COMPLIANCE & LEGAL

OUR COMPLIANCE APPROACH

Compliance forms an integral part of AIMM's business operations.

AIMM seeks to conduct its Commercial Intelligence Services in a manner that supports:

• commercial integrity;

• responsible business practices;

• information governance;

• protection of confidential information;

• anti-financial crime measures;

• intellectual property protection; and

• lawful commercial relationships.

AIMM's internal policies, governance framework and operational procedures are designed to support these objectives while maintaining clear boundaries regarding the services AIMM provides.

BUSINESS MODEL

AIMM operates as an independent provider of Commercial Intelligence Services.

AIMM researches, compiles and prepares Commercial Intelligence Deliverables using information lawfully available to AIMM at the time of compilation.

AIMM does not act as:

• a commodity trader;

• a buyer or seller of commodities;

• a commodity exchange;

• a broker acting on behalf of buyers or sellers;

• a payment service provider;

• a bank or financial institution;

• a logistics provider;

• a customs agent;

• an insurance provider; or

• a provider of legal, investment, financial, accounting or tax advice.

Commercial Intelligence Deliverables are supplied solely to support the Recipient's own independent commercial assessment and decision-making.

SCOPE OF OPERATIONS

AIMM's activities are limited to the preparation and provision of Commercial Intelligence Services.

Accordingly, AIMM does not undertake investment activities, capital deployment, project financing, lending, financial intermediation or any other regulated financial activity forming part of its business model.

ANTI-MONEY LAUNDERING (AML) & COUNTER-TERRORIST FINANCING (CTF)

AIMM is committed to conducting business responsibly and seeks to maintain appropriate procedures designed to reduce the risk of money laundering, terrorist financing, fraud and other forms of financial crime.

Where AIMM considers it appropriate, AIMM may:

• undertake Know Your Customer (KYC) procedures;

• verify the identity of prospective commercial counterparties;

• request information regarding the proposed commercial relationship;

• request information regarding the source of commercial funds where appropriate;

• decline to enter into, continue or complete a commercial relationship where satisfactory information is not provided;

• maintain records required for legitimate business, legal and compliance purposes; and

• cooperate with lawful requests from competent authorities where required.

The nature and extent of any compliance measures remain proportionate to AIMM's business model and the particular commercial relationship.

COMMERCIAL PAYMENTS

Payments made to AIMM represent commercial consideration for Commercial Intelligence Services and related Commercial Intelligence Deliverables.

Unless otherwise agreed by AIMM, payments should originate from the commercial entity responsible for the applicable contractual relationship or such other source as AIMM considers acceptable.

AIMM reserves the right to request information necessary to verify payment arrangements or to decline payments where AIMM considers this appropriate.

SANCTIONS COMPLIANCE

AIMM seeks to conduct its business in a manner consistent with applicable sanctions requirements.

Where AIMM considers appropriate, prospective commercial relationships may be assessed against relevant sanctions information and other compliance considerations.

AIMM reserves the right to decline, suspend or terminate commercial relationships where AIMM considers that an unacceptable compliance risk exists.

Each Client remains solely responsible for complying with all sanctions laws, export controls and trade restrictions applicable to its own business, jurisdictions and commercial activities.

CLIENT RESPONSIBILITIES

Each Client and Recipient remains solely responsible for:

• independently verifying all Commercial Intelligence Deliverables;

• conducting appropriate legal, commercial, financial, technical, operational, regulatory and compliance due diligence;

• satisfying its own internal governance and compliance procedures;

• obtaining any licences, approvals or authorisations it requires;

• complying with all laws applicable to its business activities;

• determining whether any Commercial Intelligence Deliverable is suitable for its intended purposes; and

• making its own commercial decisions.

Nothing supplied by AIMM transfers or reduces these responsibilities.

INFORMATION INTEGRITY

Commercial Intelligence Deliverables are prepared using information available to AIMM at the time of compilation.

Information originating from third parties may change, be amended, withdrawn, superseded or become unavailable without notice.

Accordingly:

• AIMM does not represent or warrant that third-party information will remain current after delivery;

• references to source documentation do not constitute independent certification or verification of third-party information; and

• Commercial Intelligence Deliverables are provided solely to support the Recipient's own independent assessment.

CONFIDENTIALITY

AIMM recognises the importance of protecting confidential business information.

Information exchanged during commercial discussions or contractual relationships may be handled in accordance with applicable confidentiality obligations, AIMM's internal governance framework and the applicable contractual documentation.

RECORD KEEPING

AIMM may retain business records, communications, contractual documentation and Commercial Intelligence records for legitimate business purposes including:

• commercial administration;

• legal compliance;

• accounting;

• dispute resolution;

• audit;

• intellectual property protection;

• information governance; and

• internal operational management.

Retention periods may vary according to the nature of the information and AIMM's operational requirements.

INTELLECTUAL PROPERTY

The methodologies, analytical techniques, Commercial Intelligence Deliverables, document structures, proprietary workflows, software tools and other intellectual property developed or used by AIMM remain the exclusive property of AIMM unless expressly stated otherwise.

Recipients shall not reproduce, distribute, modify, reverse engineer, decompile, exploit or otherwise use AIMM's proprietary Commercial Intelligence or intellectual property except as permitted by the applicable contractual documentation.

AIMM reserves all legal rights and remedies in respect of the unauthorised use or misappropriation of its intellectual property.

ETHICAL BUSINESS PRACTICES

AIMM seeks to conduct its business honestly, professionally and responsibly.

AIMM seeks to:

• conduct business with integrity;

• respect confidentiality;

• protect proprietary Commercial Intelligence;

• support responsible use of Artificial Intelligence;

• maintain appropriate governance practices;

• comply with applicable legal obligations; and

• continually review and improve its internal policies and procedures.

IMPORTANT NOTICE

This Compliance and Legal page provides a general overview of AIMM's compliance principles, governance practices and legal framework.

It does not constitute legal advice, regulatory advice, investment advice or a representation regarding the legal or regulatory obligations of any Client, Recipient or third party.

Commercial Intelligence Deliverables are provided solely to support the Recipient's independent commercial assessment.

Recipients remain solely and exclusively responsible for conducting their own legal, commercial, financial, technical, operational, regulatory and compliance due diligence before relying upon or acting upon any Commercial Intelligence Deliverable or related information.

Nothing on this website transfers responsibility for transaction execution, regulatory compliance, sanctions compliance, risk assessment or commercial decision-making from the Recipient to AIMM.