Introduction to the policy

Infinity Metals Limited is required to put in place appropriate systems and controls to combat money laundering and terrorist financing under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017).

For more details on the MLR 2017, see sections 9 and 10 below.

This policy contains the procedures we have developed to comply with the MLR 2017.

This policy applies to all our premises, employees, officers, consultants, contractors and to other workers including agency workers, casual workers, volunteers, interns and home workers.

All staff must be familiar with this policy and comply with its terms.

This policy does not form part of any contract of employment and we may amend it at any time.

Responsibility for anti-money laundering (AML) and counter-terrorist financing (CTF) compliance

The Company itself is primarily responsible for compliance with the MLR 2017, including all systems and control requirements.

We have appointed a board-level officer as the officer responsible for compliance with the MLR 2017 with Ian Taylor. Our nominated officer Ian Taylor has a separate responsibility to:

receive and assess suspicious activity reports (SARs)—see section 11 below; and determine whether the SAR gives rise to knowledge or suspicion (or reasonable grounds for knowledge or suspicion) that a person is engaged in money laundering or terrorist financing.