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KYC / KYP / KYS / KYE POLICY MANUAL

BaaS Platform for Collection Account Management

D Empreendimentos LTDA

Plataforma DFY

Versão 1.0

Ano 2025

1. Introduction

The purpose of this Manual is to formalize, discipline, and standardize the guidelines, procedures, and criteria adopted by DFY, a technological platform operated by D Empreendimentos LTDA, for the identification, verification, validation, and monitoring of its strategic audiences, in accordance with the principles of Know Your Client (KYC), Know Your Partner (KYP), Know Your Supplier (KYS), and Know Your Employee (KYE).

DFY operates as a technological platform in the Banking as a Service (BaaS) model, exclusively focused on the management of collection accounts, registration, tracking, reconciliation, and monitoring of flows arising from collections related to payment obligations previously established outside the platform environment.

This Manual is part of DFY's set of internal regulations and must be mandatorily observed by all operational and administrative areas, employees, partners, suppliers, and service providers who have direct or indirect access to the platform, in addition to the Terms of Use, the Policy for Prevention of Money Laundering and Financing of Terrorism (AML/CFT), the Information Security Policy, and the Code of Ethics and Conduct.

2. General Objective and Specific Objectives

2.1 General Objective

To establish criteria and procedures designed to ensure the adequate identification, validation, and continuous monitoring of DFY users, partners, suppliers, and employees, focusing on the prevention of fraud, misuse of technological infrastructure, operational risks, legal risks, reputational risks, and other situations incompatible with the platform's purpose.

2.2 Specific Objectives

Ensure the correct identification and qualification of platform users;

Ensure the integrity, consistency, and updating of registration information;

Preserve the traceability of operations carried out on the platform;

Prevent the use of technological infrastructure for illicit purposes or incompatible with its purpose;

Align internal procedures with AML/CFT guidelines, GDPR (LGPD), and other applicable regulations;

Strengthen the culture of compliance, integrity, and information security.

3. Scope

This Manual applies to all identification, due diligence, and monitoring processes adopted by DFY, covering the following audiences:

Platform Users (KYC);

Operational and technological partners (KYP);

Suppliers and service providers (KYS);

Employees, representatives, and authorized third parties (KYE).

4. Definitions

4.1 KYC – Know Your Client

A set of procedures designed for the identification, validation, and monitoring of DFY platform users, aiming to ensure that access and use of the technological infrastructure occur in a lawful, secure manner compatible with internal policies, the Terms of Use, and applicable legislation.

The KYC process is identifying, preventive, and operational in nature, limited to identity verification, registration integrity, fraud prevention, misuse of the platform, and adherence to internal guidelines, not implying validation of payment obligations registered by the User.

4.2 KYP – Know Your Partner

A set of procedures applicable to the identification, verification, and due diligence of commercial, technological, or operational partners who use, integrate with, or act jointly with the DFY platform, including:

Documentary and registration verification;

Reputational analysis and institutional history;

Compatibility of the business model with the platform's purpose;

Assessment of operational, legal, technological, and compliance risks.

4.3 KYS – Know Your Supplier

Procedures designed for the identification, verification, and validation of suppliers and service providers who maintain a relationship with DFY and who have direct or indirect access to data, systems, infrastructure, or sensitive information, observing criteria of legality, integrity, confidentiality, and regulatory compliance.

4.4 KYE – Know Your Employee

A set of procedures applicable to the identification, verification, follow-up, and monitoring of employees, representatives, and authorized third parties of DFY, especially those who have access to sensitive data, critical systems, restricted environments, or strategic functions.

5. Rules and Registration Flow – KYC

5.1 Initial Registration

Access to the DFY platform begins through electronic registration, in which the User provides personal or corporate information necessary for their identification, including registration data, official documents, contact information, and other elements required by internal policies.

The registration is exclusively identifying and operational in nature, not generating recognition, validation, or guarantee regarding registered payment obligations, nor interfering in the legal relationship existing between the User and third parties.

5.2 Registration Validation

The information provided may be subject to internal validation procedures, including, where applicable:

Document conference;

Anti-fraud verification;

Consultation of public and private databases;

Analysis of registration consistency and coherence.

5.3 Continuous Monitoring

After approval of the registration, the User will be subject to continuous monitoring, according to the operational profile and internal risk criteria, and updates to registration and additional information may be requested at any time.

6. Registration Update

The User is responsible for keeping their registration data updated. DFY may request periodic or occasional reviews, aiming to ensure compliance with internal policies, current legislation, and AML/CFT guidelines.

Failure to update or the identification of relevant inconsistencies may result in operational restrictions, suspension, or termination of access to the platform.

7. Responsibilities

7.1 Users

User responsibilities include:

Ensuring the veracity, integrity, and updating of the information provided;

Using the platform in a lawful manner compatible with its purpose;

Answering for the legality, legitimacy, and documentation of registered payment obligations;

Cooperating with validation and audit requests.

7.2 DFY

It is incumbent upon DFY to:

Implement and maintain the procedures provided for in this Manual;

Promote internal controls for identification and monitoring;

Preserve the security, confidentiality, and integrity of information;

Adopt preventive and corrective measures in the face of identified risks.

7.3 Partners, Suppliers, and Employees

Must fully comply with the guidelines established in this Manual, as well as other internal regulations of DFY, acting ethically, diligently, and compatibly with their responsibilities.

8. Integration with AML/CFT

The procedures described in this Manual are fully aligned with DFY's Policy for Prevention of Money Laundering and Financing of Terrorism, observing monitoring practices, analysis of atypical patterns, recording of evidence, and adoption of internal risk mitigation measures, as applicable.

9. Final Provisions

Failure to comply with the guidelines provided for in this Manual may result in the adoption of administrative measures, operational restrictions, suspension or cancellation of access to the platform, contract termination, and other appropriate measures, depending on the severity of the violation and current legislation.

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