Prevention and Control of Money Laundering and Terrorist Financing

Sivensa established a set of regulatory aspects that have been grouped into the Sivensa Code of Ethics. This Code sends a clear message to all employees that the company’s fundamental mission is to achieve its goals by promoting the values ​​of ethics, dignity, and honesty among its employees, and rejecting any possibility of achieving results at the cost of violating current legal regulations or internal company rules.

Sivensa, following the guidelines established in its Code of Ethics and in compliance with the provisions of Providencia No. 025 of the National Superintendence of Securities, dated March 17, 2025, published in Official Gazette No. 43,096 of March 27, 2025, which establishes the “Rules related to the administration and supervision of risks related to the crimes of money laundering, terrorist financing, financing of the proliferation of weapons of mass destruction and other illicit acts, applicable to subjects Obliged by the National Superintendence of Securities”, has implemented a Comprehensive Risk Management System for Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction (“SIAR LC/FT/FPADM” for its ____ in spanish), which includes policies, programs, manuals, standards, procedures, structures, plans and strategies, aimed at identifying, measuring, evaluating, monitoring and applying corrective measures, have been implemented to reduce the possibility that Sivensa may be used as a means to conceal the origin, purpose and destination of illicit funds in any transaction. This Comprehensive System establishes the functions of the company’s board of directors and president, as well as the appointment of a compliance officer.

Likewise, as part of the measures implemented in this area, Sivensa has designed and approved the Policies, Standards, and Procedures Manual for LC/FT/FPADM Risk Management, the Annual AR/ LC/FT/FPADM Operating Plan, and the Annual AR/ML/TF/FPADM Training and Capacity Building Program, as part of the tools to prevent the risk arising from LC/FT/FPADM and other related offenses, which are fully implemented. These tools are periodically reviewed and updated to adapt them to regulatory changes and the regulations governing the matter.

Compliance with the “Know Your Shareholder” policy is of great importance to Sivensa. Therefore, in strict compliance with the Securities Market Law, the Company has hired the services of a financial institution to act as a Transfer Agent. This institution maintains up-to-date information to identify and identify the shareholder, determine their financial profile, the economic activities they engage in, the rank in which they frequently work, the transactions they carry out, or any other criteria that allow for the timely identification of transactions that the Transfer Agent considers unusual or suspicious.

The Transfer Agent establishes individual records for each of its shareholders, applying a risk-based approach, to collect, record, and maintain up-to-date information, reliably determine their identification, and verify their identity from the moment the shareholder joins the company.

Sivensa fosters secure business relationships with its suppliers and, in turn, safeguards its reputation as an institution, in compliance with existing Venezuelan legal regulations regarding LC/FT/FPADM Risk Management and Control. This policy is implemented to ensure a proper understanding of the business relationship with the supplier, fully identify the service provider, verify their identity and data provided, determine the specific economic activity and its beneficial owners, and determine the supplier’s financial profile.

Sivensa establishes individual records, reviews, and annual updates for each of its suppliers, applying a risk-based approach to collect, record, and maintain up-to-date information, and reliably determine their identification and verification for the duration of the business relationship with the supplier.

Information that individuals, legal entities, and cooperative associations must provide when joining or updating their data with Sivensa´s Tranfer Agent:

1. Valid Identity Card (ID), for Venezuelans and foreign residents, or a copy of a passport for non-resident foreigners.
2. Valid Tax Information Registry (RIF).
3. One (1) Bank Reference, valid for at least three months.
4. Proof of current employment of the investor, or an income attestation report issued by a certified public accountant, for individuals who work independently.
5. Affidavit of Origin and Destination of Funds, each time a transaction is carried out.

1. Valid Tax Information Registry (RIF).
2. Valid Identity Card and Tax Information Registry (RIF) of the legal representative of the legal entity.
3. Articles of Incorporation and any statutory amendments of the legal entity, showing the ultimate beneficial owners of the company. In the case of a legal entity not domiciled in the country, the same documents must be duly notarized and translated into Spanish.
4. Minutes of the meeting evidencing the election of the current board of directors, without their term having expired.
5. One (1) Bank Reference, valid for at least three months.
6. Affidavit of Origin and Purpose of Funds, each time a transaction is carried out.

A legal entity that owns another legal entity among its shareholders or partners must provide the shareholding structure. If these, in turn, have the same shareholding structure, all the information will be detailed thereafter, until the final beneficiary of said legal entity is determined.

Some basic concepts and the legal framework related to money laundering, terrorist financing, and financing the proliferation of weapons of mass destruction are detailed below:

Definition: Money laundering is the process of hiding or disguising the existence, origin, movement, destination, or use of illicit assets or funds, to make them appear to be derived from a legitimate activity.

Stages: Money laundering is carried out in three stages:

a) Placement: During this initial stage of money laundering, illegal proceeds are introduced into the financial system. In most cases, this stage is accompanied by the placement of funds into circulation through financial institutions, casinos, businesses, currency exchange offices, and other businesses, both nationally and internationally.

 b) Processing: Diversification of funds into different financial products and services to confuse and give the appearance of commercial transactions.

 c) Integration: At this stage, these illicit funds are formally incorporated into the legal economic system, appearing to be of legitimate origin or source.

Money laundering is also known in other jurisdictions as:

1. Money Laundering
2. Money Laundering
3. Asset Laundering
4. Dirty Money Recycling
5. Illicit Capital Laundering
6. Money Laundering

Definition: Terrorist financing is the use of legal or illicit funds for the following purposes: belonging to, financing, acting, or collaborating with armed gangs or organized crime groups with the purpose of causing havoc, catastrophes, fires, or detonating explosive devices; it also involves subverting the constitutional order and democratic institutions; or seriously disturbing public peace.

Venezuelan Legal Framework Regulating Money Laundering and Terrorist Financing

a) Organic Law Against Organized Crime and Terrorist Financing (LOCDOFT)

 b) Organic Law on Drugs

 c) Regulations on the Administration and Oversight of Risks Related to Money Laundering, Terrorist Financing, and Financing the Proliferation of Weapons of Mass Destruction Applicable to Institutions Obligated by the National Securities Superintendency (Resolution 025-2025)