Anti-Money Laundering and Counter-Terrorist Financing Policy.

Effective Date: 10 December 2025

Purpose

Atura Group Limited (“Atura”) is committed to conducting business honestly and preventing its services and financial transactions from being used for money laundering, terrorist financing or other criminal activity.

This policy establishes proportionate controls designed to support compliance with the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 where applicable, and other relevant UK legislation.

Scope

This policy applies to Atura’s directors, employees and anyone acting on its behalf. It covers Atura’s print, merchandise, clothing, signage, account-managed and Print Portals activities.

Regulatory position

Atura does not currently undertake activities requiring registration for formal anti-money laundering supervision.

Atura will not make or accept cash payments at or above the statutory threshold that would cause it to be treated as a high-value dealer. This includes connected payments or transactions divided into smaller amounts to avoid the applicable threshold.

If Atura’s activities, payment methods or legal obligations change, its regulatory position will be reviewed before the relevant activity begins.

Payment controls

Payments should be made through normal, traceable banking, card or approved account-payment channels.

Atura will not knowingly:

• accept funds derived from criminal activity;
• assist anyone in concealing the source or ownership of funds;
• process unexplained payments from unrelated third parties;
• refund an overpayment to a different person or account without appropriate verification;
• participate in an arrangement intended to avoid legal or financial controls; or
• provide goods or services where it is known or reasonably suspected that they will support terrorism or other criminal activity.

Customer and transaction checks

Atura applies proportionate checks when establishing customer and supplier relationships. Further enquiries may be made where a transaction, payment method, delivery arrangement or party appears unusual or inconsistent with the known business purpose.

Warning signs may include:

• unusual requests to pay in cash;
• payments from unexplained third parties;
• deliberate splitting of payments;
• substantial overpayments followed by unusual refund instructions;
• inconsistent customer, billing or delivery information;
• reluctance to provide reasonable business or identity information;
• requests to conceal the parties involved in a transaction; or
• transactions having no clear commercial purpose.

Enhanced checks will be proportionate to the circumstances and will not be treated as formal regulated customer due diligence unless legally required.

Reporting concerns

Any director or employee who knows or suspects that money laundering, terrorist financing or related criminal activity may be taking place must report the concern immediately to an Atura Director.

The matter will be assessed confidentially. Atura may pause or decline the transaction while enquiries are made. The Director will determine whether professional advice, a Suspicious Activity Report to the UK Financial Intelligence Unit, or a report to another appropriate authority is required.

No person must alert a customer or third party to a report or investigation where doing so could prejudice an investigation or breach applicable law.

Records and confidentiality

Atura will maintain proportionate records of material concerns, enquiries, decisions and reports. Records will be secured, accessible only to authorised personnel and retained in accordance with Atura’s Data Protection Policy and applicable legal requirements.

Information concerning an actual or suspected offence will be shared only where necessary and lawful.

Responsibilities and awareness

The Directors are responsible for:

• maintaining and reviewing this policy;
• assessing reported concerns;
• ensuring that relevant personnel understand the required controls;
• obtaining professional advice where necessary; and
• reviewing whether changes to Atura’s operations bring the business within formal AML supervision.

All relevant personnel are required to follow this policy and promptly escalate anything suspicious.

Breaches

Failure to follow this policy may expose Atura and individuals to criminal, regulatory, contractual or reputational consequences. Employees who breach the policy may be subject to disciplinary action. Atura may terminate relationships with customers, suppliers or other parties where appropriate.

Review

This policy will be reviewed at least annually and whenever there is a significant change to Atura’s activities, payment arrangements, risk exposure or applicable legislation.

Contact

Questions, security concerns and suspected incidents should be reported promptly to Atura Group Limited at sales@aturagroup.co.uk or 0161 399 5842. A concern involving the usual contact should be raised with another Director.