Compliance Statement

Version 2 | Approved 25 March 2026

Message from the Founder

Clients trust GMA to tell them the truth about their compliance exposure, even when it’s uncomfortable. That trust only holds if we apply the same rigor to ourselves that we ask of every institution we advise. This Compliance Statement is a summary of how we do that — across AML/CFT, sanctions, anti-bribery, cybercrime, and the people we hire to do this work.

Wissam Maroun, CAMS | Founder & General Manager, GMA Consultancy S.A.R.L

1. Our Compliance Commitment

GMA Consultancy S.A.R.L (“GMA”) is committed to the highest standards of integrity, professionalism, and ethical conduct in all its activities.

As a compliance and risk advisory firm, GMA promotes good governance and supports financial and non-financial institutions in building compliance frameworks aligned with international standards.

GMA is committed to AML/CFT requirements, sanctions compliance, anti-bribery and corruption standards, combating cybercrime and fraud, data protection laws, and ethical principles across its operations. This Statement is a summary of GMA’s compliance posture; it is given full operational effect through GMA’s wider governance suite, including the Anti-Bribery and Corruption Manual, the Code of Conduct, the Official Digital Presence & Institutional Communication Statement, and the Website Privacy Policy (GMA-PRIV-2026-001), each published at www.gmaconsultancy.com.

2. Governance and Oversight

GMA is a single-partner limited liability company. The Managing Partner oversees the implementation of all compliance policies.

An independent compliance oversight function ensures adherence to laws, best practices, and ethical standards. Policies are reviewed periodically to address evolving regulations and risks.

3. Customer Due Diligence

GMA conducts appropriate customer due diligence (CDD) and risk assessments to ensure its services are not misused for illicit purposes.

CDD measures include:

• Identification and verification of clients and beneficial owners.
• Screening against local and international sanctions and adverse media.
• Assessing client business activities and engagement purpose.
• Enhanced Due Diligence for higher-risk clients or jurisdictions.
• Ongoing monitoring to detect emerging risks.

Any suspicion of money laundering or terrorism financing is reported promptly to the relevant supervisory authority.

GMA may decline or terminate engagements presenting unacceptable risks.

4. Sanctions Compliance

GMA complies with applicable sanctions issued by the UN, EU, OFAC, and HM Treasury.

GMA refrains from engaging in or facilitating activities involving sanctioned parties. Any sanctions-related suspicious activity will be reported to the competent authority immediately.

5. Anti-Bribery and Corruption

Measures include:

• Periodic assessment of corruption risks.
• Ensuring employees understand obligations under ABC laws.
• Due diligence on suppliers and partners.
• Disciplinary measures for violations.

Any detected or suspected bribery or corruption case will be reported to the relevant authority. These commitments are given full operational effect in GMA’s Anti-Bribery and Corruption Manual (GMA-ABC-2026-001).

6. Combating Cybercrime

GMA recognizes cybercrime as a major threat to the confidentiality, integrity, and security of information.

Cyber-protection measures include:

• Restricting exchange of sensitive information (including financial documents) to secure and encrypted channels.
• Confirming all sensitive or financial instructions using two independent authenticated communication methods.
• Strict access controls limiting sensitive information to authorized personnel.
• Updated firewalls, antivirus, secure configurations, and continuous system monitoring.
• Encrypted data storage, secure backups, and protection from data tampering or loss.
• Cybersecurity compliance requirements for external service providers and digital tools used by GMA.
• Continuous monitoring for cyber threats with immediate incident response.
• Employee training on cyber hygiene, phishing, fraud, and social engineering risks.

GMA is committed to maintaining a strong cybersecurity posture and protecting all client data from cybercrime threats.

7. Staff Background Checks and Awareness

GMA ensures employees possess the integrity and ethical standing required for compliance work.

Staff background check measures include:

• Pre-employment background checks for all full-time and contractual staff, covering identity verification, employment history, integrity concerns, and exposure to financial crime risks.
• Annual background reviews for key staff members occupying critical or sensitive roles.
• Ongoing awareness programs covering AML/CFT, sanctions, anti-bribery, data protection, and cybersecurity.

Training and awareness initiatives ensure employees understand their obligations, can identify suspicious behavior, and know reporting requirements to supervisory authorities.

8. Code of Conduct and Disciplinary Measures

GMA’s Code of Conduct (GMA-COC-2026-001) outlines expectations for professionalism, confidentiality, conflict-of-interest avoidance, and adherence to all compliance obligations.

Violations may result in disciplinary action, including termination.

Any matter involving potential financial crime, bribery, or terrorism financing is escalated immediately to supervisory authorities.

9. Independent Review and Continuous Improvement

GMA’s compliance framework is periodically reviewed by qualified independent parties to ensure alignment with best practices. Recommendations are implemented promptly to strengthen controls and enhance effectiveness.

10. Our Ethical Culture

GMA believes that transparency, accountability, and ethical conduct form the foundation of its advisory services and long-term client relationships.

Approval

This Compliance Statement is approved and issued by: