SCANDIC GROUP Compliance Statement

Introduction

SCANDIC GROUP is an international brand association SCANDIC ASSETS FZCO – represented by the SCANDIC TRUST GROUP LLC – in cooperation with the Legier Beteiligungs mbH based in Berlin. Business areas from media and digital, payment transactions and crowdfunding, real estate, financial trading, mobility, private aviation, yachting, healthcare and security solutions come together under the umbrella “SCANDIC by LEGIER”. This diversity brings with it regulatory requirements from different legal areas. In order to offer customers, partners and the public a reliable basis, the SCANDIC GROUP bundles all legal, operational, technological and reputational risks in a binding compliance management system and ensures that corporate management is carried out in a legally compliant, ethical and transparent manner.

Overview library

1. Compliance organization

The management of the SCANDIC GROUP has established a structured compliance management system. It covers the areas of law, data protection, risk management, information security and internal auditing. A binding policy stack regulates corporate governance, data protection, digital services, supply chain and human rights policy, modern slavery declaration, cookie guidelines and the protection of vulnerable people. Responsibilities are clearly defined and are carried out by a compliance officer and an interdisciplinary committee. This committee monitors compliance with laws and internal guidelines, reports directly to management and uses a risk-based approach that also includes the evaluation of new business areas.

2. Legal and regulatory obligations

The SCANDIC GROUP complies with national and international laws and standards. These include, among others, the General Data Protection Regulation (GDPR), the German Money Laundering Act (AMLA), regulations to combat terrorist financing, the Supply Chain Due Diligence Act, capital market and financial supervision rules as well as industry-specific requirements for aviation, medicine and media. The compliance department constantly monitors new regulations, carries out risk analyzes and adapts processes accordingly. Contracts, business practices and products are legally reviewed before launch to comply with laws and ethical standards.

3. Customer due diligence and know-your-customer (KYC)

As a provider of payment and crowdfunding services as well as financial products, SCANDIC GROUP carries out thorough customer due diligence. This includes identifying and verifying customers, assessing their risk profiles and continuously monitoring transactions. Politically Exposed Persons (PEP), sanctions and suspicious activity report lists are reviewed and suspicious activity is reported promptly. Business partners are carefully selected and must commit to adhering to our compliance standards.

4. Marketing and Advertising

Our marketing and advertising activities are transparent, honest and free of misleading statements. Product information and service descriptions are clearly formulated; Legal information such as risks associated with investments are fully disclosed. Advertising is not aimed at minors or particularly vulnerable groups of people. It is ensured that all communication channels – from print to online to social media – comply with legal requirements and internal conduct guidelines.

5. Sanctions screening and prohibited transactions

The SCANDIC GROUP carries out regular sanctions and embargo checks. Before business relationships and transactions, lists from the United Nations, the European Union, the USA and other relevant authorities are checked. Transactions involving weapons, drugs, gambling, pornography, extremist organizations or other prohibited goods and services are prohibited. If there are any suspicions, the transaction will be rejected and reported to the relevant authorities.

6. Whistleblower system

Employees, customers and suppliers can report possible violations via a secure whistleblower system. Reports can be made anonymously and will be treated confidentially. An independent team properly investigates allegations and takes action if necessary. Retaliation against whistleblowers is prohibited; The SCANDIC GROUP promotes an open corporate culture in which criticism and suggestions are welcome.

7. Training and awareness

Regular training courses teach all employees the content of compliance management and raise awareness of legal and ethical issues. New employees complete basic training; There are in-depth training courses for employees in risky areas (e.g. finance, data protection, sales). Training is documented and continually updated to cover new changes in legislation and technology.

8. Monitoring and continuous improvement

Compliance with compliance requirements is monitored through internal controls, audits and risk analyses. Deviations are documented, causes analyzed and improvement measures taken. The management evaluates the effectiveness and appropriateness of the compliance system annually. Feedback from employees, customers and authorities is incorporated into further development. In this way, the SCANDIC GROUP ensures that the compliance framework is adapted to new challenges and continuously improved.