Anti-Money Laundering (PLD/FTP) Policy

Anti-Money Laundering, Counter-Terrorism Financing and Proliferation Financing of Weapons of Mass Destruction Policy (PLD/FTP)

1. OBJECTIVE, SCOPE AND INSTITUTIONAL COMMITMENT

1.1 Objective

This Anti-Money Laundering, Counter-Terrorism Financing and Proliferation Financing of Weapons of Mass Destruction Policy ("PLD/FTP Policy") establishes the principles, guidelines, internal controls, operational procedures, and governance mechanisms adopted by Playvio to prevent its platform, technological infrastructure, products, services, or operations from being used, directly or indirectly, for illegal practices.

The Policy is part of the Playvio Corporate Compliance Program and constitutes a permanent risk management instrument, protecting the integrity of the regulated market.Brazilian, prevention of financial crimes, and compliance with applicable legal and regulatory requirements.

Playvio adopts a risk-based preventive approach (Risk-Based Approach – RBA), promoting continuous monitoring of its users, transactions, payment methods, and behavioral patterns, in a manner proportional to the identified risk.

1.2 Institutional Commitment

Playvio maintains a permanent commitment to:

Financial integrity;
Corporate ethics;
Money laundering prevention;
Counter-terrorism financing prevention;
Prevention of financing the proliferation of weapons of mass destruction;
Fraud prevention;
Prevention of abusive use of the Platform;
Protection of the economic order;
Cooperation with competent authorities;
Regulatory transparency;
Continuous improvement of its internal controls.

No commercial interest may prevail over thelegal, regulatory, or compliance obligations.

Whenever there is a conflict between business objectives and regulatory requirements, the legal obligations and the principles of this Policy shall fully prevail.

1.3 Scope

This Policy fully applies to:

All Platform users;
Administrators;
Directors;
Partners;
Legal representatives;
Employees;
Service providers;
Business partners;
Affiliates;
Strategic suppliers;
Third-party operators;
Companies within the same corporate group;
Third parties acting on behalf of Playvio.

Whenever technically possible and contractually applicable, third parties must observe equivalent standards for money laundering prevention.

1.4 Integration with the Compliance Program

This Policy integrates Playvio's Corporate Governance System and should be interpreted together with:

General Terms and Conditions;
Privacy Policy;
Responsible Gaming Policy;
Information Security Policy;
Code of Ethics and Conduct;
Anti-Fraud Policy;
Risk Management Policy;
Sports Integrity Policy;
Other applicable internal rules.

In the event of a conflict, Brazilian legislation and regulatory acts issued by the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF), the Council for Financial Activities Control (COAF), and other competent authorities shall prevail.

2. LEGAL AND REGULATORY BASIS

This Policy was prepared considering, among other applicable rules:

Constitution of the Federative Republic of Brazil;
Law No. 14.790/2023;
Law No. 9.613/1998 (Anti-Money Laundering Law);
Law No. 13.709/2018 (LGPD);
Brazilian Civil Code;
Consumer Protection Code;
Regulatory acts,ordinances, normative instructions, and regulations issued by the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF);
Standards issued by the Council for the Control of Financial Activities (COAF);
Recommendations of the Financial Action Task Force (FATF);
International PLD/FTP principles adopted by the regulated betting sector;
Other applicable national and international standards.

Playvio commits to reviewing this Policy whenever legislative, regulatory, or operational changes justify its update.

3. DEFINITIONS

For the purposes of this Policy, the following definitions apply:

AML (Anti-Money Laundering): set of measures aimed at preventing money laundering; English version for PLD.
CFT (Counter Financing of Terrorism): measures aimed at preventing the financing of terrorism; English version for FTP.
CPF: Individual Taxpayer Registry administered by the Federal Revenue of Brazil.
Client: any individual registered on the Platform.
Compliance: a set of mechanisms aimed at ensuring legal, regulatory, and ethical compliance.
COAF: Council for Financial Activities Control.
EDD (Enhanced Due Diligence): reinforced due diligence procedures applicable to situations classified as higher risk.
KYC (Know Your Customer): procedures aimed at identifying and verifying the identity of users.
PEP (Politically Exposed Person): person falling under the current legal or regulatory definition.
Platform: digital environment operated by Playvio.
RBA (Risk-Based Approach): risk-based methodology used to direct controls proportionate to the identified level of risk.
SOF (Source of Funds): source of funds used in a particularfinancial operation.
SOW (Source of Wealth): origin of the user's assets.
SPA/MF: Secretariat of Prizes and Bets of the Ministry of Finance.
Transaction: any financial, operational, or asset movement carried out on the Platform.

4. GENERAL PRINCIPLES OF THE PROGRAM FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING (PLD/FTP)

4.1. Institutional Commitment

Playvio adopts a Program for the Prevention of Money Laundering, Terrorist Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (PLD/FTP) structured based on a preventive, ongoing, and risk-based approach (Risk-Based Approach – RBA), aiming to protect the integrity of its operations, preserve the confidence of the regulated market, and ensure compliance with applicable legal and regulatory obligations.

The Program is integrated into the corporate governance system of Playvio and constitutes an essential element of its internal controls, encompassing processes, policies, technologies, operating procedures, employee training, continuous monitoring, and mechanisms aimed at preventing, detecting, and reporting potentially illicit activities.

4.2. Compliance Culture

The prevention of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (PLD/FTP) constitutes a shared responsibility among administrators, employees, service providers, business partners, and other individuals acting on behalf of Playvio.

The Company promotes an organizational culture based on ethics, transparency, integrity, corporate responsibility, and regulatory compliance, encouraging all involved to act diligently in identifying and reporting situationspotentially suspicious.

No commercial objective may prevail over the legal obligations related to the PLD/FTP Program.

4.3. Risk-Based Approach

Playvio's internal procedures will be developed considering the inherent risk of the operations carried out, prioritizing monitoring and control resources according to the level of exposure identified.

This approach will allow diligence, monitoring, customer validation, and operational review measures to be proportional to the risks presented by each client, transaction, partner, or operation.

4.4. Independence of Compliance Activities

Activities related to the PLD/FTP Program must have sufficient technical independence to allow impartial evaluations of existing risks.

Those responsible for the Program must have functional autonomy to recommend measurespreventive measures, conduct additional inquiries, request supplementary documentation, determine enhanced monitoring, and forward communications to the competent authorities, when applicable.

4.5. Principle of Good Faith

Playvio will presume the good faith of its Users during the regular use of the Platform.

However, whenever objective elements are identified that may indicate inconsistencies, incompatibilities, or significant risks, additional measures of verification, monitoring, or operational restriction may be adopted, regardless of the existence of concrete indications of criminal offense.

4.6. Proportionality

The measures adopted under this Policy will observe criteria of reasonableness, proportionality, and necessity, considering:

Nature of the operation;
User profile;
Amount of financial transactions;
Frequency of operations;
Historycadastral;
Identified risk level;
Legal and regulatory requirements.

4.7. Continuous Improvement

Playvio is committed to continuously reviewing its anti-money laundering processes, incorporating:

Legislative changes;
Regulatory updates;
New technologies;
National and international best practices;
Recommendations from specialized bodies;
Audit results;
Operational experiences obtained throughout the execution of the Program.

5. RISK-BASED APPROACH (RBA)

5.1. General Principle

Playvio's PLD/FTP Program is structured based on the international methodology called Risk-Based Approach (RBA), recognized by the Financial Action Task Force (FATF) as the most efficient model for preventing financial crimes.

Through this methodology, control resources,Monitoring and diligence are primarily directed towards operations that present the highest potential risk.

5.2. Risk Assessment

Playvio will conduct periodic assessments of the risks related to its activities, considering, among other factors:

User profile;
Products offered;
Betting types;
Payment methods used;
Customer service channels;
Geographical location;
Technologies employed;
Financial volume handled;
Nature of transactions;
Business partners;
Critical suppliers;
Technology providers.

5.3. Risk Classification

Users may be classified into different risk categories, according to internal criteria defined by the Compliance department.

The classification may consider, among other elements:

Low risk;
Medium risk;
High risk.

This classification maymay be changed at any time whenever new information is obtained or when there is a relevant change in the User's operational behavior.

5.4. Considered Criteria

Without prejudice to other factors that may be considered relevant, the evaluation may include:

Registration inconsistencies;
Financial history;
Transactional behavior;
Frequency of deposits and withdrawals;
Use of different devices;
Frequent changes of location;
Use of VPN or anonymization tools;
Financial volume inconsistent with the provided profile;
Relationship with Politically Exposed Persons (PEPs);
Use of third parties;
Source of funds;
Patrimonial origin when applicable;
Exposure to countries classified as higher risk.

5.5. Classification Update

The risk classification does not have a permanent character.

Playvio will conduct periodic or extraordinary reviews whenever it identifies:

Significant change in the User's behavior;
Change in financial profile;
New documents presented;
Communications internal;
Alerts generated by monitoring systems;
Regulatory changes;
New risk factors.

5.6. Proportional Measures

According to the identified risk level, measures such as the following may be adopted:

Simplified due diligence;
Standard due diligence;
Enhanced due diligence (EDD);
Enhanced monitoring;
Document review;
Operational limitation;
Preventive suspension of transactions;
Temporary retention of amounts for audit;
Communication to the competent authorities, when required.

5.7. Methodology Review

The risk assessment methodology will be periodically reviewed by the Compliance department,considering:

Regulatory evolution;
Legislative changes;
SPA/MF recommendations;
COAF recommendations;
FATF recommendations;
Results of internal and external audits;
Changes in Playvio's business model;
Evolution of threats related to financial crime.

6. KNOW YOUR CUSTOMER (KYC)

6.1. Objective

Playvio adopts Know Your Customer (KYC) procedures aimed at identifying, verifying, and validating the identity of Users before and during the use of the Platform, in order to prevent the use of its services for money laundering, terrorism financing, fraud, the use of false identity, asset concealment, corruption, financing the proliferation of weapons of mass destruction, and other financial crimes.

KYC procedures constitute essential element of the PLD/FTP Program and must be observed throughout the entire commercial relationship maintained between Playvio and its Users.

6.2. Mandatory Registration

The use of the Platform depends on the prior registration by the User.

During the registration process, information may be requested for the correct identification of the client, including, but not limited to:

Full name;
Valid CPF in good standing with the Federal Revenue of Brazil;
Date of birth;
Nationality;
Residential address;
Electronic address (email);
Phone number;
Profession, when applicable;
Financial information compatible with the use of the Platform;
Other information required by law or applicable regulation.

The User declares that all the information provided is true, complete, up-to-date, and solely theirresponsibility.

6.3. Identity Verification

Playvio may carry out procedures aimed at confirming the User's identity before, during, or after registration, whenever it deems necessary.

These procedures may include:

Automated document validation;
Facial biometric verification;
Liveness detection technology;
Biometric comparison;
Validation with public and private databases;
CPF verification;
Document authenticity check;
Cross-checking registration information;
Validation of payment method ownership;
Other available technological mechanisms.

The satisfactory completion of these verifications may constitute a requirement for full use of the Platform.

6.4. Registration Update

The User agrees to keep all registration information provided to Playvio permanently updated.

TheThe platform may request an update of registration information whenever:

Inconsistencies are identified;
There is a change in relevant information;
A period previously defined in internal procedures elapses;
There is a change in the risk profile;
There are new regulatory requirements;
Signs of fraud or misuse of the account are identified.

Until the requested update is completed, certain functionalities may remain temporarily unavailable.

6.5. Continuous Validation

The KYC procedure does not end after the initial registration.

Throughout the commercial relationship, Playvio may carry out periodic checks aimed at confirming that the registration information remains valid, consistent, and compatible with the observed operational behavior.

These checks may occur in an automated manner ormanual, regardless of the User's request.

6.6. Enhanced Due Diligence (EDD)

Whenever high-risk factors are identified, Playvio may apply enhanced due diligence procedures (EDD).

Among other measures, the following may be required:

Additional documentation;
Updated proof of address;
Proof of bank account ownership;
Proof of the source of funds (SOF);
Proof of source of wealth (SOW);
Additional interviews;
Additional biometric validations;
Manual review of the submitted documentation;
Additional checks in public and private databases.

The application of enhanced due diligence will observe internal risk criteria and may occur before, during, or after the use of the Platform.

6.7. Politically Exposed Persons(PEPs)

Playvio may identify Users classified as Politically Exposed Persons (PEPs), their representatives, close relatives, or individuals with a close relationship, according to the criteria established in Brazilian legislation and the rules issued by the competent authorities.

In these cases, additional due diligence measures may be adopted, including:

Individualized analysis of the registration;
Approval by a higher hierarchical level;
Enhanced monitoring of transactions;
More frequent registration updates;
Expanded verification of the source of funds;
Periodic review of the business relationship.

The status of a PEP does not, by itself, imply a prohibition on using the Platform, but it may justify additional controls compatible with the identified risk.

6.8. Source of Funds (SOF)

Whenever deemed necessary, the Playvio may request from the User information or documents intended to demonstrate the lawful origin of the funds used in the transactions carried out on the Platform.

The following may be accepted, as applicable:

Income statements;
Tax declarations;
Contracts;
Bank statements;
Corporate documents;
Proof of sale of assets;
Inheritance documents;
Other documents deemed appropriate.

The documentation will be analyzed exclusively for the purpose of compliance with legal and regulatory obligations.

6.9. Source of Wealth (SOW)

In cases classified as higher risk, Playvio may request information intended to understand the origin of the User's wealth.

The analysis may consider:

Professional activity;
Corporate participation;
Investments;
Inheritances;
Sale of assets;
Financial history;
Otherrelevant information.

The adoption of this procedure will follow internal criteria of proportionality and a risk-based approach.

6.10. Refusal or Inability to Validate

Playvio may restrict, suspend, or terminate the commercial relationship whenever:

It is not possible to confirm the User's identity;
There is an unjustified refusal to present documents;
Relevant inconsistencies are identified;
There are indications of the use of a false identity;
There is suspected document fraud;
Contradictory or incompatible information is identified.

In these cases, the Platform may, depending on the situation:

Prevent new deposits;
Block bets;
Suspend withdrawals;
Limit functionalities;
Retain funds for the period necessary for verification;
Report the situation to the competent authorities, when required by law.

6.11. Ongoing Relationship Monitoring

The relationship between Playvio and its Users will be subject to continuous monitoring, allowing the identification of significant changes in the registration, financial, or behavioral profile.

If changes incompatible with the originally declared profile are identified, additional due diligence measures, risk reclassification, enhanced monitoring, or other measures provided for in this Policy may be adopted.

6.12. Record of Verifications

All procedures for identification, validation, registration updates, enhanced due diligence, and monitoring may be recorded in Playvio's internal systems, allowing traceability of the decisions adopted and compliance with legal, regulatory, audit, and supervisory requirements.

Records will be kept for the period provided in the applicable legislation or forextended period when necessary to comply with legal, regulatory obligations or to defend Playvio's legitimate interests.

7. KNOW YOUR PARTNER (KYP)

7.1. Objective

Playvio recognizes that risks related to money laundering, terrorist financing, fraud, corruption, and other financial crimes may arise not only from its Users but also from business partners, suppliers, service providers, and other third parties involved in its operations.

Therefore, it adopts Know Your Partner (KYP) procedures aimed at prior assessment, risk classification, continuous monitoring, and periodic review of third parties with whom it maintains commercial, contractual, or operational relationships.

The objective is to ensure that Playvio's partners observe compatible standards of integrity, ethics, compliance, and regulatory conformity, reducing the Company's exposure to legal, financial, reputational, and operational risks.

7.2. Covered Partners

The procedures provided for in this Policy may be applied, depending on the nature of the contractual relationship and the level of identified risk, to any third parties that maintain a relationship with Playvio, including, but not limited to:

Platform providers technological;
Game developers;
Content aggregators;
Payment gateways and processors;
Financial institutions;
Providers of KYC, AML, and fraud prevention services;
Biometric and document verification companies;
Technology infrastructure suppliers;
Hosting and cloud computing providers;
Information security companies;
Marketing affiliates and partners, including digital influencers;
Specialized consultancies;
Law firms;
Audit companies;
Strategic suppliers;
Other third parties whose actions may impact the PLD/FTP Program.

7.3. Integrity Due Diligence

Before hiring partners classified as relevant or higher risk, Playvio may carry out due diligence procedures aimed at assessing their integrity and their ability to comply with legal and regulatory obligations.

This analysis may include, among other aspects:

Legal existence;
Corporate structure;
Identification of ultimate beneficial owners (UBOs);
Registration status;
Reputational history;
Operational capacity;
Governance structure;
Internal compliance policies;
Existence of an PLD/FTP program;
Relevant certifications;
History of administrative sanctions;
Litigationrelevant;
Available public records;
News with reputational impact.

The extent of the due diligence will consider the inherent risk of the partner and the criticality of the activity performed.

7.4. Partner Risk Classification

Partners may be classified into different risk levels, considering, among other factors:

Nature of services provided;
Access to sensitive information;
Financial transactions involved;
Degree of interaction with Users;
Geographic location;
Economic sector;
Compliance history;
Regulatory exposure;
Use of subcontractors;
Strategic relevance to the operation.

This classification may be reviewed periodically or whenever there is a relevant change in the relationship.

7.5. Sanctions, Restricted Lists, and Exposed Persons

Whenever operationally feasible, Playvio may verify ifpartners, administrators, controllers, or ultimate beneficiaries appear in:

National or international sanctions lists;
Lists of Politically Exposed Persons (PEPs), where applicable;
Public registries related to illicit practices;
Trade restriction lists;
Public integrity databases;
Other sources used for risk assessment.

The existence of records in these databases does not automatically imply prohibition to the hiring, but may justify additional diligences, approval by higher levels, or the non-formalization of the commercial relationship.

7.6. Contractual Obligations

Whenever compatible with the nature of the hiring, Playvio will seek to include in its contracts clauses related to:

Compliance with Brazilian law;
Prevention of money laundering;
Combating the financing of terrorism;
Combating corruption;
Personal data protection;
Confidentiality;
Information security;
Cooperation in audits;
Provision of information when requested;
Right to termination in case of violation of any of the clauses mentioned above, including compliance.

7.7. Continuous Monitoring

The evaluation of partners is not limited to the time of contracting.

Throughout the term of the contractual relationship, Playvio may perform periodic monitoring aimed at identifying relevant changes, including:

Corporate changes;
Change of ultimate beneficiaries;
Regulatory sanctions;
Public investigations;
Reputational changes;
Changes in governance structure;
Contractual noncompliance;
Failures related to the Compliance Program;
Information security incidents;
Events that may increase operational risk.

Whenever necessary,additional due diligence may be carried out.

7.8. High-Risk Partners

Partners classified as higher risk may be subject to additional measures, including:

Enhanced Due Diligence (EDD);
Approval by higher governance levels;
More frequent periodic reviews;
Specific audits;
Expanded monitoring;
Additional documentation requests;
Specific contractual restrictions;
Risk mitigation plans.

7.9. Right of Refusal or Termination

Playvio may refuse hiring, suspend, or terminate commercial relationships with partners whenever it identifies:

Signs of fraud;
Non-compliance with legislation;
Practices incompatible with this Policy;
Significant reputational risks;
Lack of cooperation in due diligence;
Use of structures intended to concealultimate beneficiaries;
Incompatibility with the Company's ethical principles;
Any situation that represents a significant risk to the PLD/FTP Program.

This decision may be made regardless of the existence of a definitive judicial conviction, provided it is based on objective risk management criteria.

7.10. Recordkeeping and Documentation

The procedures for assessing, risk classification, due diligence, monitoring, and review of partners may be recorded in Playvio's internal systems.

These records may include:

Due diligence forms;
Corporate documents;
Technical opinions;
Risk assessments;
Internal approvals;
Monitoring evidence;
Audit records;
Revision history;
Other documents related to the business relationship.

The documentation will be kept for the period provided for under applicable legislation orfor a period longer when necessary to comply with legal or regulatory obligations or to defend the legitimate interests of Playvio.

8. REPORTING SUSPICIOUS TRANSACTIONS AND COOPERATION WITH AUTHORITIES

8.1. General Principle

Playvio will maintain procedures aimed at identifying, analyzing, documenting, handling, and, when applicable, reporting to the competent authorities transactions, attempted transactions, or behaviors that may indicate:

Money Laundering (ML);
Terrorism Financing (TF);
Financing of the Proliferation of Weapons of Mass Destruction (FP);
Financial fraud;
Concealment of assets;
Use of third parties ("strawmen");
Financial or related crimes.

The decision regarding any reporting will be based exclusively on technical, legal, and regulatory criteria.

8.2. Internal Analysis

Every transaction considered atypical will be submitted to specialized analysis conducted by the Compliance area.

The analysis may consider, among other elements:

Registration history;
Financial behavior;
Declared economic profile;
Source and destination of funds;
Operational frequency;
Relationship with other accounts;
Use of the platform;
Geolocation data;
Devices used;
Statistical patterns;
Documents presented;
Results of additional due diligence.

8.3. Preventive Measures

During the analysis, measures may be adopted such as:

Temporary suspension of the account;
Preventive retention of funds;
Deposit blocking;
Withdrawal blocking;
Betting limitations;
Request for additional documentation;
Mandatory registration update;
Conducting complementary interviews;
Risk classification review.

These measures they have a preventive nature and do not, by themselves, constitute a conclusion regarding the existence of irregularity.

8.4. Communication to Competent Authorities

Playvio will carry out the mandatory communications to the competent authorities whenever it identifies transactions, proposed transactions, or situations that, under the applicable legislation and regulations, are subject to the obligation to report. Such communications will be made in a timely manner, observing legal and regulatory requirements and the duty of confidentiality provided for in the applicable legislation.

Communications may occur regardless of:

The existence of financial loss;
The final conclusion of the internal analysis;
The User's consent;
The existence of legal proceedings.

8.5. Confidentiality of Communications

Communications made to the competent authorities are of an absolutelyconfidential.

Employees are strictly prohibited from disclosing:

That a certain transaction has been reported;
That a certain investigation is ongoing;
That a certain User is being monitored;
That a certain account is under review.
The prohibition also applies to the User involved.

8.6. Prohibition of "Tipping Off"

No employee may inform the User, directly or indirectly, that:

A suspicious transaction has been reported;
An investigation is ongoing;
The account is being monitored;
A specific authority has been contacted.

Failure to comply with this obligation constitutes a serious offense and may result in disciplinary, civil, and criminal liability.

8.7. Institutional Cooperation

Playvio is committed to cooperating with:

Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF);
Council for the Control of ActivitiesFinancial Institutions (COAF);
Central Bank of Brazil;
Federal Revenue of Brazil;
Federal Police;
Public Prosecutor's Office;
Judiciary;
Other competent national or foreign authorities.

Cooperation will always observe:

Applicable legislation;
Duty of confidentiality;
Protection of personal data;
Due legal process;
Legal limits for information sharing.

9. DOCUMENT RETENTION AND TRACEABILITY

9.1. Objective

Playvio will maintain complete records of all relevant information for purposes of:

Audit;
Supervision;
Financial traceability;
Money laundering prevention;
Fraud investigation;
Regulatory compliance.

9.2. Documents Retained

The following may be stored, among others:

Complete registration;
Identity documents;
Proof of residence;
Biometrics;
Authentication records;
History oflogin;
Betting history;
Deposits;
Withdrawals;
Communications with the User;
Documents submitted during KYC;
Additional due diligence;
Risk analyses;
Internal reports;
Regulatory communications.

9.3. Retention Period

Records will be kept for the minimum period required by Brazilian law, SPA/MF regulations, anti-money laundering standards, terrorism financing, and financing of proliferation of weapons of mass destruction (PLD/FTP) and other applicable legal obligations. Always in compliance with the General Data Protection Law (LGPD).

If necessary for:

Administrative processes;
Legal actions;
Investigations;
Audits;
Compliance with legal obligations;

The documents may remain stored for a longer period.

9.4. Record Integrity

Playvio will adopt mechanisms intended to ensure:

Authenticity;
Integrity;
Availability;
Confidentiality;
Traceability;
Protection against unauthorized changes.

9.5. Information Protection

Records will be protected through:

Access control;
Encryption;
Logical segregation;
Audit trails;
Backups;
Continuous monitoring;
Information security policies.

9.6. Access to Records

Access will be restricted to authorized employees, observing the principle of least privilege ("Need to Know"), and will be recorded for audit purposes.

10. TRAINING, COMPLIANCE CULTURE, AND RESPONSIBILITIES OF EMPLOYEES

10.1. Institutional Commitment

Playvio recognizes that the effectiveness of its Program for the Prevention of Money Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction (PLD/FTP) depends directly on conscious, ethical, and technically competent performance of its employees.

For this reason, the Company maintains a permanent program of training, awareness, and professional updating intended to ensure that all employees understand their legal, regulatory, and internal responsibilities related to the prevention of financial crimes.

Training is an essential element of the corporate governance structure and is part of Playvio's permanent risk management mechanisms.

10.2. Scope

This Program applies to:

Administrators;
Directors;
Legal representatives;
Members of senior management;
Permanent employees;
Temporary employees;
Service providers;
Consultants;
Third parties performing activities related to the operation of the Platform;
Strategic partners engaged in activities subject to the controls of AML/CTF.

Whenever operationally possible, Playvio will seek to require relevant third parties to maintain training programs compatible with the risks inherent to the activities performed.

10.3. Training Program Objectives

The Training Program has the following main objectives:

Disseminate a culture of compliance;
Strengthen the prevention of money laundering;
Prevent the financing of terrorism;
Prevent the financing of the proliferation of weapons of mass destruction;
Reduce operational risks;
Promote corporate integrity;
Ensure compliance with SPA/MF standards;
Ensure adherence to Law No. 9.613/1998;
Ensure compliance with complementary regulations;
Provide guidance regarding individual responsibilities of employees.

10.4. Program Content

The trainings may cover, among other topics:

Applicable Brazilian legislation;
Law No. 9.613/1998;
Law No. 14.790/2023;
Regulations issued by the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF);
Recommendations of the FATF;
Concepts of PLD/FTP;
Risk-Based Approach;
Identification of the ultimate beneficiary;
KYC procedures;
Customer Due Diligence (CDD);
Enhanced Due Diligence (EDD);
Transaction monitoring;
Identification of suspicious operations;
Reporting to COAF;
Prevention of tipping-off;
National and international sanctions;
Restrictive lists;
Fraud prevention;
Sports integrity;
Information security;
Personal data protection;
Individual responsibilities;
Case studies;
International best practices.

10.5. Frequency

Training sessions may be conducted:

During the onboarding of new employees;
Periodically, at intervals defined by the Compliance area;
Whenever there are relevant regulatory changes;
When new risks are identified;
After relevant incidents;
Whenever this Policy is updated.

Extraordinary trainings may be conducted whenever deemed necessary by the Compliance area.

10.6. Training Methods

Playvio may use different training modalities, including:

In-person trainings;
Virtual trainings;
E-learning platforms;
Workshops;
Lectures;
Directed studies;
Periodic assessments;
Practical case simulations;
Internal awareness campaigns.

10.7. Knowledge Assessment

Whenever applicable, participants may be subjected to assessments aimed at verifying:

Understanding of legislation;
Knowledgeof internal procedures;
Identification of risk situations;
Correct application of this Policy;
Ability to recognize suspicious operations.

The results may be used exclusively for the purpose of improving the Compliance Program.

10.8. Training Records

Playvio will keep records of the trainings conducted, which may include:

Date;
Content provided;
Instructors;
Participants;
Duration;
Results of assessments;
Materials used;
Certificates issued.

These records may be made available to competent authorities whenever legally required.

10.9. Employee Responsibilities

All employees have the duty to:

Know this Policy;
Participate in mandatory trainings;
Fully comply with internal procedures;
Immediately report suspicious situations;
Preserve the confidentiality of information obtained by virtue of their functions;
Collaborate with internal investigations;
Act ethically and diligently;
Fully observe the applicable legislation.

Lack of knowledge of this Policy does not exempt the employee from responsibility for failing to fulfill their obligations.

10.10. Responsibilities of Senior Management

It is the responsibility of Senior Management to:

Promote a permanent culture of compliance;
Provide adequate resources for the PLD/FTP Program;
Institutionally support the Compliance area;
Ensure the functional independence of the Compliance Officer;
Encourage an environment of integrity;
Monitor indicators of Program effectiveness;
Promote continuous improvement of internal controls.

10.11. Responsibilities of the Compliance Area

It is the responsibility of the Compliance area, among other duties, to:

Develop the Training Program;
Update the content;
Monitor regulatory changes;
Promote awareness actions;
Maintain training records;
Assess the effectiveness of the training;
Recommend continuous improvements;
Prepare educational materials;
Guide employees regarding the application of this Policy.

10.12. Integrity Culture

Playvio encourages an organizational environment based on:

Ethics;
Transparency;
Good faith;
Responsibility;
Prevention of illegal acts;
Respect for regulatory norms;
Cooperation with authorities;
Protection of the integrity of the regulated betting market.

All employees must act in a manner consistent with the principles of this Policy, contributing to the maintenance of an organizational culture oriented toward regulatory compliance and the prevention of financial crimes.

11. AUDIT, MONITORING, AND CONTINUOUS IMPROVEMENT

11.1. Commitment to Continuous Improvement

Playvio recognizes that the effectiveness of its Program for the Prevention of Money Laundering, Terrorism Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (AML/CTF) depends on the constant evolution of its internal controls, processes, technologies, and governance mechanisms.

Therefore, this Policy will be subject to continuous monitoring, periodic review, and ongoing improvement, taking into account the evolution of Brazilian legislation, regulations issued by the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF), recommendations from the Financial Activities Control Council (COAF), the Financial Action Task Force (FATF), and the best international compliance practices.

11.2. Continuous Monitoring

Playvio will maintain a permanent monitoring process aimed atto assess the effectiveness of PLD/FTP controls.

Monitoring may cover, among other aspects:

Effectiveness of KYC procedures;
Quality of due diligence processes;
Transactional monitoring;
Identification of suspicious operations;
Compliance with internal procedures;
Functioning of automated systems;
Technological controls;
Risk indicators;
Quality of internal investigations;
Communications to the competent authorities;
Document management;
Record retention;
Information access controls.

11.3. Effectiveness Indicators

For the evaluation of the maturity of the Compliance Program, the following may be used performance indicators (Key Performance Indicators – KPIs) and risk indicators (Key Risk Indicators – KRIs), including, among others:

Number of registrations analyzed;
Percentage of reinforced checks;
Number of additional inquiries conducted;
Monitored operations;
Suspicious operations identified;
Communications sent to COAF;
Average response time of analyses;
Training sessions conducted;
Percentage of employees trained;
Audits carried out;
Recommendations implemented;
Incidents identified.

The use of these indicators is exclusively aimed at improving internal prevention mechanisms and control.

11.4. Internal Audits

Playvio may conduct periodic internal audits aimed at verifying:

Adherence to the provisions of this Policy;
Compliance with applicable law;
Observance of the regulations issued by SPA/MF;
Effectiveness of internal controls;
Quality of operational records;
Compliance with KYC and Due Diligence procedures;
Functioning of monitoring mechanisms;
Compliance of mandatory communications;
Adequacy of governance processes.

Audits may be conducted by the Compliance area, Internal Audit, or by specially designated professionals.

11.5. Independent Audits

Whenever considered necessary or required by legal, regulatory, or contractual obligation, Playvio may hire specialized companies to carry out independent audits.

These audits may evaluate:

Maturity of the Compliance Program;
Regulatory adherence;
Technological controls;
Anti-money laundering mechanisms;
Operational security;
Effectiveness of internal controls;
Document compliance.

The recommendations issued may support the continuous improvement of the governance structure.

11.6. Effectiveness Tests

Playvio may conduct periodic tests intended toverify the effectiveness of its controls, including:

Transaction monitoring tests;
Automated system functionality tests;
Validation of risk parameters;
Simulations of suspicious operations;
Operational response tests;
Segregation of duties tests;
Technological controls tests.

The results may be used exclusively for the improvement of internal processes.

11.7. Non-Conformity Management

Whenever failures, vulnerabilities, or violations of this Policy are identified, corrective measures compatible with the nature of the identified risk should be adopted.

Possible measures include:

Review of procedures;
Update of internal controls;
Reinforcement of training;
Process review;
Implementation of additional controls;
Technological review;
Update of parametersmonitoring;
Disciplinary accountability, when applicable.

11.8. Corrective Action Plan

When opportunities for improvement are identified, Playvio may develop an Action Plan containing, among other things:

Description of the nonconformity;
Root cause analysis;
Corrective measures;
Preventive measures;
Persons responsible for implementation;
Schedule;
Monitoring indicators;
Expected completion date.

The fulfillment of the Action Plan may be monitored by the Compliance department.

11.9. Periodic Review of the Policy

This Policy will be reviewed whenever necessary and, preferably, at intervals not exceeding 12 (twelve) months, or whenever:

Legislative change occurs;
Regulatory change occurs;
New norms are published by SPA/MF;
Relevant changes occur in Law No. 9.613/1998;
Changes in FATF/GAFI recommendations;
Changesrelevant to Playvio's operation;
Identification of new risks;
Determination of the competent authority;
Completion of audits recommending updates.

The review may cover any provision of this Policy.

11.10. Approval of Updates

Changes to this Policy will be submitted to the appropriate levels of Playvio's internal governance for approval, considering the current organizational structure.

Once approved, updated versions will be made available to employees and, when applicable, published on the Platform's official channels.

11.11. Version Control

Playvio will maintain control of the versions of this Policy, including, whenever possible:

Version number;
Approval date;
Effective date;
Brief summary of changes;
Responsible for the review;
Responsible for the approval.

Previous versions may bekept archived for auditing, traceability, and compliance with legal and regulatory requirements.

11.12. Permanent Commitment

Playvio reaffirms its permanent commitment to preventing money laundering, terrorism financing, and the financing of the proliferation of weapons of mass destruction, maintaining a governance structure guided by ethics, transparency, integrity, corporate responsibility, and improvement continuous.

All employees, administrators, partners, and third parties involved in the operation of the Platform must act in accordance with this Policy, contributing to the maintenance of a safe, integrity, transparent and in strict compliance with Brazilian law and the regulations issued by the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF).

12. FINAL PROVISIONS

12.1. 1Nature of Politics

This Policy for the Prevention of Money Laundering, Terrorism Financing, and the Financing of the Proliferation of Weapons of Mass Destruction (PLD/FTP) constitutes an internal regulatory instrument of Playvio and is part of your Compliance, Corporate Governance, and Risk Management Program.

The provisions established herein must be observed by all administrators, directors, employees, representatives, partners, and service providers of services and other persons who, directly or indirectly, act on behalf of Playvio or have access to processes related to activities covered by this Policy.

12.2. Integration with Other Corporate Policies

This Policy should be interpreted together with the other regulatory documents of Playvio, especially:

General Terms and Conditions;
Terms of Service;
Privacy Policy;
Responsible Gaming Policy;
Information Security Policy;
Anti-Fraud Policy;
Know Your Customer (KYC) Policy;
Code of Ethics and Conduct;
Other applicable internal regulations.

In the event of a conflict between internal documents, the provision that offers the highest degree of compliance with Brazilian law and the regulations applicable to the fixed-odds betting sector shall prevail.

12.3. Independence of Provisions

If any provision of this Policy is considered invalid, illegal, or unenforceable by a competent authority, such circumstance shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

Whenever possible, the provision considered invalid shall be replaced by another that produces equivalent legal effects and preserves, to the greatest extent possible, the originally intended purpose.

12.4. Policy Amendments

The Playvio may alter, update, or revise this Policy at any time, whenever necessary for:

Compliance with Brazilian legislation;
Compliance with determinations of the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF);
Adherence to the recommendations of the Council for Financial Activities Control (COAF);
Observance of the recommendations of the Financial Action Task Force (FATF);
Advancement of best market practices;
Improvement of internal controls;
Implementation of new processes, technologies, or products;
Mitigation of identified risks.

The updated versions will fully replace the previous versions upon their entry into force.

12.5. Record Keeping

The records produced as a result of the application of this Policy will be maintained for the period provided for in the applicable legislation and regulations.especially in Law No. 9.613/1998, in the regulations issued by the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF), and in other relevant legal provisions.

The preservation will observe criteria of:

Confidentiality;
Integrity;
Availability;
Authenticity;
Traceability;
Information security.

12.6. Confidentiality

The information obtained due to the application of this Policy will be treated as confidential and used exclusively for legitimate purposes related to the prevention of money laundering, terrorist financing, fraud prevention, protection of the Platform's integrity, and compliance with legal and regulatory obligations.

Access to information will be restricted to people whose functional role justifies their knowledge, observing the principles of necessity, proportionality, and information security.

12.7. 7Institutional Cooperation

Playvio commits to cooperating, within the limits of applicable law, with:

Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF);
Council for Activity Control Financial Intelligence Units (COAF);
Central Bank of Brazil, when applicable;
Police authorities;
Public Prosecutor's Office;
Judiciary;
Other competent regulatory and supervisory bodies.

The cooperation shall include the provision of information, documents, and records whenever required by law, by court order, or by legitimate request of the competent authorities.

12.8. Personal Data Protection

The processing of personal data carried out for the fulfillment of this Policy will fully comply with Law No. 13.709/2018 (General Data Protection Law – LGPD), as well as other applicable regulations on personal data protection.

Whenever possible,technical and administrative measures will be adopted to ensure the confidentiality, integrity, availability, and security of the information processed.

Additional information about the processing of personal data is available in Playvio's Privacy Policy.

12.9. Communication Channels

Any questions, communications, or complaints related to the application of this Policy may be submitted through the official channels provided by Playvio.

Compliance / AML-FTP Email: sac@playvio.com

User Support Email: sac@playvio.com

Website: playvio.com

Playvio may provide additional channels for receiving communications related to the prevention of financial crimes and compliance with this Policy.

12.10. Statement of Commitment

Playvio reaffirms its ongoing commitment to ethics, integrity, transparency, the protection of the economic order, the prevention of financial crime, and the strengthening of the regulated Brazilian fixed-odds betting environment.

The Company declares that it will maintain a continuous program for the prevention of money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction, promoting the permanent updating of its controls, processes, and governance mechanisms, in accordance with Brazilian legislation, with the rules issued by the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF), and with the best international compliance practices.

12.11. Term

This Policy comes into force on the date of its publication and will remain in effect indefinitely, until it is expressly replaced by a later version approved by Playvio.

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