Anti Fraud

BitTrust Inc. (“BitTrust”, “we”, “us”, or “our”) is committed to conducting business in accordance with the highest ethical, professional, and legal standards. Customers, partners, and users have the right to expect that BitTrust operates in a trustworthy and compliant manner.

BitTrust complies with applicable Canadian legislation and maintains a zero-tolerance policy toward fraud, corruption, collusion, money laundering, terrorist financing, and any other criminal or unlawful conduct (collectively “Prohibited Conduct”).

BitTrust will investigate and take appropriate action, which may include refusal of service, account restrictions, reporting to authorities, and/or legal action where required.

BitTrust allocates appropriate resources to implement this Anti-Fraud Policy and ensures it is communicated and applied across its operations.

1. Legal Compliance

This Anti-Fraud Policy is designed to comply with applicable Canadian laws and regulatory requirements, including anti-money laundering and counter-terrorist financing legislation administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

BitTrust ensures compliance with all applicable laws and internal policies.

2. Definitions of Prohibited Conduct

For the purpose of this Policy, “Prohibited Conduct” includes:

Fraud

Any act or omission, including misrepresentation, intended to mislead or deceive another party for financial or other gain, or to avoid an obligation.

Corruption

Offering, giving, receiving, or soliciting anything of value to improperly influence a decision or action.

Collusion

An agreement between two or more parties intended to improperly influence outcomes or actions.

Money Laundering

Any activity intended to conceal or disguise the origin of proceeds derived from criminal activity, including conversion, transfer, concealment, acquisition, or use of such property.

Terrorist Financing

Providing or collecting funds, directly or indirectly, with the intention or knowledge that they will be used to support terrorist activities, as defined under applicable Canadian law.

Criminal Conduct

Any conduct that constitutes an offence under applicable laws.

3. Compliance and Risk Controls

BitTrust applies Know-Your-Customer (KYC) and anti-money laundering procedures to verify customer identity and assess transaction risk in accordance with regulatory requirements.

BitTrust maintains internal controls designed to:

• Detect and prevent Prohibited Conduct
• Conduct risk-based customer and transaction reviews
• Monitor transactions for suspicious activity
• Report required matters to regulatory authorities

BitTrust may delay, refuse, or restrict services where compliance or risk concerns are identified.

4. Fraud Detection and Investigation

BitTrust maintains internal compliance and fraud monitoring procedures responsible for reviewing and investigating potential Prohibited Conduct.

4.1 Authority

BitTrust compliance personnel may:

• Review and investigate suspicious activity
• Request additional information or documentation
• Report findings to internal management and/or regulatory authorities

Urgent measures may be taken where necessary to preserve evidence or protect the integrity of operations.

4.2 Independence

Compliance and fraud review activities are conducted independently to ensure fairness, objectivity, and integrity.

4.3 Professional Standards

Investigations are conducted fairly and with respect for applicable rights and due process. Individuals are presumed compliant unless evidence suggests otherwise.

4.4 Cooperation

Customers agree to cooperate with BitTrust requests for information, verification, or documentation where required for compliance or risk assessment purposes.

4.5 Confidentiality

All non-public information obtained during compliance or fraud investigations is treated as confidential and disclosed only where required by law, regulation, or legitimate business need.

5. Reporting Obligations

BitTrust may report suspected Prohibited Conduct to applicable Canadian authorities, including FINTRAC, law enforcement agencies, or other regulatory bodies, in accordance with legal requirements.

Such reporting may occur without prior notice to the customer where required or permitted by law.

6. Changes to This Policy

BitTrust may update this Anti-Fraud Policy from time to time to reflect legal, regulatory, or operational changes. The updated version will be posted when applicable.