Affinitas Consulting Code of Conduct

Code of conduct, KYC and AML policies

Each employee of Affinitas has an independent responsibility to know the customers with whom it does business and to monitor the cash and trading activity of such customers. In certain circumstances, Affinitas will coordinate its anti-money laundering procedures with those of its Associated Persons and affiliates. Specifically, Affinitas will undertake appropriate steps to verify the identity and address of each of its customers. This may include phone conversations, in-person visits, and/or review of information in the customer account file at Affinitas. Background check includes the following:

Individuals – Affinitas will verify the identity and permanent address for each such customer utility bill, tenancy contract or such other means as deemed appropriate by Affinitas’ Compliance Officer.

Entities – Affinitas will review corporate, trust, LLC and partnership documents and undertake such other steps as determined by Affinitas’ Compliance Officer to ensure that the identity, ownership and address of the entity is correct.