AML / KYC Policy

Last updated: January 1, 2026

Policy statement

Prime Summa is committed to preventing its business from being used for money laundering, terrorist financing, sanctions evasion, or other financial crime. This policy summary describes, at a high level, the framework we maintain to meet that commitment.

The policy applies to all personnel, and to all business relationships and transactions entered into by the firm.

Governance and responsibility

Our Chief Compliance Officer is responsible for the AML program, including its design, its operation, and its periodic review. The officer has the authority and independence to escalate matters and to decline or terminate a relationship where financial crime concerns cannot be resolved.

Senior management is responsible for supporting a culture in which raising concerns is expected rather than discouraged.

Risk-based approach

We apply a risk-based approach, assessing the money laundering and terrorist financing risk presented by each relationship. Risk assessment takes into account:

• The type of investor and the complexity of its ownership structure
• The jurisdictions involved, including any subject to heightened risk
• The source of funds and the source of wealth
• The nature and expected pattern of activity
• Whether any party is a politically exposed person or a close associate of one
• Delivery channel and any use of intermediaries

The level of due diligence and the frequency of review are calibrated to the assessed risk.

Customer identification and verification

Before establishing a relationship, we identify each prospective investor and verify that identity using reliable, independent source documents, data, or information. Depending on the investor type, this may include:

• Individuals — full legal name, date of birth, residential address, nationality, and government-issued photographic identification
• Entities — legal name, registered and principal address, formation documents, registration number, and evidence of good standing
• Beneficial owners — identification and verification of natural persons who ultimately own or control the entity, at applicable ownership thresholds
• Control persons — directors, officers, trustees, or other persons with significant control
• Authorized signatories — evidence of authority to act

We do not establish or maintain anonymous accounts, and we will not proceed where identity cannot be satisfactorily verified.

Source of funds and source of wealth

We seek to understand both the origin of the funds being invested and the broader origin of the investor's wealth. Supporting documentation may be requested, and enhanced evidence is required where risk is assessed as higher.

Sanctions and screening

Prospective and existing investors, their beneficial owners, and their control persons are screened against applicable sanctions lists, including those administered by the U.S. Department of the Treasury's Office of Foreign Assets Control, and against politically exposed person and adverse media sources.

Screening is performed at onboarding and on an ongoing basis. We do not transact with sanctioned parties or in prohibited jurisdictions.

Enhanced due diligence

Where a relationship presents heightened risk, additional measures apply, which may include senior management approval before onboarding, more extensive documentation of source of funds and wealth, more frequent review, and enhanced ongoing monitoring.

Ongoing monitoring

Relationships are monitored over their life. We keep customer information current, review activity for consistency with what we know about the investor, and investigate activity that appears unusual or lacks an apparent lawful purpose.

Reporting and cooperation

Where required by law, we report suspicious activity to the relevant authorities. Applicable law may prohibit disclosing to any person that such a report has been made, and we comply with those prohibitions.

We cooperate fully with lawful requests from regulators and law enforcement.

Recordkeeping

Identification records, verification evidence, risk assessments, transaction records, and internal reports are retained for the period required by applicable law and our records retention policy, and are made available to authorities where lawfully required.

Training and independent review

All personnel receive AML training at onboarding and periodically thereafter, appropriate to their role. The program is subject to independent review and testing, and findings are reported to senior management for remediation.

What this means for investors

Prospective investors should expect to provide identification documents and information about the source of their funds before an investment can be accepted, and to provide updated information periodically thereafter.

We may decline, delay, or terminate a relationship where required information is not provided or where financial crime concerns cannot be resolved, and we are not obliged to explain the reason.

Placeholder: this summary should be reviewed and completed by counsel and compliance to reflect the specific regulatory obligations applicable to the firm and its registrations before publication.