AML POLICY OF BETONRED.COM WEBSITE OPERATED BY UNO DIGITAL MEDIA B.V.

CRIME AND DISRUPTIVE ACTIVITIES (INCLUDING FRAUD AND AML)

1. EXPERIENCE

1.1. Uno Digital Media B.V. (hereinafter – the “Company”) has many years of experience in protecting gambling businesses against criminal abuse and in developing extensive procedures and processes aimed at preventing fraud and money laundering, as well as implementing comprehensive employee training programs.

1.2. The basis of future training is knowledge of the legislation concerning obtaining financial benefits from criminal activity and identifying money laundering indicators typical for the gaming environment, especially in the transactional Card Not Present model.

1.3. The Director has full knowledge of all elements of the legislation on obtaining proceeds of crime and of their obligations in this area. The Director is also well prepared to provide information on AML measures and standards applied in leading remote and land-based gambling companies.

2. ANTI-MONEY LAUNDERING AND TRANSACTION FRAUD PREVENTION

2.1. The gambling industry often becomes a target for individuals attempting to launder funds derived from illegal activities. Transaction dynamics and numerous payment processing methods make gambling companies particularly vulnerable to such practices.

2.2. Therefore, many initial business and procedural decisions are directly focused on mitigating this risk. At the same time, safeguards resulting from the overall commercial strategy adopted by the Company are strengthened.

2.3. ALL employees will be trained in preventing and recognizing signals that may indicate money laundering, including but not limited to:

2.3.1. non-standard betting patterns,

2.3.2. suspicious deposit and withdrawal patterns (both in terms of frequency and amounts),

2.3.3. questionable credibility of payment card data,

2.3.4. difficulties in customer verification and cases of identity theft,

2.3.5. linked accounts or multiple postings.

2.4. All potentially suspicious attempts at money laundering must be reported to the MLRO. Information about such suspicion must not be disclosed to the customer, and any further actions require authorization. The MLRO is responsible for cooperation with relevant authorities and for submitting suspicious activity reports, as well as for maintaining appropriate records.

2.5. The Company applies a FULL KYC (“Know Your Customer”) policy. This serves as a tool not only in combating money laundering, but also in limiting other forms of fraud. Customers will be informed during registration and on a dedicated non-transactional page that the Company uses online verification tools and that, if it is not possible to confirm the data, it will be necessary to provide documents relating to identity and address.

2.6. Key measures strengthening security include arrangements regarding limits on the speed and frequency of withdrawals. The Company requires director approval for card or bank transfer withdrawals exceeding 5000 AUD in a single transaction, as well as a limit of a maximum of 3 withdrawals per day and a daily limit of 15000 AUD.

2.7. Industry standards indicate that amounts exceeding 5000 AUD within a 24-hour period and 15000 AUD within a 90-day period require enhanced due diligence, including the provision of additional documents confirming identity and address. In such cases, basic online verification will NOT be accepted.

2.8. The Company does not handle cash, which significantly reduces the risk associated with the circulation of counterfeit funds.

2.9. Systems record a full history of transactions on accounts. Account reviews will be conducted regularly and on an ongoing basis for indicators of fraud and social responsibility. If unusual betting or winning patterns are detected, they will be cross-checked with connection histories to ensure that there is no collusion between staff and customers.

2.10. The Company will maintain a register of customers classified as high risk or politically exposed persons (PEP). These accounts will be subject to detailed and more frequent monitoring.

2.11. In the event that unlawful or improper actions by staff are detected, investigative and disciplinary procedures will be implemented in accordance with applicable contracts and labor law requirements. In situations such as suspected transaction fraud, measures such as suspension may be applied. These activities form an integral part of the employee’s scope of duties.

3. SECURITY AND MONITORING

3.1. In every gambling enterprise, it is necessary to implement appropriate monitoring procedures relating to premises, equipment, personnel, communications, and transactions. The Company will apply a range of measures and procedures to ensure security in these areas.

3.2. The Company has implemented call recording technology. This solution allows, among other things, for:

3.2.1. employee training,

3.2.2. ensuring precise confirmation of bets (time and place) and transaction data,

3.2.3. protection of customer and brand reputation,

3.2.4. implementation of frequent and effective monitoring procedures preventing collusion between staff and customers.

3.3. Data protection and the security of hardware and software are key areas for any enterprise operating in a Non-Face to Face transaction environment. The Company will implement the principle “Encrypt everything that can be encrypted”. Access to shared resources will be strictly controlled, monitored, and properly protected by passwords. Appropriate procedures for data storage and backups are also implemented, preventing data loss and access by third parties.

4. RESPONSIBLE RELATIONS WITH CUSTOMERS AND COMPANIES

4.1. The Company will publish the Terms and Conditions on the website together with the KYC and AML rules. These documents will explicitly refer to dishonest activities, prior knowledge of event outcomes, match fixing, and suspicious events. They will include a detailed description of possible actions in the event of suspicion or detection of fraud, as well as the scope of cooperation with regulatory and sports authorities. This will ensure transparent communication with customers.

4.2. The Director acknowledges, however, that in cases of suspicion or confirmation of serious criminal activity, employees and management are obliged not to inform customers and to conduct actions in a manner that does not compromise the investigation. Appropriate training and escalation procedures will be implemented.

4.3. The Company will take all necessary actions to maintain proper relations with other entities. This will include standard due diligence procedures, often supported by confidentiality agreements. As part of such cooperation, disclosure of ownership and management structure, incorporation data, address details, and contact information will be required. The results of analyses will be prepared according to an established template and archived.