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OVERVIEW OF THE COMPANY'S REGULATORY AND COMPLIANCE PROCEDURES

At Tacticum, we carry out regulatory watch to ensure that the company complies with the various laws specific to the financial sector. Though the company is a non-regulated entity, this does not exempt it from following and applying internal (Luxembourg and European Union) and external (United States and United Kingdom) regulations. As our work involves investments and transactions at a global level, we ensure that we comply with all existing regulations and that we are always up to date with new regulations.

 

Company’s Anti-Money Laundering policy and General Data Protection Regulation

 

The Company has put in place a monitoring procedure to ensure that team members comply with various compliance requirements. One of these procedures is the Anti-Money Laundering (“AML”) procedure, which has been put in place to ensure that the company complies with Luxembourg laws in the framework of the fight against money laundering and the financing of terrorism. In addition to compliance, we have also put in place the internal General Data Protection Regulation (“GDPR”) policy which was created to formalize the internal GDPR policy.

Anti-Money Laundering policy  For each business relationship that the company enters into with other companies, we assess the risk associated with AML/CFT, as well as the risks to which we are exposed. We consider not only transactional and geographical risks, but also all relevant applicable risk factors. Before entering into a transaction involving a non-listed financial security or non-listed financial entity, our management carries out an analysis based on the risk approach. We also gather information on third parties as soon as a transaction is contemplated in order to ensure the best interests of the company. We also collect the necessary information from the company's beneficial owners, send this information to the Luxembourg register of commercial companies and the register of beneficial owners (“RBE”), keep this information up to date and maintain an up-to-date file of beneficial owners. All this information is recorded in the company's KYC files. In addition, as part of our banking relationship, we provide to our banks information relating to our corporate entity, such as the extract from the register of companies and other information relating to our shareholders, beneficial owners and directors of the company.  This helps us to reassure our banks that we are a company that complies effectively with European anti-money laundering and anti-terrorist financing laws. Overall, we have put in an AML procedure based on Luxembourg laws and regulations to mitigate any risk of involvement in the money laundering and financing-terrorism. Therefore, in order to keep up to date with all AML updates, the company organizes regular training programmes for the entire team.

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Tacticum Investments S.A.

T. +352 271 772 30

E. info.lu@t-investments.lu

51, Blvd. Grande-Duchesse Charlotte

L-1330, Luxembourg

Disclaimer: This website has been prepared for purposes of presentation, only. The information contained herein should not be used or considered as an offer to sell, or solicitation of an offer to buy any security, under no circumstances. The content may not be reproduced or circulated in whole or in part, and it is in summary form for convenience of presentation, it is not complete, and it should not be relied upon in the form it is presented. All information, including performance information, has been prepared in good faith; however, Tacticum Investments S.A. makes no representation or warranty express or implied, as to the accuracy or completeness of the information, and nothing on this website shall be considered as a promise or representation as to past or future performance. This material may include information that is based, in part or in full, on hypothetical assumptions, models and/or other analysis of Tacticum Investments S.A., analysts, consultants and no representation or warranty is made as to the reliability of any such assumptions, models or analysis. Everything that relates, including numbers and charts, to a portfolio or Equity Portfolio, is a sample selection of projects and assets that results from the analysis performed by Tacticum Investments S.A. and it does not include any consideration to be built at a later stage during the final due diligence process that might reveal relevant additional information used for further choice. The information discussed in this presentation was gathered from various sources which Tacticum Investments S.A. believes, but does not guarantee, to be reliable. Unless stated otherwise, any opinions expressed herein are current as of the date hereof and are subject to change at any time. All sources which have not been otherwise credited have derived from Tacticum Investments S.A.

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