INTERNAL FRAUD PREVENTION POLICY

CROSSCHANGE INTERNATIONAL OÜ

SEPTEMBER 1, 2020

Crosschange International OÜ, a Delaware limited liability company (hereinafter The Crosschange International OÜ) is committed to high legal, ethical and moral standards. All The Crosschange International OÜ employees and management are expected to share this commitment. The Crosschange International OÜ has zero tolerance for fraud and will comply with all applicable anti-fraud laws in all jurisdictions in which it operates.

The Crosschange International OÜ carries out shared responsibility to ensure that risk culture and fraud prevention policy are established. All employees are required to familiarize themselves with the types of violations that may occur within their areas of responsibility and to be vigilant to any indications of fraud risk.

The purpose of this Internal Fraud Prevention Policy (hereinafter the Policy) is to provide a general response framework and guidance for those who find themselves having to deal with suspected cases of fraud. This Policy is established to facilitate the development of controls that will help in the detection and prevention of fraud against the Crosschange International OÜ. The Crosschange International OÜ aims to promote consistent organizational behavior by providing guidance and accountability for the development of controls and investigations.

This Policy applies to any irregularity, or suspected irregularity, involving employees as well as shareholders, consultants, vendors, contractors, and/or any other parties with a business relationship with the Crosschange International OÜ. Any necessary investigative action will be conducted without regard to the length of service, position of the suspected intruder or relationship to the Crosschange International OÜ.

This Policy is an integral part of the Crosschange International OÜ control policy framework and shall be read and applied in conjunction with the Crosschange International OÜ Terms of Use, Privacy Policy and other relevant documentation.

ACTIONS CONSTITUTING FRAUD

For the purposes of this Policy, fraud is defined as the use of deception by an individual with the intention of obtaining an advantage for himself/herself or for third party/parties. The purpose of the fraud is to obtain money, property or services; to avoid payment or loss of services; or to obtain personal or business advantage.

The term fraud is used to describe offences such as, but not limited to, any dishonest or fraudulent act; deception; corruption; theft; money laundering; misappropriation of funds, securities, supplies or other assets; impropriety in the handling or reporting of money or financial transactions; defalcation; false representation; embezzlement; disclosing confidential and proprietary information to third parties; destruction, removal, or inappropriate use of records, appliances, and equipment; profiteering as a result of insider knowledge of company activities; accepting anything of material value from contractors or persons providing services/materials to the Crosschange International OÜ and other similar or related irregularities.

FRAUD PREVENTION ACTIONS – RESPONSIBILITIES

Frauds arise because of lack of proper internal control policies and procedures, failure by employees to observe internal controls, carelessness in carrying out checks or inadequate separation of duties. The Crosschange International OÜ implements a proactive approach to managing fraud risk through maintaining and continuously promoting a zero tolerance attitude towards fraud, promulgating fraud awareness culture among all employees and management.

The Crosschange International OÜ initiates and undertakes an investigation where there is suspected fraud and take appropriate legal action in all cases where necessary. Where there is suspected or proven fraud, the Crosschange International OÜ will make any necessary changes to existing internal control framework to ensure prevention of any future occurrence of similar fraud. The Crosschange International OÜ establishes system for recording and subsequently monitoring all discovered cases of suspected or proven fraud and the effectiveness of corrective measures implemented.

Everyone in the Crosschange International OÜ has a responsibility as well as an obligation to contribute to the management of fraud risk. Management shall ensure that the opportunities for fraud are kept to a minimum. The potential for fraud can be reduced by ensuring that a robust internal control system commensurate with the risk is designed and implemented and operates as intended. The management set the tone and lead in the promotion of risk management, internal controls and an antifraud culture throughout the Crosschange International OÜ. The management also ensures that employees are comfortable to report fraud without fear of reprisal. Employees conduct themselves with integrity and demonstrate awareness of the importance of ethical practices in their day to day work. The Crosschange International OÜ management and employees design, implement and manage monitoring activities, hire the right people and ensure that physical and IT services contribute to the security of computers and data. The Crosschange International OÜ expects all people and organisations to be honest and fair in their dealings with all their partners. The Crosschange International OÜ will not tolerate any level of fraud or corruption. Any case identified will be thoroughly investigated, disciplinary or criminal sanctions will be imposed if appropriate and possible, and damages will be compensated by any legal means.

The Crosschange International OÜ is also committed to ensuring that opportunities for fraud are reduced to the lowest possible level of risk and systems and procedures are reviewed and improved following the detection of fraud.

The most persuasive and effective method of preventing fraud is the promotion by management of an ethical and transparent environment that encourages employees at all levels to actively participate in protecting the Crosschange International OÜ’s reputation and resources.

FRAUD RESPONSE PROCEDURES

The Crosschange International OÜ has the responsibility for the investigation of all suspected fraudulent acts as defined in the Policy. To ensure that effective and timely action is taken in a professional manner to any suspected or proved fraud or any other irregularity, The Crosschange International OÜ has established an overall response procedure which defines the steps to be followed in such cases.

Fraud Detection

Every employee may encounter indicators of potential fraud in the course of their daily operational activities. Examples include unusual events or one-time transactions, as well as any unintentional event or action that is not part of the normal operation of the system or the expected course of action and events that may be indicators of potential fraud. All employees should be made aware of the possibility of fraud and ensure that any suspicious signs detected are reported in a timely manner. Fraud may also be detected as a result of special and/or unscheduled inspections by management, or reported to management by a third party.

Reporting

When investigating alleged violations or abuses, care should be taken to avoid making erroneous accusations or warning suspects that an investigation is under way. An employee who discovers or suspects fraudulent activity must notify The Crosschange International OÜ management immediately. The complainant may remain anonymous. As speed is essential, such initial reporting may be verbal, but must be supplemented as soon as possible by a written report that must cover:

(a) Whether or not a responsible person has been identified;

(b) The amount/value, if any established;

(c) The period during which the fraud or violation took place, if known;

(d) The date of discovery and the manner in which the fraud or violation was suspected;

(e) Whether any collusion with other persons is suspected;

(f) The details of any action taken to date;

(g) Any other information or comments that may be relevant to the case.

No information concerning the status of an investigation will be given out, unless the circumstances so provide. Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the corruption,” or any other specific reference. The reporting employee should be informed of the following by the management: “Do not contact the suspected individual in an effort to determine facts or demand restitution.”

Confidentiality

The Crosschange International OÜ treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Crosschange International OÜ management immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act. The results of the investigation shall not be disclosed or discussed with anyone other than those who have a legitimate right to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Crosschange International OÜ from potential civil liability.

Investigation and Further Actions

If informed of fraud, management should listen carefully and with respect to employees, and ensure that every allegation is treated seriously and given a fair hearing. Management should obtain as much documentation and information as possible regarding the alleged fraud, including any notes or evidence, and they should reassure employees that they will be protected and will not suffer any reprisal for having reported allegations made in good faith.

Any allegation of possible fraud will be subject to a preliminary review to confirm suspicions and assess whether the case is sufficiently substantiated to initiate the investigation process.

The Crosschange International OÜ undertakes to conduct a comprehensive analysis of all factors that have given rise to a suspicion of possible misconduct in order to determine whether a genuine error has occurred. Preliminary and subsequent investigation will be organized and conducted in strict accordance with the established procedures. An important aspect is the promptness of actions.

Upon completion of an investigation, the Crosschange International OÜ will determine the course of action, including the application of necessary legal and disciplinary measures, in all cases deemed appropriate. Decisions to prosecute or refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel (if necessary) and management, as will final decisions on disposition of the case. The Crosschange International OÜ may, for example, make changes to the existing internal control system, reorganize business processes, implement information systems, develop internal policies and procedures to prevent similar cases in the future.

Information on all allegations of suspected or proven wrongdoing will be stored in the internal case tracking system. The data recorded in the system will contain a summary of the results of all investigations conducted and all remedial actions taken in the organized case.