1. Purpose

365 business development GmbH is committed to preventing money laundering, terrorist financing and sanctions violations within its business activities and partnerships.

2. Business Model

365 business development GmbH develops and distributes software solutions and integrations for Microsoft Dynamics 365 Business Central. The company does not operate as a financial institution, payment service provider or electronic money institution.

3. Risk-Based Approach

365 business development GmbH applies a risk-based approach when engaging with its business partners. The following partner categories are subject to risk assessment:

• Customers
• Partners and Resellers
• Technology providers
• Payment and banking integrations

The risk assessment takes into account the following factors: jurisdiction, industry, business model and transaction context.

4. Business Partner Due Diligence

365 business development GmbH performs the following due diligence measures in relation to its business partners:

• Identity verification of partners where applicable
• Review of publicly available information
• Sanctions screening
• Risk classification

5. Sanctions Screening

365 business development GmbH is committed to compliance with EU sanctions regulations and embargo requirements. The company screens partners against applicable sanctions lists, avoids cooperation with restricted entities or jurisdictions and terminates existing business relationships if relevant risks arise.

6. Use of Financial Integrations

Where financial integrations form part of 365 business development GmbH's software solutions, the regulated counterparts act as licensed financial institutions. 365 business development GmbH does not hold or process customer funds; the company acts solely as a software provider and integration partner.

7. Escalation & Reporting

Potential compliance risks are documented, reviewed by management and escalated where necessary. Business relationships may be rejected or terminated based on the outcome of the risk assessment.

8. Record Keeping

Relevant compliance checks and risk assessments are documented and retained in accordance with applicable legal and regulatory requirements.

9. Responsibility

Responsibility for this policy rests with Christoph Krieg, Managing Director of 365 business development GmbH.

10. Review

This policy is reviewed periodically and updated where required to reflect changes in legal requirements, business activities or risk assessments.