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Money Laundering Policy

The management of AM CAPITAL, L.P., L.P. is ultimately responsible for preventing and reducing the incidence of fraud in the company, and they must ensure that the propercontrols are in place to achieve this. Each employee must adhere to the Policy and has an obligation to report any suspicious of fraud.

AM CAPITAL, L.P., L.P. is committed to the prevention andcontrol of money laundering

Money laundering is the process by which criminal attempt to conceal and misrepresent the true origin and ownership of the proceeds of their criminal activities.

In orderto accomplish this aforementioned commitment and in order to give effect to this Money Laundering policy:

AM CAPITAL, L.P., L.P., will keep records of all transactions for at least (5 years) fromthe date on which the business relationship is terminated or the transaction is concluded.

✓ AM CAPITAL, L.P. will provide training to staff members to increase their awareness and ability todeal with suspicious transactions and to keep them informed of new developments and requirements.
✓ AM CAPITAL, L.P. will formulate and implement internal rules and develop procedures and systemsto detect and monitor suspicious transactions and to report thereon to the relevant authorities.
✓ AM CAPITAL, L.P. will create an environment where staff members who report on suspicioustransactions can do so confidentially and without fear or reprisal.
✓ Non-reporting of knowledge or a suspicion of money laundering by a member of staff will be viewed in a very serious light and couldlead to disciplinary action against the individual concerned.
AM CAPITAL, L.P.´s anti-money laundering policies and procedures are intended to ensure that, prior to accepting funds from Clients(investors), all reasonable and practical measures are taken to confirm the Clients’ (investors’) identities.

And to verify that any third party upon whom the Firm relies for Client identification,...