PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM POLICY (AML/CFT)

D Empreendimentos LTDA

Plataforma DFY

Versão Public

Ano 2025

1. Objective

This Prevention of Money Laundering and Financing of Terrorism Policy (AML/CFT) aims to establish principles, guidelines, and procedures adopted by DFY, a technological platform operated by D Empreendimentos LTDA, to prevent, identify, monitor, and mitigate risks related to money laundering, financing of terrorism, and other illicit practices.

This Policy aims to ensure that the use of DFY's technological infrastructure occurs in an integral, transparent manner and in compliance with current legislation, preserving the security of the operating environment, institutional reputation, and platform reliability.

2. Scope

This Policy applies to all employees, administrators, directors, users, operational partners, technology partners, suppliers, service providers, and any third parties who, directly or indirectly, have access to the DFY platform, its systems, data, or operational information.

It covers all operations of registration, management, monitoring, reconciliation, and tracking of collections carried out through the DFY platform, regardless of the nature of the underlying payment obligation, the origin of which is external to the platform.

3. Definitions

For the purposes of this Policy, the following definitions apply:

Money Laundering a set of operations intended to conceal, disguise, or integrate into the formal economy amounts resulting, directly or indirectly, from illicit activities.

Financing of Terrorism acts intended to provide, directly or indirectly, resources, assets, or means for the practice of terrorist acts, as defined in applicable legislation.

AML/CFT a set of measures, controls, and procedures adopted for the prevention, detection, and mitigation of risks related to money laundering and the financing of terrorism.

User a natural or legal person registered and authorized to use the DFY platform.

Operations records, movements, and flows related to collection management carried out through the DFY platform.

COAF Council for Financial Activities Control, the body responsible for receiving and analyzing communications of suspicious operations, under Law No. 9.613/1998.

4. Principles and Guidelines

DFY guides its AML/CFT practices by the following principles:

Preventive and risk-based action, proportional to the nature and profile of operations performed;

Strict observance of current legislation and applicable standards;

Promotion of high standards of ethics, integrity, transparency, and responsibility;

Preservation of confidentiality and information security;

Dissemination of the culture of prevention of money laundering and financing of terrorism;

Adoption of controls compatible with the platform's operational model.

5. Governance Structure and Responsibilities

The Senior Management of D Empreendimentos LTDA is responsible for approving this Policy, ensuring adequate resources for its implementation, and promoting a culture of compliance and integrity.

The Compliance area is responsible for implementing, maintaining, and reviewing this Policy, monitoring the effectiveness of internal controls, analyzing atypical operations and behaviors, maintaining records and evidence, promoting training, and communicating suspicious operations to competent authorities when required by law.

All employees, partners, suppliers, and service providers must fully comply with this Policy, report evidence of irregularities, cooperate with internal and external investigations, and act ethically and diligently.

6. Risk Assessment and Management

DFY adopts a risk-based approach to the prevention of money laundering and financing of terrorism, considering, among other factors, the user profile, the nature of recorded operations, the frequency and pattern of movements, operational and technological risks, and geographic exposure.

Risk assessment is carried out continuously and reviewed periodically or whenever there are relevant changes in the platform's operational model.

7. Identification and Monitoring

Users of the DFY platform are subject to identification, registration validation, and continuous monitoring procedures, in accordance with internal KYC, KYP, KYS, and KYE policies, with a focus on fraud prevention and misuse of technological infrastructure.

DFY continuously monitors operations recorded on the platform with the aim of identifying atypical patterns, incompatible use with the platform's purpose, attempts to conceal or disguise amounts, and practices that may indicate irregularities.

8. Communication of Suspicious Operations

When indications or suspicions of practices related to money laundering or financing of terrorism are identified, DFY will adopt appropriate measures, including detailed internal analysis, recording and documentation of evidence, and communication to competent bodies, under applicable legislation, especially COAF.

9. Training and Awareness

DFY promotes periodic training and awareness actions aimed at preventing money laundering and financing of terrorism, directed at employees, partners, and other relevant audiences, compatible with their functions and access levels.

10. Recording and Keeping Information

Information, records, and documents related to AML/CFT procedures are maintained securely, integrally, and traceably for the minimum period required by current legislation, ensuring confidentiality, availability, and support for audits and inspections.

11. Final Provisions

Failure to comply with this Policy may result in the adoption of applicable administrative, contractual, and legal measures, depending on the severity of the infraction and applicable legislation.

This Policy comes into force on the date of its approval and must be reviewed periodically or whenever there are relevant changes in the operational, technological, or regulatory environment of DFY.

Last updated 01/10/2026

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