Compliance Policy

Purpose and position of Trade Base Hub

This Compliance Policy establishes risk-based standards for accepting, reviewing, supporting, restricting or declining users, documents and commercial transaction matters. It aims to reduce fraud, sanctions, money-laundering, corruption, misrepresentation, circumvention, reputational and documentation risks while supporting orderly commercial transactions.

Trade Base Hub provides commercial support, document development, transaction readiness and coordination. It is not a bank, financial institution, law firm, broker-dealer, escrow agent, investment adviser or regulated financial intermediary. Screening is an internal risk-management function, not regulatory approval, legal advice, certification or a guarantee.

Scope

This Policy applies to website and platform users, clients, principals, buyers, sellers, authorised representatives, intermediaries, consultants, service clients, counterparties, opportunities, transaction documents and relevant third parties connected with a Trade Base Hub matter.

Risk-based approach

The level of review may vary according to nature, value, jurisdiction, parties, transaction type, delivery method, payment structure, documentary quality and risk indicators. Enhanced review may apply to higher-risk jurisdictions, complex ownership, PEP exposure, sanctions proximity, unusual payments, high-value transactions, unverifiable authority, adverse media or inconsistent documents.

Client identification and KYC

Trade Base Hub may require a CIS, official identification, proof of address, corporate records, director and authorised-signatory details, authority instruments, beneficial-ownership information and other reasonable evidence. For entities, ultimate beneficial owners and controllers may be identified, including persons holding or controlling 25% or more where appropriate; information below that threshold may be requested where risk warrants. Submission does not guarantee acceptance.

Authority and representation

A person acting for a principal may be required to provide a mandate, Letter of Representation, board resolution, power of attorney, statutory appointment, government instrument or other satisfactory evidence. Trade Base Hub may limit recognition to the evidenced scope and reject unsupported claims of mandate, exclusivity, signing power or entitlement.

Sanctions, PEP and watchlist screening

Parties, beneficial owners, signatories, connected persons and counterparties may be screened against sanctions information, PEP data, watchlists, corporate records and adverse-media sources. A potential match may lead to clarification, enhanced review, temporary restriction or refusal. PEP status or adverse media does not itself establish wrongdoing; identity confidence, source reliability, context, recency, severity and legal requirements must be considered.

AML, source of funds and legitimacy

Where relevant, Trade Base Hub may request source-of-funds, source-of-wealth, transaction-purpose, payment-pathway, asset-ownership or authority information. Users must not facilitate money laundering, terrorist financing, sanctions evasion, bribery, corruption, fraud, tax evasion, market abuse or other unlawful activity. A declaration of legitimacy is not conclusive evidence.

Proof of Funds and Proof of Product

POF or POP material may undergo integrity, identity, consistency, recency, authority and verification checks. Updated documentation, issuer confirmation, video verification or other evidence may be requested. Screenshots, altered documents, inconsistent names, expired records or unauthorised third-party proof may be rejected. Trade Base Hub does not guarantee authenticity, availability, transferability or sufficiency.

Document and transaction alignment

Where applicable, records may be aligned to an Opportunity Code and checked for consistency across CIS/KYC, NCNDA, fee agreement or IMFPA, mandate or Letter of Representation, Deal Summary, POF/POP and principal or counterparty information. Material inconsistencies may stop progression until resolved.

Intermediaries, fees and genealogy

Trade Base Hub may require disclosure of known intermediary chains, roles, relationships and fee expectations. Undisclosed participants, unexplained fee chains, side arrangements, opaque commissions or conflicting claims may trigger enhanced review or rejection. No fee entitlement arises merely from participation, calls, introductions, CIS completion or document submission; entitlement must arise under a separately executed agreement between authorised parties.

Anti-bribery and corruption

Users must not offer, promise, give, request, accept or facilitate bribes, kickbacks, improper commissions, secret payments, unlawful facilitation payments or other improper advantages. Enhanced care is required around public officials, state-owned enterprises, procurement, permits, licences, customs and PEPs.

Fraud, misrepresentation and document integrity

False identities, forged or altered documents, fabricated bank records, misleading authority claims, concealed ownership, false POF/POP, deceptive transaction histories, impersonation and deliberate material omissions are prohibited. Credible concerns may result in evidence preservation, restriction or termination.

Blacklist, grey-list and internal classification

Trade Base Hub may maintain internal risk classifications. A grey-list or temporary restriction may be used while concerns remain unresolved; a blacklist or permanent exclusion may be considered for sufficiently credible evidence of serious or repeated misconduct, fraud, malicious misuse, material misrepresentation, circumvention or unacceptable risk. Classifications are risk decisions, not declarations of criminal guilt. Where practicable, affected parties may be invited to clarify or appeal, and allegations must be distinguished from verified facts and internal judgments.

Restricted or prohibited activity

Trade Base Hub may refuse or terminate matters involving unlawful goods or services, sanctioned or prohibited transactions, deceptive schemes, unauthorised financial activity, forged documentation, hidden beneficial interests, bribery, corruption or unacceptable legal, financial, security or reputational risk.

Monitoring and ongoing review

Compliance is ongoing. Documents may be refreshed and screening repeated when circumstances change, documents expire, new parties enter, adverse information arises or a transaction moves to a higher-risk stage.

Reporting and escalation

Report suspected fraud, document manipulation, sanctions concerns, impersonation, confidentiality breaches, circumvention or serious misconduct to admin@tradebasehub.net. Trade Base Hub may review, seek evidence, restrict access, notify relevant contractual parties, obtain professional advice or make lawful disclosures to competent authorities.

No duty to approve or complete

Trade Base Hub may decline, pause or discontinue a matter where information is missing or risk is unacceptable. Payment or submission does not create a right to approval, continuing access, document acceptance, introduction, progression or completion, subject to non-waivable rights.

Confidentiality and data protection

Compliance information will be handled under the Privacy Policy, Confidentiality Policy, transaction agreements and applicable law. Access should be need-to-know, while preserving reasonable retention and disclosure for legal, compliance, security, fraud-prevention, dispute or enforcement purposes.

Records and audit trail

Trade Base Hub may retain screening results, document versions, access records, correspondence, decisions and evidence for a reasonable period appropriate to risk and law. Records may support decisions or responses to disputes, fraud, legal claims or lawful requests.

Limitation of compliance assurance

No screening system is infallible. Trade Base Hub does not warrant that review will identify every sanctions, crime, fraud, identity, ownership, document, credit, solvency, reputational or transaction risk. Each principal and counterparty remains responsible for independent due diligence and professional advice.

Breach and consequences

A failure to comply may lead to requests for information, refusal to process documents, removal from a matter, suspension, termination, internal classification, record preservation or another proportionate action, subject to applicable law and contract.

Policy governance and contact

Trade Base Hub may amend this Policy as the Services, risk environment or applicable requirements evolve. Compliance enquiries and reports should be sent to admin@tradebasehub.net.

This policy is a commercial risk-management document for Trade Base Hub and does not constitute legal advice. Mandatory law may apply differently according to the location of Trade Base Hub, the user, the service and the transaction. Nothing in this policy excludes or limits rights, duties or liabilities that cannot lawfully be excluded or limited.