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KYC and Customer Due Diligence Policy

Last updated: 26 September 2026 ยท Version 1.1

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Introduction Purpose and application Our approach Identification and verification Customer due diligence Enhanced due diligence Ongoing review Privacy and confidentiality Questions and updates

Entity: Kalt Technologies Limited (trading as MyKalt)

Introduction

MyKalt is committed to providing a secure and responsible service. This policy explains why we identify and verify customers, the information we may request, and the circumstances in which we may need to carry out additional due diligence. It should be read with our AML/CFT/CPF Policy and Privacy Policy.

Identity verification supports customer protection, fraud prevention, lawful use of our services and our compliance responsibilities. It does not mean that every customer will be asked for the same information; the level of information requested may depend on the service, customer profile, transaction, risk assessment and applicable law.

Purpose and application

This policy applies to customers who use, seek to use, or apply for MyKalt services. Its purpose is to help establish and maintain a reasonable understanding of who our customers are, to assess relevant risk, and to help prevent the misuse of our services for fraud, money laundering, terrorist financing, proliferation financing or other unlawful activity.

This policy is designed to support compliance with applicable Nigerian legal and regulatory requirements, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022 and the Nigeria Data Protection Act 2023. It is also informed by a risk-based approach consistent with relevant FATF standards. This policy does not state that MyKalt is licensed, registered or supervised by any particular authority unless MyKalt expressly publishes that status.

Our approach

MyKalt applies the following principles when conducting KYC and customer due diligence:

  • Risk-based: checks may be proportionate to the customer, service, transaction and jurisdictional risk involved.
  • Accurate and current: customers are expected to provide complete, accurate and current information.
  • Respectful and lawful: information is requested and handled in accordance with applicable data-protection and confidentiality obligations.
  • Ongoing: verification and due diligence may be refreshed when circumstances, risk or legal requirements require it.

Identification and verification

We may request information reasonably needed to identify and verify a customer. The information required will be communicated through the relevant Service when necessary.

We maintain appropriate arrangements to support verification. Detailed verification methods and related operational information are confidential.

Customer due diligence

Customer due diligence may be completed before, during or after a customer relationship is established, as permitted or required by law. We may request further information where reasonably necessary for the relationship or a Service.

If we cannot complete the level of due diligence we reasonably require, we may delay, decline, limit or suspend access to a service or transaction. We may also request updated information where existing information is incomplete, inconsistent or no longer reliable.

Enhanced due diligence

We may apply enhanced due diligence where a relationship or activity presents higher risk. This may include circumstances involving politically exposed persons, complex ownership arrangements, higher-risk jurisdictions, unusual activity, adverse information, sanctions concerns, or transactions that appear inconsistent with information we hold.

Enhanced due diligence may be applied where appropriate. Detailed compliance arrangements are confidential.

Ongoing review

We may ask customers to confirm or update information from time to time. MyKalt may take appropriate action where information cannot be verified, appears inaccurate, or creates a legal, regulatory or security concern.

Privacy and confidentiality

We process KYC information for verification, security, risk management, legal and regulatory compliance, fraud prevention, service administration and related legitimate purposes. We seek to limit access to those with a legitimate need to know and apply safeguards appropriate to the nature of the information. For further information about how we process personal data and your rights, please read our Privacy Policy.

We may retain information for as long as necessary for the purposes described in this policy and to meet applicable legal, regulatory, audit, dispute-resolution and security requirements. Closing an account does not necessarily require immediate deletion of information that must or may lawfully be retained.

Questions and updates

MyKalt may revise this policy from time to time. The latest version will be published on this page. For questions about verification or customer due diligence, please contact [email protected].

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