligations arising
from this Policy and regulations in force in the country.
2. CONCEPT OF WASHING OF MONEY
Money Laundering can be defined as the term commonly used for the a process by which
an individual seeks to conceal the proceeds of a crime by exchanging property derived
from crimes for so-called \u201cclean money.\u201d This practice generally involves transactions
used to conceal the origin of financial resources and allow them to be used in a manner
that appears to have originated lawfully.
Those responsible for this operation ensure that the amounts obtained through illicit and
criminal activities are concealed or hidden, appearing as the result of legal commercial
operations and can be absorbed by the financial system, naturally.
To the following activities they can to be associated the washing of money, no if limiting the
they:
\u2022 Acquire, use or possess property coming from of crimes;
\u2022 Concealing, disguising, transferring or handling property derived from crimes such as
theft, fraud and tax evasion;
\u2022 Be consciously involved in any manner with property resulting from crimes;
\u2022 Invest property coming from of crimes, it is in products financial, it is by the
acquisition of property or assets;
\u2022 Transfer property coming from of crimes;
\u2022 Finance terrorist activity
You three internships from the washing of money usually to be:
1. Placement: this is the first phase of money laundering. It involves the entry into the
financial system of resources from illicit activities, through deposits, purchase of
financial instruments or purchase of goods. At this stage, it is common to use financial
institutions to introduce resources obtained illicitly;
2. Concealment: This second phase involves separating the assets illicit from the your
source put through the creation of complex layers of financial transactions designed to
make tracking, audit trail, monitoring and identification difficult and disguised from
the source illegal money, allowing anonymity;
3. Integration: The final phase consists of giving apparent legitimacy to the assets derived
from crimes. If the concealment phase was successful, the incorporation formal of
money in the economic system it occurs through investment in the capital market, real
estate, works of art, among others, so that the assets re-enter the financial system
appearing to come from regular funds
In relation to the illicit Object, or the illicit origin, we consider resources coming from the
following activities, such as: drug trafficking; public corruption crime of any nature;
terrorism and your financing; smuggling; traffic of weapons illegal, explosives,
ammunition or material intended for their production; illicit trafficking in organs, tissues,
medicines, nuclear substances, works of art, animals and materials toxic; traffic of human
beings or sexual exploitation; kidnapping, extortion, pimping; fraud; crimes against
intellectual property; misappropriation; falsification or alteration of currency; conduct
related to prostitution and\/or child pornography; fraudulent insolvency or bankruptcy;
crimes of genocide, war crimes, crimes against humanity, or any other considered illegal
under the applicable jurisdiction.
In addition to the general definitions, this Policy adopts and monitors the money
laundering typologies recognized by the Financial Analysis Unit (UAF) and by
GAFILAT technical reports , especially those applicable to companies in the financial and
digital sectors. Among the most common typologies, the following stand out:
\u2022 Use of Third Parties (Front Men): Customers use accounts in the name of family
members, front men or companies with no real activity to move large amounts of
money without a plausible economic justification.
\u2022 Smurfing : Repeated deposits or purchases in amounts slightly below the
mandatory reporting threshold, with the aim of avoiding automatic
identification and reporting.
\u2022 Use of Commercial Front Activities: Companies are registered and operate only
formally, with the true purpose of moving illicit funds under the appearance of
legitimate commercial transactions.
\u2022 International Movement of Funds Without Commercial Justification:
Frequent transfers to tax havens or countries with low international cooperation,
with no clear link to the company’s economic activities.
\u2022 Reintegration via High Value Assets: Purchase of real estate, luxury cars or
works of art with illicit money, to give a legitimate appearance to the assets later
resold.
\u2022 Transactions in the Names of Inactive or Newly Created Legal Entities: Use of
newly opened companies, without operational structure, to justify high-volume
operations with a scope incompatible with their size or activity.
\u2022 Use of Digital Platforms and Electronic Payments: Carrying out multiple
transactions with cryptocurrencies, digital wallets or payment applications with
accounts without adequate identity verification (weak or absent KYC).
3. FINANCING TO THE TERRORISM
Terrorism financing consists of the allocation of resources, whether legal or illegal, to one
or more individuals or organizations whose purpose is to provoke social terror, through
acts that expose others to danger. person, heritage or the peace public for reasons of
xenophobia, discrimination or prejudice based on race, color, ethnicity and religion.
Such resources generally come from the activities of other criminal organizations
involved in drug, arms and ammunition trafficking and smuggling, or they can be derived
from illicit activities, including donations to \u201cfront\u201d charities.
The methods used by terrorists to conceal their links to their sources of funding are
generally similar to those used in money laundering. However, terrorists typically use
legally obtained funds to reduce the risk of being discovered before committing a terrorist
act.
4. REGULATION
The Panamanian regulatory framework for the Money Laundering and Terrorism
Financing Prevention Program (\u201cPLDFT\u201d) is in line with international legislation, with
Panama being a signatory to the main international commitments on the subject.
The main regulatory standard for the financial market regarding this matter is the Law
No. 23\/2015, which provides for you crimes of washing or concealment of goods, rights
and values; preventing the use of the financial system to commit such practices and which
established the UAF \u2013 Financial Analysis Unit.
Others references normative applicable:
\u2714 Law No. 23 of April 27, 2015
\u2714 Law No. 254 of November 11, 2021
\u2714 Law No. 124 of January 7, 2020
\u2714 Law No. 70 of January 31, 2019
\u2714 Law No. 21 of May 10, 2017
\u2714 Executive Decree No. 35 of September 6, 2022
\u2714 Executive Decree No. 587 of August 4, 2015
5. COMPLIANCE KYRON DIGITAL SA
It is the responsibility of KYRON DIGITAL SA to know, understand and seek ways to
protect it against fraudulent operations. involving washing of money, financing of
terrorism and corruption, and omission in relation to any of these matters is prohibited.
Both the legal and sub-legal standards on these crimes and the rules of this Policy must
be known and complied with.
If any operation suspected of such crimes is identified, it must be reported to Compliance,
which will carry out analyses that consist mainly of checking the client’s registration
documentation and its updating, and the evolution of the financial and asset situation.
KYRON DIGITAL SA periodically carries out an Internal Risk Assessment (AIR), based on
its operational, geographic and customer exposure, in accordance with Art. 29 of Law No.
23 of 2015. This assessment supports the definition of controls, KYC\/KYP criteria and
continuous monitoring proportional to the degree of risk identified.
KYRON DIGITAL SA has a compliance structure, which has the following responsibilities,
among others:
\u2022 Responsible put manage and control you procedures this Policy;
\u2022 Supervise the greeting of the standards referents to the Flat of Prevention Money
Laundering and Terrorism Financing;
\u2022 Observe you standards ethical in the driving of the business, node
establishment and in maintaining relationships with Users;
\u2022 To update to the information contained in this manual, with basis in the
legislation and applicable standards;
\u2022 Review periodically the Policy or always what occur facts relevant aspects
identified by internal and external audit;
\u2022 Monitor occurrences on operations atypical \/ suspicions communicated the
Management;
\u2022 Perform Due Diligence and processes of KYC and KYP to to the partner companies ;
\u2022 Perform checks internal annually, the end of to guarantee the greeting of
policies;
\u2022 Perform when necessary to the communications to U AF \u2013 Financial Analysis
Unit;
\u2022 To analyze eventual new products and services, the end of identify
vulnerabilities from the perspective of preventing money laundering.
THE KYRON DIGITAL SA no performs business with:
\u2714 Individuals or companies suspects of washing of money and\/or financing of
terrorism;
\u2714 Shell banks;
\u2714 Individuals or companies to you which the level necessary of Due Diligence NO has
been executed;
\u2714 Users listed as no acceptable by the Policies from the KYRON DIGITAL SA.;
\u2714 Companies based in countries sanctioned.
6. ACTIONS OF PREVENTION
The entire procedure for identifying and monitoring activities related to the prevention
of money laundering begins with the registration of customers, partners and users.
Therefore, to ensure compliance with sound risk management practices, the activities of
customers and Users must be monitored in accordance with the standards issued by
applicable regulatory and self-regulatory bodies.
Among the measures adopted to combat and prevent the flow of potential illicit
transactions, the following stand out:
\u25cf Procedures of \u201cMeet Your Customer” (KYC), and \u201cMeet your Partner” (KYP) listed in this
Policy, understood as the set of practices whose objective is the correct identification,
qualification and classification of the institution’s clients for prevention purposes the
washing of money and to the financing of terrorism (\u201cPLD\/FT\u201d);
\u25cf Establishment of limits of buy for users;
\u25cf Investments in tools of control and monitoring, what allow the detection of atypical
operations; and
\u25cf Checking and validation of Personal Identity Card at the Electoral Court \u2013 Civil Registry
and lists of international sanctions ;
The tools – already existing and those to be created and improved – related to monitoring
of the activities of its Users, offer the KYRON DIGITAL SA control of your activities,
allowing what any operations suspicions may to be promptly analyzed for proper
communication to the organs competent and service from the legislation in force.
KYRON DIGITAL SA undertakes to fully comply with the resolutions of the United
Nations Security Council (UNSC) related to the prevention of the financing of terrorism
and the proliferation of weapons of mass destruction, in accordance with the
provisions of Chapter VI of Law No. 23 of 2015 and Executive Decree No. 587 of
August 4, 2015.
Thus, the company will adopt the necessary measures for the preventive and immediate
freezing of goods, funds or other assets belonging to natural or legal persons listed by
the UNSC, without prior notice to the holders, ensuring reporting to the Financial
Analysis Unit (UAF) , as required by Panamanian regulatory frameworks.
7. KNOW YOUR CUSTOMER (\u201c KNOW YOUR CLIENT ) AND REGISTER
KYRO N DIGITAL SA will assess the risk of each client, taking into account the
purpose of the account or relationship, the level of assets and the volume and
frequency of transactions executed, as well as the regularity and duration of the
business relationship.
This is a recommendation from the Basel Committee on Banking Supervision \u2013 BCBS
applicable to financial institutions or similar companies, where they establish a set of
internal rules and procedures with the aim of knowing their customers, seeking to identify
and understand the origin and constitution of the Users’ assets and financial resources.
By analogy to such practices, KYRON DIGITAL SA establishes, in the process of verifying
the Client, not to maintain ties with people who present any indication of a relationship with
activities of a criminal nature, especially those allegedly linked to drug trafficking, terrorism
or organized crime, whose businesses are of a nature that makes it impossible to verify the
legitimacy of their activities or the origin of the funds transferred, or who refuse to provide
the information or documents requested.
In accordance with good market practices, and in compliance with the internal regulations
of the financial market, KYRON DIGITAL SA carries out several procedures related to the
KYC process through its registration process, classified according to the monthly volume
of the user’s operation.
At the time of registration, all new users are asked to provide the following minimum
content:
I \u2013 If Person Natural:
\u2714 Full name;
\u2714 Sex;
\u2714 Date of birth;
\u2714 Nationality;
\u2714 Nature and number of document of identification, name of organ sender and date
of dispatch;
\u2714 Number of enrollment of the Personal Identity Card,
\u2714 Address full (street, complement, neighborhood, city, state );
\u2714 Number by telephone;
\u2714 Address electronic correspondence ;
\u2714 Professional occupation ;
\u2714 Copy\/proof of document of identity.
II \u2013 If Person Legal:
\u2714 A name or reason social;
\u2714 Names and Personal Identity Card of the controllers direct or reason social and
enrollment node Single Taxpayer Registry (RUC) of direct controllers;
\u2714 Names and Personal Identity Card of the administrators;
\u2714 Name of the attorneys (if applicable);
\u2714 Number of RUC;
\u2714 Address full (street, complement, neighborhood, city, state );
\u2714 Number by telephone;
\u2714 Address electronic of correspondence
\u2714 Activity main developed;
\u2714 Billing average monthly;
\u2714 Qualification of the representatives or attorneys and description of their powers;
\u2714 Copy of the following documents:
\u2022 RUC
\u2022 Document of constitution from the person legal properly updated and
registration with the competent body; and
\u2022 Proxy and document of identity of attorney (if for the case).
Guidelines :
To the changes of address constant of register depend of order of client, in writing or
electronically, and proof of the corresponding address;
THE customer if compromises the inform any changes what come the occur in your
registration data;
THE customer if responsible for the divergence of information constants in the registry;
Also, node what tange registrations, our system blocks automatically users who register more
than once on the same device.
Regarding KYC control regarding purchase limits, we currently have controls that aim to
regulate and restrict monthly purchase limits for users, according to the risk presented.
8. PEOPLE POLITICALLY EXPOSED
KYRON DIGITAL SA pays special attention to commercial relations with politically
exposed persons (hereinafter \u201cPEP\u201d), and:
\u2714 Supervises of manner more strict the relationship of business maintained with PPE;
\u2714 Dedica special attention the proposals of start of relationship and the
operations recommended to PPE and;
\u2714 Keeps procedures and controls internal to identify customers what became ,
after the start of relationship with the KYRON DIGITAL SA., or what it is found who
were already PPEs at the beginning of the relationship, and apply the same procedures.
They are conceptually considered PPEs:
That person who performs or has performed – us last 5 (five) years: relevant public positions,
jobs or functions, in Panama or in other foreign countries, territories and dependencies, as
well as their representatives and family members; and
They are effectively considered PPEs:
\u2714 From one form general, people with position, job or function public relevant exercised
by bosses of state and of government, politicians of high level, high servers of the public
authorities, magistrates or high-level military personnel, directors of public companies or
directors of parties politicians;
\u25cf President of the Republic, Vice-president
\u25cf Ministers of State
\u25cf Deputies of the National Assembly
\u25cf Magistrates of the Supreme Court of Justice
\u25cf Attorney General of the Nation
\u25cf Comptroller General of the Republic
\u25cf Directors and managers of state-owned companies
\u25cf Members of the National Security Council
\u25cf Senior officers of the Armed Forces or National Police (from colonel or equivalent)
\u25cf Leaders of registered political parties
\u25cf Presidents, directors or administrators of autonomous and semi-autonomous entities
PROCESS OF DILIGENCE REINFORCED \u2013 PEOPLE WITH MONITORING SPECIAL
The Compliance area pays special attention to Users identified as highly sensitive, such as
People mentioned in the media or other media for involvement in criminal activities, or
Politically Exposed Persons.
9. KNOW YOUR PARTNER ( \u201cKNOW YOUR PARTNER ) – KYP
In compliance with applicable legislation, regulations and internal controls, this Policy
aims to collect information about those interested in providing services to KYRON
DIGITAL SA for the purposes of Preventing Money Laundering and Combating the
Financing of Terrorism.
KYRON DIGITAL SA will do business and hire services from reputable and reputable third
parties, with adequate technical qualifications and who expressly undertake to adopt the
same zero tolerance policy regarding corruption.
In this line, the company establishes criteria to ensure that its Suppliers and\/or
Business Partners comply with the legislation and that they carry out adequate
controls. of form the restrain practices of Washing of Money \/ Financing of Terrorism.
The following precautions must be taken when hiring Suppliers or formalizing
business partnerships:
\u2713 Good business integrity background check.
\u2713 Certification regarding the intention of Suppliers\/Business Partners to use the financial
system for crimes of money laundering, financing of terrorist activities, drug
trafficking, arms trafficking and other criminal activities.
\u2713 Certification whether the potential business partner has an Executive Committee or
equivalent for matters related to AML\/CFT.
\u2713 Verification whether the Supplier or business partner has formalized AML\/CFT
Policies approved by the Board of Directors.
\u2713 Certification regarding the existence of Politically Exposed Persons (PEP) in the
management\/direction staff of Suppliers\/Business Partners.
\u2713 Verification whether the financial situation of the business partner or Supplier is
compatible with its activities and investments.
\u2713 Research the possible involvement of Suppliers\/Business Partners in media reports in
situations that may indicate Money Laundering, Terrorism Financing or other similar
offenses.
\u2713 Point of attention to be considered, observe whether the Supplier or Business Partner
offers any impediment to receiving a Know Your Supplier\/Business Partner visit (Due
Diligence) or resistance regarding providing requested information or scheduling
visits.
10. SEARCH REPUTATIONAL
THE search reputational of Suppliers, Partners of Business and customers and carried out
through third-party sources with a high level of notoriety among other companies in the
sector. If any unfavorable situation or conflict is identified in the initial contacts or research
reputational the information he must to be reported to the Director General – Responsible by
the PLD\/CFT for analysis and additional measures.
11. BANKS AND BANKS CORRESPONDENTS INTERNATIONAL
In cases of establishing commercial relations with banks and international correspondent
banks, the same rules and procedures will be adopted for the identification and acceptance
of correspondent banks, as well as the verification of their competent registration and
authorization with the competent regulatory body in their country, in order to prevent the
carrying out of business with untrustworthy institutions or those suspected of involvement
in illicit money laundering or terrorist financing activities.
12. TREATMENT OF OCCURRENCES AND SITUATION MONITORING ATYPICAL
Once the occurrence has been generated, without prejudice to applicable legal
communications, the responsibility for Compliance to analyze the register, to the
operations and transactions of customer. Verified the need, the Compliance may request
various provisions such as, the cadastral update and the order of clarification to the
Customer.
Cases not considered critical by the Compliance area or when there is no confirmed
evidence of money laundering are closed by archiving the incident.
All information dealing with indications\/suspicions of washing of money and combating
the financing of terrorism are confidential and should not, under any circumstances, be
made available to third parties.
KYRON DIGITAL SA will keep, in a safe and organized manner, for a minimum period of
5 (five) years , all records and documents relating to the identification and verification
of customers, final beneficiaries, operations carried out, suspicious operations reports
(ROS), due diligence records diligence and communications to the Financial Analysis
Unit (UAF) , as established in Article 30 of Law No. 23 of 2015 .
These records must be readily available to competent authorities upon formal request,
respecting the principles of confidentiality and integrity of information.
13. COMMUNICATION TO THE UAF
Atypical situations or situations that demonstrate signs of the occurrence of crimes
provided for in Law 23\/2015, or that may be related to them, will be communicated to the
UAF in the form analogous to obligated persons, including:
\u2713 Resistance to supply of information necessary for the beginning of relationship or to
the update cadastral, offering of information false or providing information that is
difficult or costly to verify; and
\u2713 Operations with evidence of washing of money and\/or financing of terrorism;
In compliance with Executive Decree No. 587 of 2015, KYRON DIGITAL SA adopts internal
procedures that ensure the ability to execute, immediately and without prior notice to the
client, the freezing of funds, assets or economic resources of individuals or entities listed by
the United Nations Security Council, or included in the UAF lists. The Compliance Officer will
be responsible for ensuring the prompt execution and reporting of these measures.
14. POLICY ANTI-CORRUPTION AND ANTI-BRIBERY
In sense wide, corruption he can to be understood as any act unrighteous what guard in
itself a deviation from institutional goals by a private individual in relationship the one
public agent or state entity. 4
KYRON DIGITAL SA has adopted this Anti-Corruption and Anti-Bribery Policy to comply
with the requirements and restrictions of the Panamanian Anti-Corruption Law, and too
much applicable the international level (US Foreign Corrupt Practices Act), the Anti-Bribery
Act of Kingdom United (UK Bribery Act) and other applicable anti-bribery laws in force
worldwide.
THE law define you acts harmful against the administration public as:
\u25cf Promise, offer or give, direct or indirectly, advantage undue the agent public or third
person related to it;
\u25cf Provenly, finance, to pay for, sponsor or of any mode subsidize the practice of the
illicit acts provided for;
\u25cf Provenly, use of interposed person physical or legal to hide or dissimulate your real
interests u the identity of the beneficiaries of the acts practiced;
\u25cf Hinder investigation or inspection activities by public bodies, entities or agents or
intervene in your performance, including node scope of the agencies regulatory and
of the supervisory bodies of the national financial system.
KYRON DIGITAL SA is committed to winning business through fair and honest
competition in the market. THE Accordance with this Policy anti-bribery and with their
respective guidelines is the responsibility of everyone in the KYRON DIGITAL SA .
KYRON DIGITAL SA will strictly follow the anti-bribery laws in force when conducting its
your business.
KYRON DIGITAL SA also he must to fulfill with the Law anti-bribery of Kingdom United
(\u201cAnti-Bribery Act\u201d) of 2010. The Anti-Bribery Act prohibits bribes to public officials and
companies and makes it a criminal offence to offer, promise or give a bribe (which, to you
For the purposes of this Anti-Bribery Policy, means a financial or other advantage);
soliciting, agreeing to receive, or accepting a bribe; or bribing a foreign public official.
In addition to the FCPA and the Anti-Bribery Act, the Company may be subject to other
anti-bribery laws around the world.
It is strictly prohibited to give or offer anything of value to a government official or
covered government official of any country in violation of anti-bribery law, or to make
illegal payments to third parties knowingly or having reason to do so. knowing that any
part will be offered, given or promised to a said official. Facilitation payments, which are
payments made to expedite or secure the performance of a routine government action,
are also prohibited.
Finally, this Policy prohibits promising, authorizing, offering, giving, accepting, or
soliciting any item of value or any other benefit to any third party, including customers,
prospective customers, suppliers, or other business partners, with the intent or
appearance of inappropriately influencing or rewarding the recipient’s business decisions.
15. ADMINISTRATION PUBLIC
Law Anti-corruption and Acts Harmful the Administration Public
KYRON DIGITAL SA does not adopt, encourage and\/or allow the practice of any conduct
that constitutes or results in acts that are harmful to the Administration. Public, national
or foreign, and other private companies, according to an exhaustive and non-explanatory
list:
\u2022 Promise, offer or give, direct or indirectly, advantage undue the agent public, or the third
person related to it;
\u2022 Finance, to pay for, sponsor or of any mode subsidize the practice of the unlawful
acts provided for in this law;
\u2022 Use of interposed person physical or legal to hide or to dissimulate your real interests
or the identity of the beneficiaries of the acts performed;
\u2022 Make it difficult activity of investigation or oversight of organs, entities or public agents
, or intervene in your performance, including node scope of the agencies regulatory and
of the supervisory bodies of the national financial system;
\u2022 Node touching the public procurement and contracts:
\u25cf THE KYRON DIGITAL SA no participate of public procurement; node
However, it has an internal policy prohibiting:
\u2022 To frustrate or defraud, by means of an arrangement, combination or any
other file, the competitive nature of public bidding procedures;
\u2022 Prevent, disturb or to defraud the realization of any act of public
bidding procedure;
\u2022 To move away or to search for to move away bidder, put quite of fraud
or offering of advantage of any kind;
\u2022 To defraud hiring public or contract her arising;
\u2022 Fraudulently or irregularly creating a legal entity to participate in
contracting public or enter into an administrative contract;
\u2022 Obtaining undue advantage or benefit, in a fraudulent manner, from
modifications or extensions of contracts entered into with the public
administration, without authorization by law, in the public bidding notice
or in the respective contractual instruments; or
\u2022 Manipulate or defraud the economic-financial balance of contracts
concluded with the public administration.
Interactions with Agents Audiences
Interactions between administrators, employees, as well as people who act as
representatives of KYRON DIGITAL SA , with public agents must occur in accordance with
guidelines established in internal regulations that govern the relationship with the Public
Administration.
Corruption Private
KYRON DIGITAL SA does not adopt, encourage and\/or allow the practice of any conduct
that constitutes the following acts: offering, promising, delivering or paying, directly or
indirectly, to a partner, director, administrator, employee or representative of a legal entity
under private law, undue advantage.
Likewise, the Administrators, potential employees, interns of KYRON DIGITAL SA must
not accept undue advantages.
Contributions, Donations and Sponsorships the Candidates the Positions Audiences or
Parties Politicians
KYRON DIGITAL SA no contributes, direct or indirectly, it is put intermediate of donation
or loan of goods, use or transfer of physical space or advertising, sponsorship of events,
provision of labor and\/or any other resource, leafleting, sending electronic messages,
posting posters, or of any other form, to campaigns policies, political parties, candidates for
public office or any other type of organization that carries out political activity.
Although donations by individuals are not prohibited by law, KYRON DIGITAL SA and
their legal representatives refrain from making personal donations to electoral campaigns,
including to those within their circle of economic dependence.
Application the Positions Politicians
Employees who run for political office must step away from their activities at the Company,
without the right to remuneration, during the period between the registration of their
candidacy with the Electoral Court and the day following the election.
Acceptance and Offering of Courtesies
KYRON DIGITAL SA is against the direct and indirect acceptance and offering of courtesies
that may affect decisions, facilitate business or benefit third parties.
Among other prohibitions, the acceptance or offering of courtesies involving Public
Administration bodies or employees is prohibited.
Restructuring Corporate
During any merger and acquisition process, of which KYRON DIGITAL SA participate, due
diligence must be carried out on the target company in order to ensure, among other
aspects, compliance with the requirements of the Anti-Corruption legislation. The purchase
and sale or other document that has the same purpose as this one contract he must contain
clauses specific anti-corruption measures and, in the case of mergers and incorporations, it
must be stated that the transferee is responsible for acts and facts that occurred before the
date of the merger or incorporation, except node case of simulation or evident intention of
fraud, duly proven.
Any violation identified in the merger and acquisition process must be reported and
recorded to the competent management.
Management of Risk of Corruption
KYRON DIGITAL SA has a methodology that provides support to (a) identify, (b) assess,
(c) mitigate, (d) monitor and (e) report exposure to the risk of corruption for
communication, assessment and deliberation by the Company’s competent corporate
governance bodies, according to the respective area of activity, as well as to regulatory
bodies.
Encouragement of reporting acts that are harmful to the Public Administration and acts of
private corruption, committed by employees and administrators of KYRON DIGITAL SA
and other stakeholders of this Policy.
Whenever possible and with the best diligence, KYRON DIGITAL SA will seek to
individualize and particularize the conduct that may be classified as a crime punishable in
accordance with current legislation, informing and collaborating with the competent
authorities for the complete investigation and accountability of the individuals who commit
them.
In the event that Administrators and\/or employees are involved in investigations into acts
of corruption, any applicable measures, such as removal, will be assessed and deliberated
upon by the Company’s governance bodies, according to the applicable jurisdiction.
Training
All employees, interns and administrators of KYRON DIGITAL SA must undertake
mandatory annual training on Prevention of Money Laundering and Financing of Terrorism
(PLD\/FT), whose participation will be documented through an attendance list and learning
assessment. The Compliance area will maintain control over the trainings carried out, their
dates and contents, as required by UAF good practices.
16. PROVISIONS GENERAL
This is a document for internal use and may, in certain cases, be made available to third
parties subject to approval by the Compliance team. It must be sent exclusively in physical
form or digitally in duly protected \u201cPDF\u201d format.
KYRON DIGITAL SA . maintains a confidential and secure internal reporting channel,
accessible to employees, partners and third parties, intended for reporting suspected
illegal acts, such as money laundering, terrorist financing or corruption. The channel
guarantees confidentiality, non-retaliation and will be monitored by the Compliance area.
UPDATE FROM THE POLICY
The update of this Policy should occur whenever there are substantial changes in
procedures or regulations that affect the topic or are applicable, and it is the responsibility
of the Compliance area, with the support of its legal advisor, to monitor legal and
institutional innovations.
17. CONSIDERATIONS FINALS
Lack of knowledge regarding any of the obligations and commitments arising from this
document does not justify deviations. Therefore, in case of doubts or need for additional
clarification regarding its content, please consult the Compliance area.
Failure to comply with the provisions of this document or other related documents may
result in disciplinary, administrative or legal measures, which may lead to dismissal,
reporting to the competent authorities or other sanctions, including those arising from
applicable legislation, self-regulation or regulations.
KYRON DIGITAL SA undertakes to cooperate fully with government agencies and
banking institutions in order to optimize their systems, enabling them to detect, prevent
and combat activities related to the topics covered, so as not to be inadvertently used as
an intermediary in any process tending towards Money Laundering or financing of
terrorism.
ANNEX I \u2013 VERSION CONTROL
Review Date Responsible Summary of Changes Version
01\/04\/2025 Compliance Officer \/
Legal Advisor
Preparation of the
document.
v1.1<\/p>\n
[\/et_pb_text][\/et_pb_column][\/et_pb_row][et_pb_row _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content”][et_pb_column _builder_version=”4.27.4″ _module_preset=”default” type=”4_4″ theme_builder_area=”post_content”][et_pb_button button_text=”RETURN TO HOMEPAGE” _builder_version=”4.27.4″ _module_preset=”default” theme_builder_area=”post_content” button_url=”https:\/\/kyron.com.pa\/us” hover_enabled=”0″ sticky_enabled=”0″][\/et_pb_button][\/et_pb_column][\/et_pb_row][\/et_pb_section]<\/p>\n","protected":false},"excerpt":{"rendered":"
MONEY LAUNDERING PREVENTION POLICIES AND FIGHTTO THE FINANCING OF TERRORISMKYRON DIGITAL SAPRIVATE INTERNAL POLICYAND CONFIDENTIALType : POLICYTitle of document \/ Matters: Prevention of Fight the Washing Moneyand Terrorism Financing and Policy Antibriberyand Anti-CorruptionArea Responsible: Risk & ComplianceLast update: 01\/04\/2025INDEX1. INTRODUCTION AND SCOPE ………………………………………………………………………………………………………… 32. CONCEPT OF WASHING OF MONEY ……………………………………………………………………………………………… 33. FINANCING TO THE TERRORISM […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_et_pb_use_builder":"on","_et_pb_old_content":"","_et_gb_content_width":"","footnotes":""},"class_list":["post-170","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/pages\/170","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/comments?post=170"}],"version-history":[{"count":5,"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/pages\/170\/revisions"}],"predecessor-version":[{"id":177,"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/pages\/170\/revisions\/177"}],"wp:attachment":[{"href":"https:\/\/kyron.com.pa\/us\/wp-json\/wp\/v2\/media?parent=170"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}