Preamble

Commitment to Financial Integrity

WE PLAN INTERNATIONAL TRADE (HK) LIMITED ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance. This policy is established in accordance with:

• the Drug Trafficking (Recovery of Proceeds) Ordinance, Cap. 405 (Hong Kong);
• the Organized and Serious Crimes Ordinance, Cap. 455 (Hong Kong);
• the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Cap. 615 (Hong Kong);
• the United Nations (Anti-Terrorism Measures) Ordinance, Cap. 575 (Hong Kong);
• the Financial Action Task Force (FATF) Forty Recommendations;
• applicable international sanctions regimes (OFAC, UN Security Council, EU).

Section 1

Scope of Application

This policy applies to all business relationships, transactions and operations conducted by the Company, including:

• trading operations (commodities, agro-industrial goods, consumer products, industrial equipment);
• intermediation and brokerage mandates;
• HK company incorporation and structuring services;
• Africa-Asia corridor and investment facilitation services;
• all counterparties: buyers, sellers, intermediaries, agents and service providers.

This policy applies regardless of the nationality, jurisdiction or size of the counterparty.

Section 2

Know Your Customer (KYC) Requirements

2.1 Standard Due Diligence

Before initiating any business relationship or transaction, the Company requires the following documentation from all counterparties:

2.2 Enhanced Due Diligence

Enhanced due diligence (EDD) is applied in the following circumstances:

• counterparties located in high-risk or non-cooperative jurisdictions (FATF grey/black list);
• Politically Exposed Persons (PEPs) or their close associates;
• transactions involving amounts above USD 500,000;
• complex, unusual or apparently non-economic transaction structures;
• counterparties from jurisdictions subject to international sanctions;
• any case where the Company has doubts about the veracity of the information provided.

EDD may include: third-party identity verification, direct telephone or video interview, independent verification of source of funds, engagement of external compliance advisors.

2.3 Ongoing Monitoring

The Company maintains ongoing monitoring of all active business relationships, including periodic review of KYC files, monitoring of transaction patterns, and immediate escalation in the event of any suspicious activity.

Section 3

Sanctions Screening

All counterparties are screened against the following sanctions lists prior to any engagement and at regular intervals during the business relationship:

• OFAC (Office of Foreign Assets Control — United States);
• UN Security Council Consolidated Sanctions List;
• European Union Consolidated Sanctions List;
• UK HM Treasury Financial Sanctions List;
• Hong Kong Monetary Authority (HKMA) sanctions guidance.

Section 4

Prohibited Activities & Red Flags

The Company will not engage with any counterparty or transaction where the following red flags are identified:

• refusal or inability to provide required KYC documentation;
• inconsistencies between the declared source of funds and the counterparty's apparent business profile;
• requests to use unrelated third-party payment accounts;
• transactions structured to avoid reporting thresholds;
• pressure to expedite transactions without adequate documentation;
• involvement of shell companies with no apparent economic purpose;
• counterparties based in jurisdictions with inadequate AML/CFT regimes;
• payments to or from high-risk or non-cooperative jurisdictions without adequate justification;
• use of fraudulent, forged or materially altered documents.

Section 5

Suspicious Transaction Reporting

Where the Company suspects that a transaction involves proceeds of crime or terrorist financing, it is required to file a Suspicious Transaction Report (STR) with the Joint Financial Intelligence Unit (JFIU) of Hong Kong, in accordance with the AMLO and the OSCO.

The Company and its personnel are prohibited from disclosing to the counterparty or any third party that an STR has been filed ("tipping off"), as required under Hong Kong law.

Staff involved in the identification of suspicious activity are protected from liability for good-faith reporting in accordance with applicable law.

Section 6

Record Keeping

The Company retains all KYC documentation and transaction records for a minimum period of seven (7) years from the date of the transaction or the end of the business relationship, whichever is later — in compliance with the AMLO Cap. 615 and FATF Recommendation 11.

Records are stored securely and are available for inspection by competent authorities upon lawful request.

Section 7

Data Protection

All personal data collected for AML/KYC purposes is processed in strict compliance with the Personal Data (Privacy) Ordinance, Cap. 486 (PDPO) of Hong Kong and, where applicable, the EU General Data Protection Regulation (GDPR — EU 2016/679).

KYC data is used exclusively for the purposes of client identification, due diligence and regulatory compliance. It is never sold, shared or used for commercial purposes.

For further information, please refer to our Privacy Policy.

Section 8

Compliance Contact

For any AML/KYC-related enquiry, document submission or compliance matter, please contact us:

We acknowledge all compliance enquiries within 48 business hours.