Know Your Customer (KYC) Policy

1. Introduction and Scope

This Know Your Customer (“KYC”) Policy (“Policy”) outlines the procedures Teravent Limited (“Teravent”) will follow when onboarding and monitoring all clients, partners, and account holders interacting with Teravent platforms, including the Teravent Registry and any associated digital services.

The purpose of this Policy is to reduce the risk of money laundering, terrorist financing, fraud, and other financial crimes, and to ensure Teravent follows high standards of integrity, transparency, and ethical business conduct.

Although Teravent may not, at present, fall squarely under regulated AML/CTF regimes in either India or the United Kingdom, we voluntarily adopt these standards to uphold global best practices.

This Policy is designed to align Teravent’s KYC procedures with applicable laws, regulations, and international standards. It draws on the United Kingdom’s regulatory framework, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), and guidance from both the Financial Conduct Authority (FCA) and the Joint Money Laundering Steering Group (JMLSG). It also incorporates the requirements of Indian legislation, including the Prevention of Money Laundering Act (PMLA), 2002, related rules and notifications issued by the Financial Intelligence Unit – India (FIU-IND), and relevant circulars from the Reserve Bank of India (RBI) and the Ministry of Finance.

In addition, the Policy follows international best practices, including the Financial Action Task Force (FATF) Recommendations and relevant global sanctions frameworks, such as the United Nations Sanctions List. These combined standards ensure that Teravent’s KYC procedures meet both domestic and international expectations for preventing money laundering, terrorist financing, and other financial crimes.

This Policy applies to all Account Holders on the Teravent Registry, encompassing buyers of credits, project proponents or suppliers originating credits, and any third-party entities transacting or interacting with Teravent platforms. It establishes a uniform, rigorous approach to verifying the identity, legitimacy, and risk profile of all parties engaging with Teravent’s services.

2. Continuous Review

This Policy will be reviewed at least annually by the CEO or designated Head of Policy to ensure continued alignment with applicable law and best practice. Additional interim reviews may occur based on:

• Identified gaps in KYC implementation or monitoring,
• Changes to AML/CTF regulation in India, the UK, or any jurisdiction in which Teravent operates,
• Updates to FATF guidance or global sanctions frameworks,
• Significant shifts in industry best practice requiring policy modifications.

3. KYC Requirements

Teravent requires all Account Holders to provide and verify specific information during the onboarding process to ensure compliance with anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations under both UK and Indian law, as well as international best practices. For corporate entities, the information collected includes the full legal name of the company, its registered office address, and the company registration number, which corresponds to the Companies House registration number for UK entities or the Corporate Identification Number (CIN) for Indian entities. Tax identification details are also required, including the Unique Taxpayer Reference (UTR) in the UK and the Permanent Account Number (PAN) in India where applicable.

In addition, Teravent collects information on the company’s industry sector and the nature of its business activities, alongside details of directors and senior management. Ultimate Beneficial Ownership (UBO) information is also required in line with UK MLR 2017 and Indian beneficial ownership disclosure regulations. UBOs are defined as individuals with more than 25% ownership or control over the entity. Publicly available corporate information, such as official websites or other verifiable sources, is also reviewed to support the verification process.

Teravent applies a comprehensive set of verification checks using the information provided. Account Holders are screened against high-risk jurisdictions identified by the Financial Action Task Force (FATF), as well as sanctions lists maintained by UK HM Treasury, the Office of Financial Sanctions Implementation (OFSI), the United Nations, and relevant Indian authorities. Politically Exposed Persons (PEPs) registers are also consulted to identify individuals in positions of public trust who may present heightened risk.

The onboarding process is designed not only to verify identity but also to establish a detailed understanding of the organisation’s structure, business activities, and legitimacy. This includes an assessment of beneficial ownership and control structures to ensure transparency and accountability.

Once onboarded, Teravent maintains secure and accurate KYC records for a minimum of five years from the date of the last transaction, consistent with the requirements of the Prevention of Money Laundering Act (PMLA) in India and MLR 2017 in the UK. Complete transaction records are also maintained to support auditing, monitoring, and compliance obligations.

Ongoing monitoring is performed to detect unusual or suspicious activity. Where onboarding or monitoring identifies an elevated risk of money laundering, terrorist financing, or other illicit activity, Teravent may refuse to open an account or may apply Enhanced Due Diligence (EDD) procedures to assess and mitigate the identified risks. This structured approach ensures that all participants in the Teravent platform meet rigorous standards of integrity, legitimacy, and regulatory compliance.

4. Ongoing Monitoring

Teravent conducts continuous monitoring of all transactions and participant activity on its platforms to detect unusual or potentially suspicious behaviour. This ongoing oversight allows the company to identify risks related to money laundering, terrorist financing, sanctions violations, or other forms of financial misconduct. Where monitoring reveals elevated risk or irregularities, Teravent may take measures including temporarily suspending or permanently ceasing trading with the counterparty, initiating Enhanced Due Diligence (EDD) procedures, requesting further information from the Account Holder, verifying the ultimate beneficial owners (UBOs) and re-screening them against sanctions and PEP lists, or conducting on-site verification where necessary.

Certain patterns or behaviours may indicate higher risk and trigger closer review. These include single transactions that are unusually large relative to the entity’s normal activity or industry norms, a high volume of small-value transactions, or transactions deliberately structured just below regulatory thresholds. Monitoring may also flag behaviour that is inconsistent with the stated business purpose, requests to route transactions through opaque intermediaries, or entities with unnecessarily complex ownership structures designed to obscure control.

All assessments and risk evaluations are conducted in accordance with established best practices, drawing on guidance from the UK Joint Money Laundering Steering Group (JMLSG), advisory notes from the Financial Intelligence Unit – India (FIU-IND), and typologies identified by the Financial Action Task Force (FATF). This structured approach ensures that Teravent maintains robust vigilance over platform activity, enabling proactive identification and mitigation of potential financial crime risks while supporting compliance with both UK and Indian regulations.

5. Training

Teravent recognises that preventing financial crime is a responsibility shared by all employees and stakeholders involved in its operations. To ensure that every team member understands their obligations under this Policy, it is mandatory for all new employees to review the KYC and AML guidelines as part of their onboarding process. Furthermore, all employees are required to review updated versions of the Policy annually to remain aware of evolving regulatory requirements and internal procedures.

In addition to general awareness, role-specific training is provided to staff whose responsibilities directly involve the Teravent Registry, client onboarding, or transaction monitoring. This training focuses on identifying and mitigating risks related to money laundering, terrorist financing, and other suspicious financial activity. Engineering and technical teams engaged in the development of the Registry or associated verification and monitoring tools receive targeted instruction on incorporating AML/KYC requirements into system design, ensuring that the platform itself supports real-time detection, compliance, and risk mitigation.

Through ongoing training and knowledge reinforcement, Teravent fosters a culture of vigilance, accountability, and proactive compliance, ensuring that all employees are equipped to uphold the highest standards of financial integrity and regulatory adherence.

6. Reporting

Teravent requires all employees to remain vigilant and promptly escalate any high-risk or suspicious activities to their Line Manager and the Compliance Officer. Reporting is triggered whenever there is evidence of potentially elevated risk, including cases where an Account Holder presents high-risk attributes during the onboarding process—such as being based in a FATF-designated high-risk jurisdiction—or where unusual or suspicious activity is identified during ongoing transaction monitoring. Employees must also report any indication of fraudulent behaviour, sanctions violations, money laundering, or potential financing of terrorism.

All reports are escalated and documented following Teravent’s internal protocols, which are designed to align with UK and Indian regulatory guidance and global best practices. This structured approach ensures that potentially risky cases are reviewed promptly and consistently, reducing the likelihood of financial crime while maintaining regulatory compliance.

7. Mitigations

Upon receiving a report of a high-risk or suspicious Account Holder, the Compliance Officer evaluates the case to confirm the risk level and determine the appropriate mitigation measures.

For new account applications, the process involves conducting Enhanced Due Diligence (EDD) as necessary, requesting clarifications or additional documentation from the prospective client, and assessing whether the entity continues to pose a significant risk. If the risk remains high, the application will be declined, preventing onboarding.

For existing Account Holders, Teravent may request further information to reassess risk. Where significant risk is confirmed, the account may be temporarily frozen to prevent any further transactions, and, if appropriate, an account closure procedure will be initiated. All actions are taken in compliance with contractual obligations and relevant legal requirements.

When communicating with clients about account restrictions or closures, staff provide only general explanations. Specific details regarding internal assessments, monitoring triggers, or suspicion indicators are never disclosed, in order to prevent tipping off and maintain compliance with UK MLR 2017 and Indian PMLA obligations.

In cases where the suspicious activity appears to involve criminal or unlawful behaviour, Teravent may submit intelligence reports to the appropriate authorities. In the UK, reports may be filed with the National Crime Agency (NCA) following Suspicious Activity Reporting (SAR) best practices. In India, reports may be submitted to the Financial Intelligence Unit – India (FIU-IND) or other relevant enforcement authorities. While Teravent is not currently classified as a formally obligated entity under MLR 2017 or PMLA, it adheres voluntarily to industry best practices for reporting high-risk or suspicious activity.

8. Record Keeping

Teravent maintains comprehensive and secure records to support compliance and audit readiness. All KYC documentation collected during onboarding, transaction data, ongoing monitoring logs, and communications regarding risk assessment and escalation are retained for a minimum of five years from the date of the most recent activity.

These retention practices ensure compliance with both UK MLR 2017 and Indian PMLA guidelines while allowing Teravent to conduct thorough reviews and investigations if needed. By maintaining detailed and accurate records, the company preserves transparency, accountability, and the integrity of its financial operations.