The risk of money laundering and terrorist financing is the possibility that the Company may incur for loss or damage when it is used directly or through its operations as an instrument for money laundering and/or channeling resources to carry out terrorist activities, or when it is intended to conceal assets from such activities. The ML/FT risk materializes through the associated risks, these are: legal, reputational, operational and contagionNex.

Nexsys has adopted and has implemented a Self-control and Risk Management System for Money Laundering and Terrorist Financing -SARLAFT, as part of the organizational culture, based on stages, elements and instruments disseminated through prevention-oriented policies and procedures. , control, detection and reporting of operations related to money laundering and terrorist financing, in accordance with Circular 100-000005/2014 supersociedades issued by the Superintendence of Companies, which allows for the effective identification, measurement, control and monitoring of this risk in the company.

Nexsys de Colombia has a Manual for the Money Laundering and Terrorism Financing Risk Management System, which outlines the policies regarding the prevention of asset laundering and the Financing of Terrorism, the methodologies, the procedures, as well as the control mechanisms and instruments used for the proper management of ML/TF risk. In the development of control management, an annual compliance plan is designed and executed, whose purpose is to measure, monitor, control, evaluate and follow up on the different aspects involved in the prevention, detection and control of illegal money laundering activities. of assets and/or financing of terrorism that may arise in the development of the ordinary operation of the Company.

The implemented policies, controls and procedures, within a risk management concept, are actions that seek due diligence to prevent the use of the Company by criminal elements for illegal purposes. Said actions include, likewise, and among other aspects: knowledge of the client and its operations with the Company, definition of market segments served, monitoring of transactions, training of personnel and reports of suspicious operations to the competent authority.

Nexsys’ Know Your Customer Policy seeks to know its customers to prevent possible contagion of activities related to ML/FT by executing due diligence.

For the linking of clients to any product or service offered, users, suppliers and employees, procedures are carried out that allow adequate knowledge of them and their information and that of their counterparties is verified and managed to keep it updated in accordance with the requirements. of the circular

The Company monitors customer transactions. This monitoring seeks to identify unusual operations, based on warning signs.

In the development of know-your-customer policies, when the analysis determines that operations are suspicious, they are reported to the competent authorities, in accordance with the regulations.

Depending on the previous activities, decisions are made to maintain or terminate the commercial relationship with the client.

The Entity’s Board of Directors has appointed a compliance officer, who is a high-level person with decision-making capacity and has the effective support of the Entity’s directives.

In the above terms, attention to the Risk of Money Laundering and Terrorism Financing is one of the Company’s priorities and the necessary elements and tools have been allocated for its proper control.

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