1. Introduction

Elite Company s.r.o., operating the PropHelix platform (the “Company”), is committed to

preventing money laundering, terrorist financing, and breaches of international sanctions.

This Anti-Money Laundering Policy (the “Policy”) is intended to ensure compliance with the applicable laws of the Slovak Republic, the European Union, and relevant international standards.

2. Purpose of This Policy

The purpose of this Policy is to:

• prevent the misuse of the platform for financial crime

• ensure compliance with applicable regulatory requirements

• implement effective Know Your Customer (KYC) and monitoring procedures

• protect both the Company and its users

3. Business Model

PropHelix is a proprietary trading platform offering:

• simulated trading accounts

• trader evaluation programs

• the opportunity to obtain a simulated funded account

The Company:

• is not a broker

• does not manage client investments

• does not accept client funds for investment purposes

Any fees charged by the Company are solely for access to educational and simulated services.

4. Definition of Money Laundering

Money laundering refers to the process of disguising or legitimizing funds derived from criminal activity.

This may include, in particular:

• concealing the origin of funds

• manipulating transactions or assets to obscure their origin

• using funds obtained through illegal activity

5. Regulatory Framework

The Company complies with:

• the laws and regulations of the Slovak Republic

• applicable European Union directives, including AMLD

• international sanctions lists, including OFAC and the EU sanctions list

6. Customer Identification (KYC)

Users may be required to complete a KYC process before accessing selected services.

Required documentation may include:

• a valid government-issued identification document

• proof of address not older than 3 months

Additional verification may include:

• selfie or video verification

• payment method verification

• confirmation of source of funds

7. KYC Verification Process

Verification is considered complete once the following requirements have been successfully fulfilled:

• identity verification

• address verification

• biometric verification, where applicable

The Company uses both automated and manual verification checks, including:

• verification of government-issued documents

• biometric comparison

• screening against sanctions lists and PEP (Politically Exposed Persons) databases

8. KYC Provider

The Company uses an external identity verification provider:

Veriff

Veriff provides:

• automated identity verification

• biometric verification

• fraud detection services

9. Risk Management

The Company applies a risk-based approach and may assess, among other factors:

• the user’s country of residence or nationality

• account behavior

• payment patterns

• the existence of multiple accounts

Users identified as higher risk may be subject to Enhanced Due Diligence (EDD).

10. Monitoring of Activities

The Company monitors account and platform activity to identify:

• suspicious transactions

• unusual or abnormal behavior

• attempts to misuse the platform or its services

The Company reserves the right to:

• suspend an account

• reject transactions

• request additional information or documentation

11. Prohibited Jurisdictions

The Company does not provide services to users located in, or citizens of, the following countries:

• Iran

• North Korea

• Myanmar

• Russian Federation

• Belarus

This list may be amended in accordance with applicable sanctions regimes and updated sanctions lists.

12. Prohibited Activities

The following activities are strictly prohibited on the platform:

• money laundering

• fraud

• identity theft

• the use of stolen or unauthorized payment details

13. Reporting of Suspicious Activity

Where illegal or suspicious activity is suspected:

• an internal review may be conducted

• the Company may, and where required must, report such activity to the relevant authorities

14. Data Retention

The Company retains the following records:

• identification data

• transaction data

• verification documents

Such records are retained for a minimum period of 5 years in accordance with applicable legal requirements.

15. Data Protection

Personal data is processed in accordance with applicable data protection laws, including GDPR, and is stored securely.

16. Employee Training

Employees receive regular training in the areas of:

• anti-money laundering

• fraud detection

• compliance

17. Technological Tools

The Company uses appropriate technological tools and systems, including:

• monitoring systems

• database systems

• KYC tools, including Veriff

18. Cooperation with Authorities

The Company cooperates with:

• law enforcement authorities

• regulatory and supervisory authorities

19. Enforcement of This Policy

Any breach of this Policy may result in:

• account suspension

• termination of the business relationship

• legal action, where appropriate

20. AML Officer

The Company has appointed a responsible person (AML Officer) to oversee compliance with this Policy and the implementation of AML measures.

21. Contact Details

Email: support@prophelix.com

22. Company Details

Company Name: Elite Company s.r.o.

Brand: PropHelix

Registered Address: Hlavná 2901/61, 080 01 Prešov

Company ID (IČO): 57 504 440

23. Changes to This Policy

The Company reserves the right to amend or update this Policy at any time in accordance with applicable law or internal requirements.

Any updated version becomes effective upon publication on the Company’s website.

Effective Date

02 April 2026