Anti-Money Laundering & Counter-Terrorist Financing Policy

This Policy is maintained in accordance with:

• the Financial Intelligence Centre Act No. 46 of 2010 (as amended) and regulations made under it;
• the Prohibition and Prevention of Money Laundering Act No. 14 of 2001 (as amended);
• the National Payment Systems Act and applicable Bank of Zambia directives on mobile money; and
• United Nations Security Council sanctions measures given effect in Zambian law.

This Policy applies to all Lupasphere employees, directors, and contractors; to all users of our Services (buyers, sellers, and delivery riders); and to all transactions and value moving across the platform — including order payments, escrow settlements, seller payouts, rider commissions and float, and refunds.

• Money laundering — disguising the origin of proceeds of crime so they appear legitimate.
• Terrorist financing — providing or collecting funds intended to carry out terrorist acts.
• Customer Due Diligence (CDD) — identifying and verifying a user and assessing the risk they present.
• Politically Exposed Person (PEP) — an individual entrusted with a prominent public function, and their close associates and family.
• Suspicious Transaction Report (STR) — a report filed with the Financial Intelligence Centre where money laundering or terrorist financing is suspected.
• MLRO — the Money Laundering Reporting Officer appointed by Lupasphere.

We assess and manage risk in proportion to the threat presented. Higher-risk indicators include:

• large or unusually frequent transactions inconsistent with a user's profile;
• new sellers receiving high transaction volumes shortly after registration;
• mismatches between account identity and the mobile money account holder;
• transactions structured to fall just below reporting thresholds;
• requests to settle off-platform or to circumvent escrow; and
• users appearing on, or linked to, sanctions or PEP lists.

Risk ratings determine the level of due diligence, monitoring frequency, and approval required.

• Tier 1 — Buyers: verified name, phone number, and mobile money account used at checkout.
• Tier 2 — Sellers: Tier 1 plus National Registration Card (NRC) or passport, selfie/liveness match, business address, and settlement mobile money number.
• Tier 3 — Riders: Tier 1 plus NRC, selfie/liveness match, and float settlement account.
• Enhanced Due Diligence: for high-risk users, PEPs, and high-volume sellers — all of the above plus a source-of-funds declaration and MLRO sign-off before payout limits are raised.

We do not allow anonymous accounts. Accounts that fail verification cannot receive payouts.

We monitor transactions on an ongoing basis. Activity is reviewed where it meets defined value or velocity thresholds, or matches any high-risk indicator above, regardless of amount. Flagged activity is escalated to the MLRO, who decides whether to clear, restrict, or report it.

Where we know or suspect that funds are the proceeds of crime or relate to terrorist financing:

• staff report the concern internally to the MLRO without delay;
• the MLRO, where suspicion is confirmed, files an STR with the Financial Intelligence Centre within the period required by law;
• we do not "tip off" the user that a report has been or may be made; and
• affected funds may be held pending guidance from the FIC or law enforcement.

• We screen users against applicable sanctions lists at onboarding and periodically thereafter.
• A confirmed sanctions match results in account suspension and freezing of associated funds.
• PEP matches trigger Enhanced Due Diligence and senior-management approval before high-value activity is permitted.

We retain identity, verification, and transaction records for at least ten (10) years from the end of the business relationship or the date of the transaction, whichever is later, as required under the Financial Intelligence Centre Act. Records are stored securely and made available to competent authorities on lawful request.

Lupasphere appoints a Money Laundering Reporting Officer responsible for maintaining this Policy and our AML/CTF controls, receiving and assessing internal suspicion reports, filing STRs with the FIC, and liaising with regulators and law enforcement. The MLRO can be reached at info@lupasphere.com (marked "MLRO — Confidential").

All relevant staff and contractors receive AML/CTF training at onboarding and at least annually, covering how to recognise suspicious activity and how to report it internally.

Where this Policy or the law is breached, we may, without prior notice, suspend or terminate accounts; freeze or withhold funds, payouts, or float; decline or reverse transactions; and report the matter to the FIC, Bank of Zambia, or law enforcement.

Lupasphere Integrated Platforms Limited
Plot 1193/B, Ibex, Chongwe, Zambia
PACRA: 120261046351
General: info@lupasphere.com · Support: support@lupasphere.com