AML Policy

I. GENERAL PROVISIONS

Policy on prevention of money laundering and terrorist financing (hereinafter – “the
Policy”) establishes the procedures of the company UAB Sapion Solution (hereinafter
– “the Company”) as obliged entity, for implementation and daily compliance of
the legal requirements on prevention of money laundering and terrorist financing (hereinafter –
“ML/TF”).
The Policy is prepared according to the Law on Prevention of Money Laundering and Terrorist
Financing of the Republic of Lithuania No. VIII-275 (hereinafter – ”the Law”),
Order of the director of the Financial Crime Investigation Service Under the Ministry of
Interior of the Republic of Lithuania “On instructions to deposit virtual currency wallet
operators and virtual currency exchange operators to prevent money laundering and / or terrorist
financing” (hereinafter – “the Order”), and other EU and national legal
acts.
The main activity of the Company is the provision of virtual currency exchange and virtual
currency deposit wallet services (hereinafter –
“the Services”) and related services in the Republic of Lithuania. According to
the Article 2 Paragraph 10 Points 10 an 11 of the Law, the Company as a virtual currency deposit
wallet and exchange operator is obliged to provide services according to the Law in order to
prevent ML/TF.
The Company assesses the risks of ML/TF using a risk-based approach and evaluates the following
types of risks:

risk related to the Customer’s attributes;
risk associated with the channel for the supply of a product, service,
transaction, or service delivery
risk related to the area (country and/or geographical).

The Policy is prepared considering that the Company does not provide financial services and cash
services. All of the Company’s services are provided electronically through a service platform
(website) operated by the Company.
At least annually or in the case of significant events, the Company will carry out a risk
assessment, monitor the adequacy of the measures set out in the Policy for the implementation of
the ML/TF, where necessary, new or adequate preventive measures shall be amended or
introduced.
This Policy must be followed by all employees of the Company. The obligations of the Company as
defined in the Policy must be understood as the duties of all employees of the Company unless it
is provided that certain duties of the Company must be performed by a specially designated
employee of the Company.
The Company shall notify the Financial Crime Investigation Service (hereinafter – “the FCIS”) in
writing of the appointment or change of the employee (hereinafter – “the AML Officer”)
responsible for implementation of prevention of ML/TF measures in the Company no later than 7
business days after their appointment or change.
This policy shall be accepted and approved by the resolution of the CEO and the AML Officer.

II. RISK ASSESSMENT AND MANAGEMENT

The Company shall apply a risk-based approach when implementing measures to mitigate the risk of
ML/TF.
The Company continually assesses and manages the ML/TF risks associated with the Company’s
business relationship or incidental transactions. The Company’s risk assessment consists of:

Risk assessment at the Company level, which covers all activities of the Company, helps
identify areas in which the Company has to implement priority risk management measures
commensurate with the risks and the business specificities of the Company, the scope of its
activities;
Risk assessment of relationships and transactions with customers and transaction validation,
which includes identification, other KYC procedures and ongoing monitoring;
Continuous monitoring of the level of risk arising from the ongoing monitoring of customer
transactions, monetary operations and status to match the Company’s customer profile and be
not suspicious, ensuring that the information available to the Company is relevant, allowing
an assessment of whether the level of risk has remained unchanged.

Comprehensive measures are applied by the Company to determine the risk of ML/TF both before and
after establishing a business relationship with the customer, by analyzing the customer’s
behavior and monetary operations, transactions carried out and information provided (documents)
by him/her.
Customers of the Company are divided into following three risk groups:

Low-risk, customers who carry extremely low risk of ML/TF, including low risk to the
Company’s reputation. Low risk group customers include all those who fulfil one or more of
the low-risk attributes listed in Annex 1 of this Policy.
Medium-risk, customers rated as being at risk for some ML/TF by one or more attributes, but
their status or operations carried out by them would not have the same impact on the
Company’s reputation as high-risk customers or activities thereof. Medium-risk group
customers include all those who do not fall under low or high risk customer categories as
indicated in Annex 1 of this Policy.
High-risk, customers who have one or more of the attributes of increased risk of ML/TF and
in respect of whom the Company has a reasonable suspicion that they may significantly
adversely affect the Company’s reputation. Higher risk group customers include all those who
meet one or more of the high-risk attributes listed in Annex 1 of this Policy.

Customers are assigned to one of the identified risk groups when establishing business
relationships. Subsequently, the risk profile of the customer may be changed in the light of the
results of the monitoring of business relationships.
The customer risk assessment is built on the principle that higher risk is given a bigger risk
score.
The establishment of the business relationship with high-risk customers must be approved by the
AML Officer.
The customer risk assessment, both prior to establishing a business relationship and updating
the customer’s data, is performed by employees responsible for the customer’s onboarding. Only
after the customer’s risk assessment is completed, a decision is made on establishing a business
relationship.
When assessing the risk of the customers, the primary aim is to evaluate all information
available about the customers.
During assessment of customer’s risk and establishment of business relationship the Company
shall collect duly filled-in and executed Company’s customers and/or ultimate beneficial owner
questionnaire(-s) in accordance to section V of this policy. The Company’s customers and
ultimate beneficial owner questionnaire are presented in annexes of this Policy, accordingly Annex 2 and Annex 4.

III. CUSTOMER’S TRANSACTIONS AND OPERATIONS MONITORING

After establishing a relationship with the customer, the customer’s business relationships,
including transaction and operations, are monitored on an ongoing basis- ongoing customer due
diligence (ODD) is applied. This shall ensure that transactions and operations are consistent
with the Company’s information of the Customer, its business, risk profile and source of funds.
The Company maintains real–time and retrospective monitoring of business relationships and
operations.
Employees of the Company (incl. the CEO and the AML Officer) must monitor customer’s
transactions on an ongoing basis for any unusual operations or activities. Unusual features may
be related to the size of the transaction, which is inconsistent with the customer’s financial
position or past known business, the customer’s knowledge or experience, the unusual nature of
the transaction as distinguished from other customer’s methods of operation or similar usual
business practices, the complex structure of the transaction as compared to similar transactions
in a similar profile of the customer or the market. ODD also means that the Company periodically
updates of customer’s information.
In the event of any employee of the Company having any doubts about the legality, economic or
legal validity of the customer’s activities or of any particular operation or transaction, its
non-consistence with customer’s personal or business profile, sources of funds or financial
capacity, the employee must immediately notify the AML Officer, who must then investigate
further and determine decide on the necessity of reporting to the FCIS of the customer’s
activity or transaction.
When monitoring the customer’s activities, transactions and operations, particular attention
must be paid to:

complex or unusually large transactions and any unusual transactional structures that have
no apparent economic or visible legitimate purpose, and business relationships or operations
with customers from third countries, where, in accordance with official information
published by international intergovernmental organizations, measures to prevent ML/TF are
insufficient or do not meet international standards.
any threat of ML/TF that may arise from the use of the services provided or the transactions
carried out in order to conceal the identity of the Customer or the beneficial owner, as
well as in respect of any business relationship or transaction with the customer who has not
been identified through direct presence and, where necessary, immediate measures are taken
to prevent the use of money for ML/TF.
whether the customer or a beneficial owner is included in the consolidated list of the
United Nations of persons, groups and entities and bodies subject to EU financial sanctions.
whether the customer or the beneficial owner has no links with countries that are classified
in the category of higher risk countries: they are subject to European Union sanctions or
other restrictive measures, as well as to the countries identified by the Financial Action
Task Force as high risk or non-cooperative countries.

The Company has ongoing control over its operations for possible violations of international
sanctions. Depending on the nature of the Company’s activities – provision of virtual currency
services – the Company implements this obligation through a third-party monitoring tool.
The results and conclusions of unusual customer activities, transactions and operations
investigations must be recorded in writing.
All communications to the FCIS are provided by the Company’s CEO or the AML Officer who is
assigned to perform this function.
In case the Company has established a business relationship with the customer, determined as a
high-risk customer, the Company applies enhanced ongoing customers due diligence (EODD). In
addition to the measures applied for ODD, the Company shall monitor and analyze the following
actions of high-risk customer:

Transaction types (e. g. series of high-value cryptocurrency transactions in a short period
of time, instant withdraw of cryptocurrency deposits with no transaction activity);
Transaction patterns (e. g. frequent transfers of large amounts of crypto within a set
period of time, to the same account from more than one person);
Anonymity (e. g. multiple cryptocurrency wallets controlled from the same IP address, IP
associated with suspicious sources);
Senders and recipients (e. g. elderly or financially vulnerable customers engaging in
high-volume cryptocurrency transactions);
Source of funds (e. g. transactions involving cryptocurrency accounts with known links to
illegal activities, such as fraud, extortion, etc.).

If the employee (incl. the CEO and the AML Officer) becomes aware or otherwise suspects that a
transaction, operation, or customer activity is suspicious, or for any other reason listed in
this Policy would be reported to FCIS, he/she will promptly record it, re-examine, carry out
further examination of the information available in order to assess whether there is a basis for
providing such information to the FCIS and, where available, submit the information in the
format, procedures and timelines set by the FCIS.
All employees of the Company, without exception, must be prohibited from informing the customer
or any other person that information about the customer’s operations or transactions, or any
other information, has been provided to the FCIS or other supervisory authority.
The Company or its employees are not liable to the customer for failure to perform their
contractual obligations or for damage if this occurs as a result of suspending an operation or
transaction and reporting the allegations to the FCIS or because of failure by the customer to
provide data to confirm his identity, or providing incomplete or incorrect information, or if
customer or his representative avoids providing the information necessary to identify
him/her.
No liability must be imposed on Company’s CEO, the AML Officer or other employees who, in good
faith, report information on suspected ML/TF or suspicious operations or transactions to the
FCIS. Likewise, they may not be subject to any disciplinary action by the Company.
The Company must notify the FCIS immediately, no later than within 1 (one) business day after
the occurrence of such information or suspicion, if the Company is aware or suspects that assets
of any value are directly or indirectly derived from a criminal offence or by participating in a
criminal offence.
Where it is determined that the customer carries out a suspicious operation or transaction,
regardless of the amount of the operation or transaction, it is mandatory to suspend the
operation or transaction (unless due to the nature of the operation or transaction, the manner
in which it is performed or other circumstances it is objectively impossible) and no later than
3 business hours from the time of the transaction or the suspension of the monetary operation to
report this operation or transaction to the FCIS. If, due to the nature of the operation or
transaction, the manner in which they are performed, or other circumstances, the operation or
transaction has not been suspended, the FCIS must be notified no later than 3 business hours
after such operation or transaction is identified. Immediate reporting is also required when the
Company employees receive information that the Customer intends or will attempt to execute a
suspicious operation or transaction.
The Company is required to unilaterally suspend a suspicious operations/transaction and upon
receipt of a written order from the FCIS must suspend any suspicious operation or transaction
performed by the customer for a period of up to 10 business days from the time or circumstances
specified in the order. During this period, the Company’s suspended transaction/operation may be
renewed only with the permission of the FCIS.
If the Company is not obligated to execute the temporary restriction of the ownership rights
within 10 business days after the notification or FCIS order has been received, the operation or
transaction shall be resumed.
Notification of suspicious operations or suspicious transactions to the FCIS must be submitted
by logging in to the FCIS information system and filling in the approved electronic form for the
provision of information on suspicious operations or suspicious transactions.
Only in exceptional cases, should the Company not be able to access the FCIS information system
and complete the information submission form, or would not be able to do so for other technical
reasons, it may also, in emergency cases, submit the information to the FCIS by phone, fax or
email.
The suspicious transaction report form must include:

identity information of the customer, his representative (for natural persons – full name,
date of birth, personal code; for legal entities – name, legal form of legal entity,
registered address, legal code, if any).
to what kind of criteria approved by the FCIS, to recognize that the operation or
transaction is considered to be suspicious, the operation or transaction is in conformity.
method for performing a suspicious operation or suspicious transaction.
the date of the suspicious operation or suspicious transaction, a description of the
property to which the transaction relates and its value.
Deposit wallet management methods.
contact information of the customer, his representative (phone numbers, e-mail addresses,
contact persons).
A beneficiary in whose favor a suspicious operation or suspicious transaction is performed
(for natural persons – full name, date of birth, personal code; for legal entities – name,
legal form of legal entity, registered address, legal code, if any).
date and time of suspension of the suspicious operation or suspicious transaction.
if the suspicious operation or transaction has not been stopped, – the reasons for not
stopping it.
other information that the Company considers relevant.

The Company will report to the FCIS the customer identifying data and information on executed
virtual currency exchange operations or transactions in the virtual currency where the value of
such monetary operation or transaction equals or exceeds EUR 15 000 in Fiat currency or virtual
currency, regardless of whether the transaction is made in one or several related monetary
transactions.
Multiple related transactions mean multiple virtual currency exchange operations or transactions
in virtual currency during the day, where the total amount of operations and transactions equals
or exceeds EUR 15 000 or the equivalent in fiat currency or virtual currency.
Notification of operations or transactions of EUR 15 000 or more must be submitted to the FCIS
without delay and no later than 7 business days after the date of the execution of the monetary
operation or transaction.

IV. IMPLEMENTATION OF SANCTIONS

The AML Officer is an employee appointed by the Company who arranges the implementation of
financial sanctions, is responsible for suspending the disposal of the deposit wallets, regular
updating of the list of entities subject to financial sanctions or the selection of eligible
third party suppliers to provide consolidated updates of international lists of financial
sanctions and quality control of their services, reporting to FCIS and other authorities
responsible for overseeing the implementation of international sanctions.
The Company must:

implement financial sanctions.
Check in the consolidated databases used by the Company, and in their absence or if they are
inoperative, in direct sources, whether the Company’s customer and its beneficial owner are
not included in the list of entities and their groups, which are subject to United Nations
Security Council resolutions against terrorism, a consolidated list of the European Union’s
financial sanctions, as well as the lists of financial sanctions issued by the United States
Treasury Department’s Office of Foreign Control and/or the Republic of Lithuania.
pay particular attention to customers from countries on the lists of non-cooperating states
and territories drawn up by the FATF and the European Commission, and operations or
transactions carried out on their own or on their behalf.
restrict the right of customers included in the abovementioned international financial
sanctions lists to operate, use and dispose of the virtual currency and the Fiat currency
held in the Company, subject to the implementation exemptions provided for in international
organizations decisions and/or European Union legislation.
immediately terminate or suspend the obligations incurred prior to the imposition of the
international financial sanctions in the Republic of Lithuania for the period of the
implementation of the international financial sanctions.
to terminate immediately – unilaterally or by agreement of the parties – transactions
concluded prior to the imposition of financial sanctions in the Republic of Lithuania, or to
suspend their execution for the period of implementation of financial sanctions.
inform the FCIS of the suspension of the accounts of the customers subject to financial
sanctions.
provide information on the implementation of financial sanctions and all data necessary for
supervision to the FCIS.

Company employees and customers are prohibited:

to carry out actions which are prohibited by international sanctions implemented in the
Republic of Lithuania.
to enter into transactions which would be contrary to international sanctions implemented in
the Republic of Lithuania.
to assume new obligations, the fulfillment whereof would be contrary to international
sanctions implemented in the Republic of Lithuania.

V. CUSTOMER AND BENEFICIAL OWNER IDENTIFICATION

The Company’s employees whose functions include performing prevention of ML/TF (hereinafter –
“the Responsible employees”) are responsible for the identification of the customer, its
representative and the beneficial owner, collection and initial verification of customer’s, its
representative and beneficial owner data and documents.
The Company shall take steps to identify and verify the identity of the customer, its
representative and the beneficial owner in the following cases:

Before starting a business relationship.
Before performing occasional virtual currency exchange operations or occasional transactions
in virtual currency equal to or exceeding EUR 700 or the equivalent in foreign or virtual
currency, or by making an occasional deposit or withdrawal of virtual currency in the amount
of or exceeding EUR 700 or the equivalent in a foreign or virtual currency, whether the
transaction is concluded in one or more related transactions (the value of the virtual
currency is determined at the time of the monetary transaction or transaction), unless the
identity of the customer and the beneficial owner has already been established.
When there are doubts about the accuracy or authenticity of previously obtained customer and
beneficial owner identities.
In any other case where there is a suspicion that ML/TF activities are, have been or will be
carried out by the customer.

The Company’s Responsible employees shall be responsible for reviewing the quality of the
customer’s file, verifying the data in independent reliable sources available to the Company
(lists of politically exposed persons, international sanctions, etc.). These responsible
employees shall also perform risk assessment and assignment of the customer to the risk category
and other compliance procedures as provided in the Policy.
After gathering all the necessary information about the customer (duly filled-in and executed
customer questionnaires), the Responsible employees first identifies the customer’s risk
group.
Upon making a decision to establish a business relationship with the customer, the Responsible
employees, while providing the services to the customer, shall continue to monitor the customer
on a regular basis.
Customer and beneficial owner has to provide the following documents and information for
identification purposes:

Passport or ID copy if the customer, its representative, beneficial owner is a natural
person.
Utility bill indicating residence address of natural person.
Apostilled or legalized commercial excerpt of the company if customer is legal entity
(translated to English language).
Apostilled or legalized Articles of Association of the company if the customer is a legal
entity (translated to English language).

The Company only considers provided documentation form the customer suitable if scanned copies
and/or good quality photos are provided to the Company.
In case the Responsible employee determines a customer as a low-risk customer, the Company might
not apply rules indicated above in Section V of this Policy. The Company then:

collects correctly filled-in and duly filled-in and executed customers questionnaires.
ensures that the first payment of the customer would be carried out through an account with
a credit institution, registered in a Member State of the European Union.

If the Responsible employee determines customers category as a high-risk, in addition to the
documents listed above in Section V of this Policy, the Company shall:

obtain additional information on the customer and on the beneficial owner;
obtain additional information on the intended nature of the business relationship;
obtain information on the source of funds and source of wealth of the customer and of the
beneficial owner;
obtain information on the reasons for the intended or performed transactions;
obtaining the approval upon paragraph 6 Section II of this Policy;
conduct EODD of the ongoing business relationship with these by increasing the number and
timing of controls applied, and selecting patterns of transactions that need further
examination;
ensures that the first payment of the customer would be carried out through an account with
a credit institution, registered in a Member State of the European Union.

It is forbidden to enter into transactions, to establish or continue business relationships,
provide Services when customer identification is not possible in accordance with this Policy:

if the customer does not provide data proving his identity.
if the customer does not provide all data or data is incorrect.
if the customer or his representative avoids providing the information necessary for his
identification or avoids providing the information necessary to identify the beneficial
owner, or the data provided is not sufficient.

If the customer avoids or refuses to provide additional information to the Company at its request
and within the time limits, the Company shall take measures to mitigate the ML/TF risk in
accordance with this Policy. The Company may also refuse to execute transactions or operations,
suspend transactions or terminate business relationships with the customer. Upon termination of
the business relationship, the Responsible employees must report such customer and other related
information into the registration journal of customers with whom transactions or business
relationships are terminated (Annex 5) in accordance with the procedure set forth in this
Policy.
If proper identification, verification, or follow-up is not possible, Responsible employees of
the Company who notices such a case must immediately notify the Company’s AML Officer. The AML
Officer shall decide on the advisability of reporting a suspicious operation or transaction
report to the FCIS.
The customer and/or its representative shall perform identity verification remotely via tools
presented by the Company.
The documents, data or information submitted to the Company during the identification of the
customer and the beneficial owner must remain true, accurate and up-to-date throughout the
business relationship with the Company.
The data of customers, both existing and new, is updated as the circumstances surrounding the
customer change, as new circumstances become evident, and periodically, depending on the
customer’s level of risk.
High-risk customer data must be updated at least once a year, medium-risk customer data is
updated at least every 2 years, low-risk customer data is updated upon learning of any changes,
but at least every 3 years.
If the customer has initiated updates in his account information, the changes must be evaluated,
and risk should be reassessed accordingly.
If the changes in the customer’s information resulted in a change of the customer’s risk level,
the date from which the customer’s data must be updated is renewed according to their risk
level.
If the customer did not update his/her data when required according to his/her risk level during
the period of 3 months, services provided by the Company to the customer will be limited.
Updating the data means that it is obligatory to check that the Company has up-to-date
information about the customer, its representatives and beneficial owners. It is necessary to
ensure that the transactions and/or operations executed by the customer so far comply with the
information available to the Company on the customer, its activities and the source of
funds.
During the review, it is always mandatory for customers to be screened for being included in the
sanctions lists, changes in their status of politically exposed persons or existence of any
negative information. If the functionality of the systems used by the Company allows, such
verification must not be periodic, but is performed on a continuous basis through consolidated
databases, whereby once entered, the customer’s information is constantly verified and any
changes in customer status are reported to the Company’s CEO who periodically reviews system
alerts for potential new results related to changes in the customer status and takes appropriate
action.
Evidence of the review is stored in the customer’s electronic file in the Company’s database.

VI. KYC AND CUSTOMER DUE DILIGENCE

Customer due diligence (CDD) is a key responsibility of the Company in the implementation of the
prevention of ML/TF and includes:

Customer identification and verification based on provided documents, data and information
obtained from an independent and reliable source.
Identification of the beneficial owner and taking reasonable steps to verify that the named
person is in fact the final beneficial owner and to verify his identity.

The data provided by the customer must be verified on the basis of documents, data or information
obtained from a reliable and independent source.
The information must be verified by various means and sources available, including:

checking the consistency of the information received (whether there are illogical or
unexplained facts, inconsistencies).
comparing the information provided by the customer with the content of official documents
provided by the customer or received at the initiative of the Company, information contained
in public registers.
using targeted web search: for example, by typing in the customer’s name and certain
keywords, depending on the search context, using information available on social networks to
identify the customer’s relations, etc.
using other reliable sources depending on the information to be verified.

VII. STORAGE OF INFORMATION

The Company shall maintain the following journals and database:

Database/ journal for registration of customers with whom transactions or business
relationships have been terminated in the cases provided for in the Policy or in other
circumstances related to the prevention of ML/TF (Annex 5).
Database/journal of virtual currency exchange operations or transactions in virtual currency
amounting to or above EUR 15 000 or equivalent in Fiat currency or virtual currency (Annex 6).
Database/journal of reports submitted to FCIS on suspicious operations and transactions (Annex 7).

The information in the listed registration databases shall be maintained and stored in the
Company’s information systems. Data may be entered in the databases no later than within 3
business days after the date of the transaction or suspension of transaction/termination of a
business relationship, either manually or automatically.
Copies of the customer’s identity documents, beneficial owner’s identity data, other data
received during the customer’s identification, documentation shall be retained for 8 years from
the date of termination of transactions or business relationships with the customer.
Business correspondence with the customer must be stored for 5 years from the end of
transactions or business relationship with the customer in paper or electronic form.
Documents or information supporting operation or transaction or other legal instruments relating
to the performance of operations or transactions must be stored for 8 years from the date of
operation or transaction.
Documents analyzing the results of the transaction investigation are stored in an electronic
database for 5 years.
Retention periods may be further extended additionally for a period not exceeding 2 years, upon
motivated instruction of the competent authority.

VIII. TRAINING OF THE COMPANY’S EMPLOYEES

All employees of the Company shall be introduced to the Policy upon their appointment by their
signature. The CEO of the Company must ensure that all newly recruited employees are made aware
of this Policy in writing and receive training, depending on the functions performed by the
employee.
The Company must review and, where necessary, update its internal control procedures:

strengthen the applicable internal control procedures upon receipt of an order from the
FCIS.
upon significant events or changes in the Company’s management and operations.
periodic monitoring of the implementation and adequacy of internal control procedures.

The CEO of the Company must ensure that the relevant employees of the Company are aware of the
legal acts and requirements applicable to them and the provisions of this implementing Policy.
These measures shall include participation of their relevant employees in special ongoing
training programs to help them recognize the actions which may be related to ML/TF and to
instruct them as to how to proceed in such cases.
Responsible employees must continually upgrade their skills, following the Republic of
Lithuania, European Union legislation updates, recommendations of FATF and other organizations,
to seek to participate in the training on ML/TF prevention and enforcement of international
sanctions (courses, seminars, internships, etc.).
The CEO of the Company also identifies the need for internal training of the Company’s
employees. Any other member of the compliance department may also indicate such need.
The CEO of the Company must ensure that Company’s employees are informed in a timely manner of
material events occurring inside or outside the Company, incidents affecting the effectiveness
of prevention of ML/TF or sanctions.

IX. FINAL PROVISIONS

The implementation of measures for prevention of ML/TF is organized by the AML Officer in liaison
with the FCIS.
The CEO of the Company must ensure that the AML Officer has access to all information necessary
to perform their functions, including information relating to the identity of the customer and
the beneficial owner customer’s business relationship and other information.
This Policy is approved by the CEO and the AML Officer of the Company. This Policy and
appendices to the Policy shall take effect from the date of its approval unless otherwise
specified. The Policy may be withdrawn, amended and/or supplemented only by a decision of the
CEO and the AML Officer of the Company and shall enter into force on the day following the date
of adoption of such amendments and/or additions. All employees of the Company are familiarized
with the changes immediately.

X. Legal information

Company Name: Sapion Solution UAB

Company Number: 306182986

Legal Address: Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius,
Lithuania

Email: [email protected]