Anti-Money Laundering Policy

Version 1.0 · November 2026

Commitment

Muculo Retail does not accept funds of illicit origin and does not allow its operations to be used to launder money or to finance terrorism or the proliferation of weapons of mass destruction.

Legal framework

This policy takes into account Law No. 5/20 of 27 January (Angola), as amended by Law No. 11/24 of 4 July, Law No. 83/2017 of 18 August (Portugal), the recommendations of the Financial Action Task Force (FATF) and the applicable law of other jurisdictions where we operate.

Risk assessment

We assess the risk of each relationship and each operation, considering the client or supplier, corporate structure, country (including jurisdictions under FATF increased monitoring), sector, goods, payment method and value. High risk leads to enhanced checks and approval by the compliance officer.

Identification and verification

• We identify the counterparty and its beneficial owners, with official documents and up-to-date commercial registers.
• We verify the real activity, the source of funds and the consistency of the operation with the counterparty's profile.
• We check whether the counterparty, its directors and beneficial owners are politically exposed persons or appear on sanctions lists.
• We update the information periodically and whenever something relevant changes.

Payments

• We accept and make payments by bank transfer between accounts held by the parties themselves, or by documented banking instruments such as documentary credit.
• We do not accept cash or payments by third parties with no demonstrable link to the operation, nor to accounts in countries unconnected to the operation.
• We do not split amounts to avoid controls, nor accept that others do.
• Invoices, contracts and payments must match in amount, currency, parties and goods.

Monitoring and reporting suspicions

We monitor operations and investigate those that depart from the expected profile. Where there is a well-founded suspicion, the compliance officer decides on reporting to the competent Financial Intelligence Unit (in Angola or Portugal) and suspends the operation where the law requires. We do not tell the counterparty about the report.

Records and training

We keep identification documents, analyses, decisions and operation records for the applicable legal periods. People exposed to these risks receive training and the policy is reviewed at least once a year.

Raising a concern

Anyone can report a suspicion confidentially through the Whistleblowing Channel. This policy complements the Sanctions and Trade Controls Policy and the Anti-Corruption Policy.