Anti-Money Laundering / Anti-Terrorist Financing Policy

Bermuda Investment Advisory Services Limited, BIAS (CAYMAN) Limited, BIAS Global Portfolios, SPC, BIAS Nominees Ltd., BIAS Pension Plan Trust and BIAS Asset Management Ltd (collectively referred to as BIAS) and its Senior Management are firmly committed to compliance with all laws and regulations relating to combating money laundering and terrorist financing, including laws that criminalise money laundering and rules and regulations that require financial institutions to report currency transactions, certain monetary instruments and suspicious activity.

BIAS is committed to ‘knowing its customers’ appropriately, both prior to acceptance as a client of BIAS and throughout the business relationship. BIAS will exercise this commitment through taking the appropriate steps to verify every client’s identity and business, and their reason for seeking a business relationship with BIAS.

Protecting BIAS against exploitation by money launderers or terrorists is the responsibility of every employee. Any involvement in money laundering or terrorist financing- even if unintentional or indirect – could result in serious civil and criminal penalties for BIAS and its employees, as well as forfeiture of assets. Association with money laundering or terrorism also could cause significant damage to BIAS’ reputation.

BIAS is committed to ensuring that employees are trained and made aware of the law and their obligations under it.

Under no circumstances may an employee of BIAS wilfully facilitate or participate in any money laundering or terrorist activity. BIAS expects that employees will promptly report any suspicious activity to the designated Money Laundering Reporting Officer (“MLRO”). Any violation of this policy will subject the employee involved to disciplinary action, including dismissal, and may subject them to possible civil and criminal penalties.

BIAS has adopted this policy to assist its employees to guard against money laundering and terrorist financing through BIAS and to encourage employees to detect and report transactions as required by BIAS. It is not intended that these policies and procedures be applied unthinkingly, as a checklist of steps to take. BIAS strongly encourages all employees to “think risk” as they carry out all their duties.