The Asset management Code for independent asset managers as members of ARIF

Confidia AG "Confidia" Trading as "How To Pay"

Regulatory Supervision

Confidia AG ("How To Pay") is an authorized member firm of Association Romande des Intermediaires Financiers ("ARIF") (Member No.: 3188), and as such is supervised by ARIF in its capacity as an SRO officially recognized by the Swiss Financial Market Supervisory Authority (FINMA), with dual supervision pursuant to (1) independent asset management and; (2) the Anti-Money Laundering Act (AMLA). The rules of professional conduct of ARIF regulate the content of the asset management agreement and how it must be implemented (asset manager's duty of trust, information and due diligence towards the customer and regulation of the asset manager's compensation), with due attention aid to the protection of investors.

Anti Money Laundering (AML)

Confidia is subject to provisions on Anti Money Laundering (AML) under the laws of Switzerland, which are in accordance with the FATF recommendations (Switzerland is a member country of the Financial Action Task Force FATF). This means in particular that Confidia has to identify its customers and establish the beneficial owner's identity. The AML compliance policies approved by the Management Board include inter alia the processes for the identification of the customers and establishing the identity of the beneficial owner. The policies also cover the collection of information regarding the customers' business activities, relationships with Politically Exposed Persons and record retention procedures. Furthermore, Confidia regularly provides AML training to relevant employees and does not provide banking services to any bank that does not maintain a physical presence in any country and that is not a regulated affiliate. The anti-money laundering policies are applicable to head office and branches alike and are in accordance with the Wolfsberg anti-money laundering principles.

Director (Verwaltungsrat)

CEO Founder & Systems Development Manager: Mr Cameron McKean

Email: cameron@confidia.ch

Director (Verwaltungsrat)

European Operations Manager: Richard Bunch

Email: richard@confidia.ch

Registered office address

Rigistrasse 2

6300 Zug

Switzerland

Canton

Zug

Company number (UID)

CHE-106.916.441

Commercial register number

CH17030006463

Date of formation

30 April 1971