1. Introduction

Hive PT ("Hive PT", "Company", "we", "our", or "us") is committed to maintaining the highest standards ofintegrity, transparency, and compliance in all aspects of its business operations.

This Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") Policy outlines the measuresimplemented by Hive PT to prevent its services from being used for money laundering, terrorist financing,fraud, sanctions violations, or any other unlawful activity.

By accessing or using the Hive PT platform, users agree to comply with this Policy and all applicable lawsand regulations.

2. Legal Entity

Hive PT is owned and operated by:

SINCRONIELEVADA – UNIPESSOAL LDA

Registered Address:

Avenida da Boavista, No. 1679
4100-132 Porto
District of Porto
Municipality of Porto
Parish of Lordelo do Ouro e Massarelos
Portugal

Throughout this Policy, references to "Hive PT", "Company", "we", "our", or "us" refer to SINCRONIELEVADA– UNIPESSOAL LDA and its operated platform Hive PT.

3. Business Model

Hive PT operates exclusively as a proprietary trading evaluation platform.2

The Company provides:

• Simulated trading challenges

• Trader evaluation programs

• Educational and assessment services

• Performance-based reward programs

  
  

Hive PT does not:

• Accept investment deposits

• Manage customer funds

• Provide brokerage services

• Execute live trades on behalf of users

• Offer investment advice

• Hold client assets for investment purposes

• Operate collective investment schemes

  
  

All trading activities conducted within Hive PT are performed in a simulated environment using virtualcapital.

Any rewards or payouts issued by Hive PT are funded solely from the Company's operational revenues andare not derived from the investment or trading of customer funds.

4. Expected Flow of Funds

Incoming Payments

Hive PT receives payments from customers purchasing:

• Trading challenge access

• Evaluation programs

• Educational services

• Platform-related products and services

  
  

Outgoing Payments

Hive PT may issue payments to:

• Verified users who qualify for performance-based rewards

• Employees and contractors

• Marketing affiliates

• Technology vendors

• Professional service providers

  
  

Purpose of Transactions

All transactions processed through Hive PT must relate exclusively to legitimate business activitiesassociated with the Company's services.

Hive PT strictly prohibits the use of its platform as a mechanism for transferring funds between thirdparties.

5. Customer Identification and Verification (KYC)

Hive PT reserves the right to verify the identity of any user at any time.

• Verification may include:

• Government-issued identification

• Passport

• National ID card

• Driver's license

• Proof of address

• Selfie verification

• Source of funds information

• Additional supporting documentation

  
  

Users may be required to complete identity verification before receiving any rewards, payouts, or access tocertain services.

Failure to provide requested documentation may result in account suspension or termination.

6. Risk-Based Compliance Approach

Hive PT applies a risk-based approach to compliance and may assess risk factors including:

• User identity

• Country of residence

• Payment methods used

• Transaction behavior

• Fraud indicators

• Sanctions exposure

• Regulatory considerations

  
  

Higher-risk accounts may be subject to additional review and verification procedures.4

7. Enhanced Due Diligence (EDD)

Hive PT may conduct Enhanced Due Diligence where necessary.

Additional verification may be required for:

• Politically Exposed Persons (PEPs)

• High-risk jurisdictions

• Unusual transaction activity

• Multiple account usage

• Large payout requests

• Users identified as presenting elevated risk

  
  

Additional documentation may include:

• Source of funds documentation

• Source of wealth documentation

• Banking information

• Business records

• Tax-related documentation

  
  

8. Sanctions Compliance

Hive PT does not provide services to individuals, entities, or jurisdictions that are subject to applicableeconomic or trade sanctions.

The Company reserves the right to conduct sanctions screening against:

• OFAC Sanctions Lists

• United Nations Sanctions Lists

• United Kingdom Sanctions Lists

• European Union Sanctions Lists

• International Watchlists and Compliance Databases

  
  

Accounts associated with sanctioned parties may be restricted, suspended, or terminated immediately.

9. Prohibited Activities

Users are strictly prohibited from using Hive PT in connection with:

• Money laundering

• Terrorist financing

• Fraud

• Identity theft

• Payment fraud

• Chargeback abuse

• Stolen payment methods

• Sanctions evasion

• Criminal proceeds

• Human trafficking

• Drug trafficking

• Organized crime

• Financial crime of any kind

  
  

Any suspected violation may result in immediate account restrictions and further investigation.

10. Transaction Monitoring

Hive PT monitors transactions and account activity to identify suspicious behavior.

Examples may include:

• Unusual payment patterns

• Multiple accounts controlled by one individual

• Attempts to bypass verification procedures

• Inconsistent account information

• Suspicious geographic activity

• Fraud indicators

• Abnormal payout requests

  
  

The Company reserves the right to investigate any activity deemed suspicious.

11. Suspicious Activity Handling

Where suspicious activity is identified, Hive PT may:

• Request additional information

• Delay processing transactions

• Restrict account functionality

• Suspend accounts

• Cancel payouts

• Terminate user relationships

  
  

Where required by law, Hive PT may cooperate with:

• Law enforcement agencies

• Financial institutions

• Payment processors

• Regulatory authorities

  
  

Users may not be notified where such notification is prohibited by law.

12. Record Retention

Hive PT may retain records relating to:

• User identification

• Verification documents

• Transaction history

• Compliance reviews

• Risk assessments

• Fraud investigations

  
  

Such records may be retained for a minimum period of five (5) years or longer where required by applicablelaw.

13. Right to Refuse Service

Hive PT reserves the absolute right, at its sole discretion, to:

• Reject applications

• Refuse transactions

• Delay or cancel payouts

• Request additional documentation

• Restrict account access

• Suspend services

• Permanently terminate accounts

  
  

where compliance, fraud, legal, regulatory, operational, or reputational concerns arise.

14. Limitation of Platform Use

Hive PT is intended solely for trading evaluation and educational purposes.

The platform may not be used:

• As a banking service

• As a payment service

• As a money transfer service

• For depositing investment capital

• For storing funds

• For transferring funds between users

  
  

Any attempt to use Hive PT for purposes other than those expressly permitted by the Company is strictlyprohibited.

15. Company Disclosure

Hive PT is a proprietary trading evaluation platform operated by SINCRONIELEVADA – UNIPESSOAL LDA, acompany incorporated in Portugal.

The platform provides simulated trading evaluations, educational services, and trader assessmentprograms only.

Hive PT does not accept deposits for investment purposes, does not manage client funds, does not providebrokerage services, and does not execute live trades on behalf of customers.

16. Policy Updates

Hive PT reserves the right to amend, modify, or update this AML/CTF Policy at any time without prior notice.

The most current version will always be published on the Company's website.

Continued use of the platform constitutes acceptance of any updated version of this Policy.

17. Compliance Contact

Hive PT Compliance Department

Operated by: SINCRONIELEVADA – UNIPESSOAL LDA

Email: support@hive-pt.com

Website: https://hive-pt.com

Registered Address:

Avenida da Boavista, No. 1679
4100-132 Porto
Portugal

Zero-Tolerance Statement

Hive PT maintains a strict zero-tolerance policy toward money laundering, terrorist financing, fraud,sanctions violations, payment abuse, and all forms of financial crime.

Any attempt to misuse the platform may result in immediate account termination, forfeiture of rewards,suspension of services, reporting to relevant authorities, and permanent exclusion from all Hive PTprograms.

Important Notice

Hive PT operates exclusively as a simulated proprietary trading evaluation platform.

No customer funds are invested, traded, managed, pooled, or placed in financial markets.

Users purchase access to evaluation programs, educational services, and simulated trading challenges only.

Hive PT is not a bank, broker, investment adviser, asset manager, payment institution, electronic moneyinstitution, money transmitter, or financial intermediary.