EMPLOYEE AML/CFT TRAINING POLICY

ZESTFLOW INDIA PRIVATE LIMITED (CIN-U62099DC2026PTC468956)

Registered Address - Office No. 201, Plot No 4, 2nd Floor, LSC Gujranwala Colony North West Delhi Delhi India 110009

1. Purpose and Policy Statement

ZESTFLOW INDIA PRIVATE LIMITED ("ZESTFLOW" or "the Company") is committed to maintaining a strong culture of compliance by ensuring that relevant employees and personnel understand their responsibilities relating to Anti-Money Laundering ("AML"), Combating Financing of Terrorism ("CFT"), Know Your Customer ("KYC"), Customer Due Diligence ("CDD"), fraud prevention and other financial-crime risks.

This Policy establishes a risk-based framework for providing appropriate AML/CFT training and awareness to relevant personnel so that they are able to identify compliance risks, recognise suspicious or unusual activities, follow applicable internal procedures and promptly escalate concerns.

This Policy shall be read together with the Company's AML, CFT, KYC/CDD, Risk Management and other applicable compliance policies.

2. Scope and Applicability

This Policy applies, as relevant, to:

• Directors and Senior Management;
• permanent, temporary and contractual employees;
• consultants and interns;
• personnel involved in customer or merchant onboarding;
• operations, finance, customer support and technology personnel performing compliance-sensitive functions;
• the Compliance and Risk functions; and
• outsourced personnel or other persons performing relevant functions on behalf of the Company, where appropriate.

The nature and extent of training shall be proportionate to the individual's role, responsibilities and exposure to AML/CFT and financial-crime risks.

The Company may also provide appropriate compliance awareness to merchants, channel partners, vendors and other relevant third parties where considered necessary.

3. Training Governance and Responsibilities

The Board of Directors shall have overall oversight of the Company's AML/CFT training framework.

The designated Compliance Officer or Compliance Function shall be responsible for:

• identifying relevant training requirements;
• developing or arranging appropriate training programmes;
• ensuring that training content remains reasonably current;
• coordinating training and awareness activities;
• maintaining appropriate training records; and
• periodically reviewing the effectiveness of the training framework.

Where a Principal Officer or other designated officer is appointed or required under applicable law, such person may perform or oversee relevant training responsibilities.

Department Heads shall support employee participation in mandatory training applicable to their respective functions.

4. Training Framework and Frequency

The Company shall provide AML/CFT and related compliance training appropriate to the roles and responsibilities of relevant personnel.

Training may be delivered through:

• induction programmes;
• classroom or virtual sessions;
• online learning modules;
• workshops or webinars;
• case studies and practical exercises;
• internal compliance communications; or
• any other suitable method.

The Company shall endeavour to provide:

a. Induction Training

Relevant new employees and personnel should receive appropriate AML/CFT and compliance awareness at the commencement of, or within a reasonable period after beginning, their relevant duties.

b. Periodic Refresher Training

Relevant personnel shall receive refresher training periodically and ordinarily at least once annually, based on their roles and risk exposure.

c. Additional Training

Additional or targeted training may be provided where appropriate, including upon:

• material changes in applicable laws or regulatory requirements;
• introduction of new products, services or business processes;
• significant changes to internal policies or procedures;
• identification of compliance deficiencies;
• occurrence of significant incidents; or
• emergence of new financial-crime risks.

Higher-risk or specialised functions may receive more frequent or detailed training.

5. Training Content and Role-based Approach

Training content shall be proportionate to the responsibilities of the persons receiving the training and may include:

• basic principles of AML and CFT;
• the Company's AML, CFT and KYC/CDD framework;
• customer and merchant identification and verification;
• beneficial ownership;
• customer and merchant risk assessment;
• enhanced due diligence;
• sanctions and designated-person screening;
• transaction monitoring and financial-crime red flags;
• identification of unusual or suspicious activities;
• internal escalation procedures;
• regulatory or partner reporting requirements, where applicable;
• confidentiality and prohibition of tipping-off;
• fraud prevention and identity-related risks;
• record retention and data protection requirements;
• cyber-security awareness relevant to financial crime; and
• consequences of non-compliance.

Role-specific training may include:

Customer and Merchant Onboarding Personnel: KYC verification, document review, beneficial ownership, due diligence and risk classification.

Operations and Customer Support Personnel: Unusual activity indicators, transaction-related red flags, fraud indicators and escalation procedures.

Compliance and Risk Personnel: AML/CFT requirements, enhanced due diligence, sanctions screening, internal investigations, escalation and applicable reporting requirements.

Technology Personnel: Access controls, system security, transaction- monitoring support, data protection and technology-related financial-crime risks.

Senior Management: Governance, risk oversight, material compliance risks and management responsibilities.

The above topics are illustrative and may be modified based on the Company's business activities and identified risks.

6. Assessment, Records and Effectiveness Review

The Company may assess the effectiveness of training through:

• quizzes or online assessments;
• case studies;
• practical exercises;
• employee feedback;
• compliance observations;
• incident trends; or
• other appropriate methods.

Where material gaps in understanding are identified, additional guidance or training may be provided.

The Company shall maintain appropriate records of training activities, which may include:

• date and nature of training;
• training materials;
• attendance or participation records;
• assessment results, where applicable; and
• certificates or acknowledgements, where issued.

Training records shall be retained in accordance with the Company's Record Retention & Data Preservation Policy and applicable requirements.

The training framework shall be periodically reviewed to consider changes in laws, business activities, internal policies, audit findings, incidents and emerging financial-crime risks.

7. Employee Responsibilities, Confidentiality and Non-compliance

Relevant employees and personnel shall:

• attend mandatory training assigned to them;
• complete required assessments, where applicable;
• understand and follow applicable Company policies and procedures;
• apply the knowledge acquired during training;
• promptly escalate unusual or suspicious activities through authorised internal channels;
• maintain confidentiality; and
• cooperate with compliance reviews, audits and investigations.

Employees shall not disclose confidential internal compliance procedures, investigations, suspicious activity reviews or other restricted information except where authorised or required by law.

Failure to attend mandatory training without reasonable cause, deliberate disregard of compliance obligations or material failure to follow applicable AML/CFT procedures may result in appropriate corrective or disciplinary action in accordance with the Company's internal policies and applicable law.

8. Policy Review, Approval and Effective Date

This Policy shall be reviewed periodically and, where appropriate, upon:

• changes in applicable laws or regulatory requirements;
• material changes in the Company's business model;
• introduction of new products or services;
• significant compliance incidents;
• emerging financial-crime risks; or
• findings arising from audits or compliance reviews.

This Employee AML/CFT Training Policy has been approved by the Board of Directors of ZESTFLOW INDIA PRIVATE LIMITED and shall come into effect from the date of its approval.

The Board may amend or replace this Policy from time to time.

CERTIFICATION

All employees, consultants and other relevant personnel of ZESTFLOW INDIA PRIVATE LIMITED shall comply with this Policy to the extent applicable to their respective roles and responsibilities.

For ZESTFLOW INDIA PRIVATE LIMITED Approved by the Board of Directors on: __________________ Effective Date: __________________