Anti-Money Laundering (AML) Policy

1. Objective
   Zero Emissions World (ZEW) is committed to the highest standards of ethics, transparency, and legal compliance.

   This policy aims to establish guidelines to prevent and combat money laundering (ML) and the financing of terrorism (FT), as required by national and European legislation.

2. Legal Framework
   This policy is aligned with the following legal and regulatory standards:

2.1 National Legislation (Portugal):

• Law No. 83/2017, of August 18 – Measures to combat money laundering (ML) and the financing of terrorism (FT), transposing Directive (EU) 2015/849.

• Law No. 97/2017, of August 23 – Legal regime applicable to the supervision of compliance with preventive ML/FT obligations.

• ASAE’s Regulation No. 686/2019 – Defines the specific duties to prevent and combat money laundering and the financing of terrorism of entities subject to ASAE’s supervision.

3. Scope

This policy applies to all ZEW team members, including employees, project managers, consultants, institutional partners, ambassadors, service providers, and any donor whose contribution meets the risk assessment criteria.

4. Definitions:

• Money Laundering (ML): (i) the conducts provided for and punished by article 368-A of the Penal Code; (ii) the acquisition, possession, or use of goods, with knowledge at the time of their receipt, that they originate from a criminal activity or participation in such an activity; and (iii) the participation in any of the acts referred to in the preceding subparagraphs, the association to commit said act, the attempt and complicity in its commission, as well as facilitating its execution or advising someone to commit it.

• Financing of Terrorism (FT): the conducts provided for and punished by article 5-A of Law No. 52/2003, of August 22, with subsequent amendments.

• Beneficial Owner: the individual or individuals who ultimately own or control an entity and/or the individual or individuals on whose behalf a transaction or activity is carried out, in accordance with the criteria established in article 30 of Law No. 83/2017.
  

5. Principles and Procedures

5.1. Compliance with ZEW’s purpose

ZEW’s management ensures the proper definition of the purpose(s) of each of the activities pursued by ZEW.

ZEW keeps its business purpose and objectives up to date as all times.

ZEW adopts risk-based procedures to ensure that the activities actually carried out and the way in which funds are used align with its purpose, objectives and values.

ZEW’s funds may only be used or allocated to achieve its purpose and objectives, and such use or allocation must always be within the specific activities carried out by ZEW.

It is expressly prohibited for ZEW to engage in activities that do not fall within its purpose or one of its objectives.

ZEW team members, including employees, who, in the performance of their duties, detect signs of non-compliance with the provisions of the previous paragraphs must report it immediately to ZEW’s management.

The records and the respective proofs referred to in the previous paragraphs must be kept in accordance with the terms and period provided in 5.9. below.

5.2. Suitability of ZEW’s Corporate bodies

ZEW verifies, prior to their election or appointment, the suitability of the members of its corporate bodies and other individuals responsible for its management.

The individuals concerned must provide ZEW with all the necessary information for this purpose.

The individuals concerned must immediately report to the person(s) with the authority in ZEW to dismiss them any subsequent changes to the facts relevant to assessing their suitability for the position, so that, when justified, their dismissal can be carried out.

5.3. General duty of information retention

ZEW maintains, at all times, information about its purpose and the objectives of its activities as well as promotes the performance of the necessary actions to ensure that such elements are always kept up to date.

ZEW also maintains information about the identity of its Beneficial Owners and other persons who control or direct its activities, including its corporate bodies and other individuals responsible for its management.

ZEW’s Beneficial Owners are duly registered in the Central Register of Beneficial Owners (RCBE), promoting the respective update whenever necessary in accordance with the applicable legislation.

5.4. Mandatory record of transactions

ZEW keeps record of all domestic and international transactions carried out.

The record referred to in the previous paragraph is accompanied by a reasonably detailed description of the transaction, including its nature and purpose, as well as the respective proof(s) of fund transfer.

The maintenance and circulation of unrecorded or concealed ZEW’s funds is expressly prohibited.

The creation of false, artificial, or virtual entries in the financial records of ZEW is expressly prohibited.

The maintenance of parallel or double accounting is expressly prohibited.

ZEW team members, including employees, who, in the performance of their duties, detect signs of non-compliance with the provisions of the previous paragraphs must report it immediately to ZEW’s management.

The records and the respective proofs referred to in the previous paragraphs must be kept in accordance with the terms and period provided in 5.9. below.

5.5. Crypto-assets

ZEW does not accept, perform nor takes part in any transactions performed in crypto-assets.

5.6. Know Your Donor/Partner (KYD/KYP)

In order to ensure that ZEW knows its counterparts, ZEW collects and keeps record of information on the same, either through public sources or directly, including but not limited to their business and corporate structure.

For this purpose, ZEW also collects and keeps record of information on the identity, professional background, and reputation of those in charge of the management of their counterparts, if applicable.

ZEW ensures, contractually or by another more appropriate means, that the counterparty is obliged to provide, whenever ZEW requests it, all additional information deemed necessary to fulfill its obligation to know its counterparties

ZEW team members, including employees, who have initial contact, in-person or remotely, with individuals or entities that:

(a) donate funds or goods free of charge to ZEW; or

(b) receive funds or goods free of charge from ZEW;

must obtain and verify the identity of these individuals or entities whenever the funds or goods have a value equal to or greater than €100.00 (one hundred euros).

For this purpose, ZEW team members, including employees, shall collect and keep record of the following information:

1. In the case of individuals:

   1. Full name;

   2. Date of birth;

   3. Identification document;

   4. Tax identification number (or equivalent); and

   5. Full address of permanent residence.

2. In the case of legal persons:

   1. Corporate name;

   2. Registered office;

   3. Legal person identification number (or equivalent); and

   4. Economic activity classification code (or equivalent).

If in the context of ZEW’s crowdfunding projects, before engaging in a given project, ZEW team members, including employees, shall always, irrespective of the amounts involved, collect and keep record of the information set out above as well as the following:

(a) Amounts of funding granted, itemized by supporter and by transaction; and

(b) Payment method.

Whenever objectively possible, the identification obligation set forth above must be fulfilled prior to the receipt or delivery of the funds or goods by ZEW.

When it is objectively not possible to fulfill the identification obligation set forth above prior to the acceptance or delivery of funds or goods by ZEW, it must be fulfilled immediately afterwards.

The identification obligation set forth above must be fulfilled whenever there is a new delivery or receipt of funds or goods that meet the requirements set forth above or, when conducted within the scope of an ongoing relationship, must be updated annually.

Whenever there are changes in the identification elements of the parties or their representatives, the elements collected for compliance with the identification obligations set out above must be updated.

In case of doubt regarding the content, authenticity, timeliness, accuracy, or sufficiency of the identification information and/or the documents provided for this purpose, ZEW team members, including employees, must report such a situation to their superior or to the management, to ensure full verification of the identification elements in question.

The information collected in compliance with the provisions set forth above and the corresponding supporting documentation must be retained for the period and under the terms set forth in 5.9. below.

It is expressly prohibited to accept and/or deliver funds or goods free of charge that:

(a) originate from or are destined for a person or entity for which it was not possible to fulfill the identification and due diligence obligation set forth above;

(b) originate from or are destined for a person or entity that refuses to provide the information and documentation necessary to comply with the identification obligation set forth above or who, having provided it, refuses to allow ZEW to retain a copy in compliance with the provisions of the preceding paragraph;

(c) originate from or are destined for a person or entity that, during their identification, provides information or documents that are manifestly false or do not generate sufficient guarantees of their authenticity.

5.7. Risk Assessment and Classification

When appropriate, ZEW applies internal risk analysis mechanisms, considering factors such as geographical location, transaction volume, the nature of the entity, and the historical relationship.

Clients or partners from high-risk jurisdictions identified by the EU or the FATF (Financial Action Task Force) will be subject to enhanced due diligence, as required by Law No. 83/2017.

5.8. Reporting Suspicious Activities

ZEW actively cooperates with the competent authorities, both national and European, including but not limited to the Central Department of Investigation and Penal Action (DCIAP), the Financial Intelligence Unit (UIF/PJ), other judicial and police authorities, as well as ASAE, in the prevention, investigation, and repression of any conduct that may constitute criminal or illegal acts, including by providing all elements whose retention is mandatory under the law, applicable regulations, and this Policy whenever necessary.

ZEW immediately informs the Central Department of Investigation and Penal Action (DCIAP) and the Financial Intelligence Unit (UIF/PJ) of any and all suspicions that certain funds may originate from criminal activities or be related to the financing of terrorism, maintaining confidentiality regarding the communications made and the identity of those who made them, in accordance with the terms set out by Law no. 83/2017 and ASAE’s Regulation No. 686/2019.

Copies of the communications to the authorities made under the law and this article are retained for the period and in accordance with the terms provided in 5.9. below of this Policy.

All communications and contacts made with the competent authorities under the law, applicable regulations, and the provisions of this Policy are covered by a duty of non-disclosure that applies to their existence, content, and any possible or known consequences, which all ZEW team members, including employees, who, for any reason, become aware of these facts must uphold.

5.9. Record Conservation

The documents, information and other referenced elements whose retention is expressly required by this Policy must be kept for a period of 7 years.

The retention of the documents, information, and other referenced elements is done on a durable computerized form that ensures conditions for their proper preservation and easy retrieval, as well as immediate access to them whenever requested by the competent authorities.

6. Awareness

All members of the ZEW team are informed and made aware of this Policy.

The organization promotes a "zero tolerance" culture for Money laundering and Terrorist financing practices and takes proactive measures to identify emerging risks.

7. Policy Review

This policy will be reviewed annually or whenever there are:

• Significant legislative changes;

• Changes in ZEW's operational risks;

• New funding vectors (e.g., new payment methods, international expansion, etc.).

8. Institutional Commitment

Zero Emissions World is committed to ensuring that all funds received or moved are in compliance with applicable legal and ethical obligations.

Transparency and integrity are core pillars of ZEW's mission to combat climate change.