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Compliance

Our Compliance Policy

Through its Compliance Policies, NAPLES PRIME SAS CI adopted a continuous improvement cycle, which allows it to efficiently manage the risks of money laundering, terrorist financing, and the financing and proliferation of weapons of mass destruction (ML/TF/FPDAM and FPADM) associated with its operations, guaranteeing ethical transparency and regulatory compliance at the corporate level.

Our fundamental pillar is the creation of a preventive culture, which transmits trust and security to our clients and counterparties; Assuring them that we apply the best national and international guidelines and standards for the management of AML (Anti-Money Laundering) risks.

1. AML/CFT (Money Laundering and Terrorist Financing)

2 FPDM (Financing and Proliferation of Weapons of Mass Destruction)

3 C/ST (Transnational Corruption and Bribery)

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Compliance Policy Chart

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Compliance Structure Chart

Compliance Program Structure

1. Commitment from Senior Management

  • Support and clear communication of regulatory compliance

  • Establishing a Compliance Culture

  • Designation of Risk Committee

  • Resource allocation

2 Risk Analysis, Policies and Procedures

  • SAGRILAFT Risk Management Systems

  • Knowledge of the Mineral Supply Chain (OECD)

  • Responsible Gold Sourcing (LBMA)

  • KYC (Know Your Customer) Principles

3. Communication and Training

  • Reporting Channels and Ethics Hotlines

  • Counterpart Training Plans

  • Transparency and Business Ethics Programs

4. Audit Monitoring

  • Audit: Effective evaluation of compliance policies

  • Technological Tools for the management of AML/CFT, FPDM and C/ST risks

  • Monitoring of Controlling Entities and Financial Institutions

  • Automated Databases

Compliance training

The Compliance Management System encompasses the design, implementation, review and improvement of all elements that contribute to the company's regulatory compliance.

That is why NAPLES PRIME SAS CI prioritizes the training and development of its employees in the area of risk management. Since 2022, the risk management and compliance staff of NAPLES PRIME SAS CI have attended various conferences, workshops, and seminars given by different regulatory bodies, including:

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Naples Prime Compliance Team (2026)

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KYC Counterparty Process Chart

Know Your Counterparty (KYC) Processes

NAPLES PRIME SAS CI acknowledges the actions involved in complying with the national regulatory framework for the prevention of risks associated with money laundering, terrorist financing, and the financing of the proliferation of anti-money laundering and counterfeiting (ML/TF) related to its operations with its various counterparties. The company directs its efforts toward exceeding the requirements of Colombian regulations in Know Your Customer (KYC) processes to ensure effective control and security of international trade operations.


Our process is structured around the following pillars:

  • Monitoring and Tracking

  • Evaluate the accounting and financial situation

  • Verify compliance with tax obligations (business activity)

  • Validate the legal structure and existence of the legal entity

  • Determine the origin of funds and traceability of resources

  • Identify counterparties up to the ultimate beneficiary

Traceability

  • Supplier selection and validation: We conduct due diligence processes for supplier onboarding, verifying their legal and commercial information and the lawful origin of the products.

  • Validation of the commercial operation: Each transaction is evaluated under criteria of commercial consistency, product availability and compliance with internal risk policies.

  • Control of origin and documentation: We verify the supporting documentation of the products, guaranteeing their traceability, origin and regulatory compliance.

  • Relationship with international clients: We apply Know Your Customer (KYC) processes, ensuring transparent business relationships aligned with international standards.

  • Logistics and Export: We guarantee an efficient, secure, and transparent logistics process thanks to our partnerships with companies specializing in international transport. Our experience and track record are backed by strong banking partners, reinforcing confidence in every one of our transactions.

We have a strict traceability system that allows us to monitor every stage of the process in real time. We comprehensively coordinate logistics and customs management, ensuring compliance with all documentary and regulatory requirements.

We work to offer our customers peace of mind, reliability, and excellence in every shipment.

TRACEABILITY

Traceability Process Chart

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