Anti-Money Laundering (AML) Policy

1.Scope

This policy applies to every person acting on behalf of Better Quality Assurance S.R.L. ("BetterQA," "the company"), in every country we operate in. That includes all employees, contractors, freelancers, directors, the Administrator (Tudor Brad), agents, intermediaries, and suppliers whose conduct is attributable to BetterQA.

The policy is built around Romanian Law 129/2019 on preventing and combating money laundering and terrorist financing (transposing the EU 4th and 5th Anti-Money Laundering Directives), and aligns with FATF Recommendations and the EU 6AMLD framework. Where local law in another jurisdiction we operate in is stricter, the stricter standard applies.

2.Our Position

BetterQA is a professional services company, not a financial institution. Even so, we are exposed to money laundering risk through the clients we onboard, the territories we invoice into, and the way we receive payment. We take that risk seriously. We will not knowingly accept funds, contracts, or business relationships that have the purpose or effect of disguising the origin of criminal proceeds, financing terrorism, or evading international sanctions.

3.Specific Obligations

Client onboarding (KYC). Before BetterQA signs a contract or issues a first invoice, the responsible commercial owner must collect and verify:

• Legal name, registration number, and registered address of the counterparty entity
• A current company extract (Companies House, ONRC, equivalent) or screenshot of the registry record
• Identification of the ultimate beneficial owner (UBO) where ownership exceeds 25%, with corroborating documentation
• Identity verification of the contract signatory (passport or national ID)
• Confirmation of the source of funds where the contract value exceeds EUR 50,000 over 12 months, or where any red flag is present
• Sanctions and PEP screening result, dated and stored against the client record

Payment hygiene. All client payments to BetterQA must arrive by bank transfer to a BetterQA corporate bank account in BetterQA's legal name. We do not accept:

• Cash, in any amount
• Cryptocurrency or stablecoins, unless specifically and contractually approved by the Managing Director after enhanced due diligence
• Payments from a different legal entity than the contracting counterparty, unless a written assignment is in place
• Payments routed through third-country intermediaries that the client cannot explain
• Over-payments or "round-tripping" where funds are sent and then partially refunded outside the normal credit-note process

Enhanced due diligence triggers. Apply enhanced due diligence (additional documents, ownership tracing, Managing Director approval) where any of the following apply: counterparty is registered in or pays from a country on the EU high-risk third country list; UBO is a PEP or close associate of a PEP; payment structure is unusually complex; sector is high-risk (cash-intensive retail, crypto exchanges, gaming, shell-pattern holding companies); contract value is disproportionate to the counterparty's apparent size.

Sanctions. No work may be performed for, no payment received from, and no payment sent to, any natural or legal person on the EU consolidated sanctions list, UK OFSI list, US OFAC SDN list, or UN consolidated list. Screening is repeated annually for ongoing clients.

Record keeping. KYC files, sanctions screening evidence, and supporting documents are retained for 5 years from the end of the business relationship, in line with Romanian Law 129/2019.

4.Reporting Channel

If you suspect that funds offered to BetterQA, or funds passing through any business relationship, may relate to money laundering, terrorist financing, or sanctions evasion, you must report it.

• Internal channel: [email protected] (anonymous reporting permitted)
• Acknowledgement within 7 days, outcome within 90 days, per EU Directive 2019/1937 and Romanian Law 361/2022
• Suspicious Activity Reports (SARs) to the Romanian competent authority are filed by the Managing Director to the Oficiul Național de Prevenire și Combatere a Spălării Banilor (ONPCSB) within the statutory timeline
• You must not "tip off" the client or counterparty that a report has been or may be filed. Tipping off is itself a criminal offence under Romanian Law 129/2019

See the separate Whistleblowing Policy for full procedure, protections, and external escalation routes.

5.Consequences

Breach of this policy is treated as gross misconduct. Depending on severity, the consequences may include:

• Disciplinary action up to and including termination of employment or contract
• Personal criminal liability under Romanian Law 129/2019, including up to 10 years' imprisonment for money laundering offences and significant individual fines for failure to report
• Corporate liability for BetterQA, including administrative fines up to 10% of annual turnover for serious AML failures
• Loss of ISO 27001 / ISO 9001 certification status if control failures are systemic
• Reporting to ONPCSB, ANAF, or other competent authorities where law requires

6.Review Cadence

This policy is reviewed at least annually by the Managing Director, or sooner if there is a material change in Romanian or EU AML law, in the company's client mix or invoicing markets, or following any reported incident. The review covers the KYC sample, sanctions screening evidence, and any SARs filed.

7.Owner