Anti-Money Laundering Policy

Anti-Money Laundering and Anti-Terrorism Financing Policy Statement

Duales Inc. remains committed to preventing our organizatoin from being used, in any manner, by persons engaged in transactions or other activities designed to conceal the true source of funds derived from criminal activity or used to fund criminal activity, including terrorism. Even unintentional and indirect involvement in criminal activity is of great concern to Duales Inc.'s management.

Since criminals require financial services to support their illegal activity, financial companies can play a key role in the detection and prevention of money laundering and the financing of terrorism, principally with proper Know Your Customer practices. Knowledge of the customer provides a basis for understanding the general activities in which a customer would normally be expected to engage, thus giving an organization an opportunity to determine whether unusual activity should be reported as suspicious in accordance with applicable laws and regulations. It also enables financial companies to determine whether certain customers are included on various government listings of terrorists or are under investigation for ties to terrorist activities.

Duales Inc. will conduct its business in conformity with the highest ethical standards in the countries in which it does business, and will adhere to all laws and regulations pertaining to financial organizations. It is vital for all Duales Inc. clients, agents and employees and associates to fully understand those actions that may be violations of applicable AML or counter-terrorism statutes, and to report any potential violation in the manner set forth in the appropriate AML compliance procedures.

Duales Inc. will:

• Take reasonable steps to determine the true identity of all customers and beneficial ownership of accounts with Duales Inc..

• Take appropriate measures, consistent with the law, when Duales Inc. becomes aware of facts which lead to a reasonable suspicion that funds held by it are from money laundering or other criminal activity, that transactions entered into are themselves criminal in purpose, that funds are owned by a government-designated terrorist entity (such as FINTRAC in Canada and the Office of Foreign Assets Control in the US OFAC), or that transactions are intended to conduct or further terrorist activities. The appropriate measures to be taken may include: severing relations with the customer, closing or freezing accounts and filing a suspicious activity report.

• Cooperate with law enforcement and regulatory agencies to the extent that it can do so under all applicable foreign and domestic laws.

• Comply with all AML and counter-terrorism laws and regulations, including reporting and blocking of assets, to the fullest extent that it can do so under all applicable foreign and domestic laws.

While preventing the misuse of Duales Inc. by terrorists and other criminals is of vital importance, associates must not draw conclusions about customers and their banking activities based solely on the customers' religious affiliation, ethnicity, or national origin.

Every Duales Inc. employee is responsible for complying with all applicable AML laws, regulations, the Policy and procedures that implement the Policy. Complete details are in the Duales Inc. Corporation AML Policy.