Know Your Customer (KYC) Policy

1. Introduction

RECYBOVER AE, a company registered in Meydan Free Zone, Dubai, United Arab Emirates, with operational presence in Business Bay, Dubai, is committed to maintaining the highest standards of compliance and transparency in its commercial operations.

As part of its commitment to preventing financial crime, RECYBOVER AE implements Know Your Customer (KYC) procedures designed to verify the identity of its clients, suppliers, and business partners.

These procedures support the company’s compliance with UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and international standards promoted by the Financial Action Task Force.

2. Purpose of the KYC Policy

The purpose of this policy is to ensure that RECYBOVER AE:

• conducts business only with legitimate counterparties
• understands the identity and ownership structure of its clients and suppliers
• reduces the risk of fraud, money laundering, terrorist financing, and trade-based financial crime
• complies with applicable regulatory requirements

3. Scope

This policy applies to:

• customers and buyers
• suppliers and producers
• intermediaries, brokers, and agents
• logistics partners involved in commercial transactions

The KYC process may be conducted prior to establishing any business relationship or completing a transaction.

4. Customer Identification Requirements

Corporate Clients

For corporate entities, RECYBOVER AE may request the following documentation:

• Certificate of Incorporation
• Trade License or Business Registration
• Memorandum and Articles of Association (if applicable)
• Registered office address
• Identification documents of directors or authorized signatories
• Information regarding Ultimate Beneficial Owners (UBOs)

Individual Clients

For individuals, the company may collect:

• Full legal name
• Government-issued identification (passport or national ID)
• Residential address
• Contact details

All documents must be valid and may be subject to verification.

5. Beneficial Ownership Identification

RECYBOVER AE may identify the Ultimate Beneficial Owners (UBOs) of corporate clients or suppliers to ensure transparency in ownership structures.

Beneficial ownership verification may include identifying individuals who:

• directly or indirectly own a significant percentage of a company
• exercise control over the company’s management or decision-making

6. Risk Assessment

The company applies a risk-based approach when conducting KYC checks. Factors considered in assessing risk include:

• country of incorporation or residence
• business activity
• transaction structure and value
• involvement of intermediaries
• history of the business relationship

Higher-risk relationships may require Enhanced Due Diligence (EDD) procedures.

7. Sanctions and Compliance Screening

As part of its KYC process, RECYBOVER AE may screen counterparties against international sanctions lists, including those issued by:

• the United Nations Security Council
• the UAE Financial Intelligence Unit

If a match or potential risk is identified, the company may suspend or decline the transaction and take appropriate compliance actions.

8. Ongoing Monitoring

RECYBOVER AE may conduct periodic reviews of existing business relationships to ensure that customer information remains accurate and that transactions remain consistent with the nature of the business relationship.

9. Confidentiality and Data Protection

All information collected through the KYC process is handled with strict confidentiality and used solely for compliance, regulatory, and risk management purposes.

10. Policy Updates

This policy may be reviewed and updated periodically to reflect regulatory developments or changes in the company’s operations.