Anti-Money Laundering Policy

Money Laundering is the generic term used to describe the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to have derived from a legitimate source.

Terrorism Financing refers to activities which involves the solicitation, collection and the providing of funds and other assets with the intention that it may be used to support terrorist acts, terrorist organisations or individual terrorists.

Managing money laundering risks requires robust controls that must also be implemented to manage any risks associated with the financing of terrorism.

The requirements set out in this policy apply to RN Bullion and define the responsibilities and accountabilities for the Entity.

The implementation of this policy will be proportionate to the nature, scale and complexity of each of the various Companies. The principle of proportionality is of particular importance to ensure the consistent application of the policy whilst ensuring a fair and balanced approach to implementation. Proportionality is broadly defined with reference to the following measures:

• Nature – The specific nature of RN Bullion's activities including, for example, types of lines of business and the number of lines of business;

• Scale – The size of RN Bullion's business activities including for example gross premium and maximum risk retention;

• Complexity – The complexity of RN Bullion's business and its activities including the business and distribution model, governance structures, product design, number of lines of business and special or alternative risk transfer activities.

This Policy applies to all RN Bullion employees, contractors, partners, vendors, intermediaries and non-compliance to the policy may lead to disciplinary, regulatory, criminal and civil proceedings. The RN Bullion Compliance Regulatory Non-Compliance process must follow when there has been an infringement of FICA or RN Bullion's Prevention of Money Laundering and the Combatting of the Financing of Terrorism Policy.

The implementation, accountabilities, roles and responsibilities in terms of this policy will be applied in terms of the three lines of defense as outlined in the Enterprise Risk Management (ERM) Framework.

3. LEGAL AND COMPLIANCE APPETITE STATEMENT

RN Bullion is committed to avoid the risk of non-compliance to regulatory obligations. The RN Bullion Board and Senior Management is committed to conducting the business affairs of RN Bullion in an ethically and legally compliant manner with due regard of our responsibilities towards our customers, shareholders, regulators and the environment in which we operate. RN Bullion will not knowingly engage in any transaction, product development or initiative or design or implement any procedure or control that will result in a non-compliance.

4. POLICY FORMULATION

The principles and objectives of the RN Bullion Prevention of Money Laundering and the Combatting of the Financing of Terrorism Policy will be supported by several policies, standards, procedures and other documentation adopted throughout RN Bullion, as well as relevant regulatory and compliance frameworks.

5. ANTI MONEY LAUNDERING AND COUNTER TERRORISM FINANCING LEGAL AND REGULATORY FRAMEWORK

The Financial Action Task Force (“FATF”), an independent inter-governmental body develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.

The FATF Recommendations are taken into account in South Africa in developing a comprehensive framework or measures to combat money laundering and terrorist financing as well as the financing of proliferation of weapons of mass destruct