Anti-Money Laundering Policy

Purpose, scope and responsibility

Widestream Development OÜ (“Widestream” or the “Company”) are subject to various anti-money laundering (AML) laws, regulations, requests and requirements relevant to the specific business and jurisdiction where the business operates (the “the applicable law”). This policy recognizes the need for awareness by the Company to comply with such laws and regulations and to fulfill such requirements and requests, as applicable, including risk-based Know Your Customer (KYC) policies and procedures and requests from contractors and other banking and financial institutions with whom the Company may transact or be engaged with for business.

This policy appliesto all employees of the Company.

The General Counsel of the Company is the final authority for this policy.

Policy Statement

Widestream established this AML policy in conjunction with its other corporate policies to help detect transactions that may involve money laundering, terrorist financing, or other illicit activity, and to provide resources for reporting applicable situations as required by applicable law or as required by third parties for business engagement. This policy also helps ensure the Company satisfy all legal and regulatory requirements and maintain ethical business practices.

Widestream issubject to various AML laws and regulations.

The Company’s General Counsel shall monitor and support compliance with this policy and regularly reporttosenior management, includingthe Management Board Member.

Anti-Money Laundering Program Requirements

The applicable law sets forth the requirements imposed on financial institutions to facilitate the prevention, detection, and prosecution of international money laundering and the financing of terrorism. The applicable law requires financial institutions such as banks, securities broker-dealers, mutual funds, insurance companies, and other financial services businesses to establish formal AML programs. Although the Company is not deemed a financial services businesses governed by the applicable law, the Company frequently engages with banks, and other third parties throughout the countries in which it operates who, as a result of their own AML policies and legal requirements, require that the Company respond to specific requirements and requests, including certification of its own AML and KYC policies and processes. Subject to conforming to industry specific regulations, these AML policies are generally required to address the following:

• Collecting and verifying appropriate identifying information about customers, beneficial owners, and control persons and maintaining records ofsuch information (a “control person” is someone who has a level of control over, or entitlement to, the funds or assetsthat, as a practical matter, enable the person, directly or indirectly, to control, manage, or direct the account/or on whose behalf a transaction/activity is being conducted);
• Refusing to accept funds from, or to do business with, shell banks or customers whose funds the company should reasonably believe are derived from criminal activity or from a sanctioned source;
• Training employees, agents, and brokers to identify red flag activities and report them to their manageror asdirectedin their AML procedures;
• Designating an authorized person who, in conjunction with applicable compliance personnel, will review red flag activities and determine appropriate measures to take, consistent with applicable law.
• Understanding the nature and purpose of the customer relationships and implementing appropriate risk-based procedures for conducting ongoing due diligence; and
• Conducting annualindependent auditsto evaluate the effectiveness oftheCompany'sAMLpolicies and procedures.

The Company’s General Counsel, along with the legal and finance departments, have developed and implementedAMLprogramstailored to addressthe risksspecific to the Company’s business.

Suspicious Activity Reporting/Company Contacts

All Company employees and representatives must report all suspicious transactions in writing to the Company’s General Counsel, either directly or through their supervisor or other member of the legal department. Supervisors will coordinate suspicioustransaction information with the Company’s General Counsel.

Accountabilities

All Company employees and representatives are responsible for knowing and following all applicable AML, OFAC, and similar jurisdiction-specific policies and procedures. They should:

• Be familiar with the AML, OFAC, and other policies;
• Be familiar with any specific AML or other policies required by law,
  • All verification (KYC) proceduresfor contracting with customers
  • How to flag activities that may require special attention, trigger reporting requirements, and/or need special approval.
• Report red flag activities or suspicious transactions as directed