KRATOR+ Compliance Program

Section 1

About Compliance

KRATOR+ is committed to maintaining a safe, lawful and transparent ecosystem for its users, partners and stakeholders. This commitment is implemented through a formal Compliance Program, established and maintained by MAMA BIA, the company legally responsible for the operation of the KRATOR+ platform.

The Compliance Program is not a single document, but an integrated system of governance: policies, controls, training, monitoring procedures and reporting mechanisms designed to ensure that every activity carried out on or in connection with KRATOR+ is conducted in accordance with applicable law, industry regulation, and the ethical standards MAMA BIA holds itself to. The Program applies to employees, officers, contractors, suppliers, service providers, business partners and, where relevant, users of the platform.

MAMA BIA's Compliance Department is responsible for the design, implementation, ongoing review and enforcement of this Program. It operates independently from commercial and operational areas of the business, reports on compliance matters through MAMA BIA's governance structure, and has the authority to review conduct, recommend corrective action, and escalate matters of concern regardless of the seniority of the individuals involved.

Governing Principles

The Compliance Program is built on six governing principles. Each of these principles is reflected in the policies and procedures described throughout this portal, and each is subject to periodic review to ensure it remains effective and current with applicable regulatory requirements.

Professional Ethics: Every decision made in connection with KRATOR+ — commercial, technical or administrative — is expected to be guided by sound ethical judgment, consistent with MAMA BIA's stated values and with the reasonable expectations of users and partners.
Transparency: MAMA BIA provides clear, accurate and accessible information about how the KRATOR+ platform operates, how decisions affecting users are made, and how compliance matters are handled, to employees, partners, regulators and the public.
Fraud Prevention: Internal controls, transaction monitoring and periodic risk assessments are maintained to detect, prevent and respond to fraudulent activity connected to the platform, its users, or its business relationships.
Integrity: MAMA BIA expects consistency between what is communicated externally about KRATOR+ and how the platform is actually operated, including in matters of pricing, data handling, and representations made to users and partners.
Accountability: Responsibility for compliance is assigned clearly across the organization. Individuals and teams are accountable for the decisions they make and the controls they are responsible for maintaining.
Regulatory Compliance: KRATOR+ is operated in alignment with the laws, regulations and industry standards applicable to MAMA BIA's business activities in the jurisdictions in which it operates, including those governing data protection, anti-corruption and consumer protection.

Note. This portal describes the Compliance Program at a summary level. The full text of individual policies is available to employees, partners and regulators upon written request to the Compliance Department, as described in Section 5.

Section 2

Code of Conduct

The KRATOR+ Code of Conduct sets out the standard of behavior expected from everyone who interacts with the platform in a professional capacity, including users, partners, suppliers, collaborators and service providers. Compliance with the Code is a condition of any ongoing relationship with KRATOR+ and, where applicable, forms part of contractual obligations with MAMA BIA.

I.

Integrity

All parties are expected to act with honesty and to ensure consistency between what is stated and what is done. This includes providing accurate information during onboarding, in commercial dealings, and in any communication with the Compliance Department. Misrepresentation, concealment of relevant facts, or deliberately misleading conduct is treated as a serious violation of this Code, regardless of the intent behind it.

II.

Respect

Everyone engaging with KRATOR+ is expected to treat other users, partners, employees and service providers with courtesy and consideration, and to value diversity across the platform's community. Harassment, discrimination, or abusive conduct toward any individual, whether in direct interactions or through the platform's channels, is not tolerated and may result in the suspension or termination of the relevant relationship.

III.

Confidentiality

Individuals and organizations with access to non-public information related to KRATOR+ — including user data, business terms, or internal communications — are required to protect that information from unauthorized access, use or disclosure. Confidentiality obligations continue after a relationship with KRATOR+ or MAMA BIA ends, to the extent permitted by applicable law.

IV.

Transparency

Communications with users, partners and regulators are expected to be clear, accurate and made in good faith. This includes disclosing material information relevant to a business relationship, avoiding deceptive practices, and cooperating with reasonable requests for information made by the Compliance Department in the course of its oversight activities.

V.

Accountability

Every party is responsible for the outcomes of their own decisions and actions in connection with KRATOR+. This includes promptly reporting known or suspected violations of this Code, cooperating with any resulting investigation, and accepting the consequences established under applicable policy where a violation is confirmed.

Section 3

Corporate Policies

The Compliance Program is implemented through a set of formal corporate policies, maintained by MAMA BIA and applicable to the operation of KRATOR+. The current policies in force are summarized below. Each policy is reviewed on a periodic basis and updated to reflect changes in applicable law or business operations.

PC-01

Compliance Policy

In force

Establishes the overarching governance framework for the KRATOR+ Compliance Program, including the roles and authority of the Compliance Department, the escalation process for compliance matters, and the mechanisms used to monitor adherence to applicable law and internal standards across the platform.

PC-02

Anti-Corruption Policy

In force

Prohibits bribery, facilitation payments, and the offer or receipt of any improper advantage in connection with KRATOR+'s business activities. Sets out due diligence requirements for third parties, restrictions on gifts and hospitality, and the procedures for reporting suspected corruption.

PC-03

Conflict of Interest Policy

In force

Requires employees, officers and relevant third parties to identify and formally declare any personal, financial or professional interest that could reasonably be seen to influence their judgment in connection with KRATOR+, and establishes the process by which such conflicts are assessed and managed.

PC-04

Information Security Policy

In force

Defines the technical and organizational measures used to protect the confidentiality, integrity and availability of information processed in connection with KRATOR+, including access controls, incident response procedures, and requirements applicable to third parties handling platform data.

PC-05

Data Protection Policy

In force

Sets out the principles governing the collection, use, storage and disclosure of personal data processed through KRATOR+, in accordance with applicable data protection law, and describes the rights available to individuals whose data is processed by the platform.

Section 4

Reporting Channel

The KRATOR+ Reporting Channel is the formal mechanism through which users, partners, employees, suppliers and any other stakeholder may report conduct that they reasonably believe violates the Code of Conduct, a corporate policy, or applicable law. MAMA BIA's Compliance Department is responsible for receiving, reviewing and investigating every report submitted through this channel.

Confidentiality and Protection Against Retaliation

Providing a name and email address when submitting a report is optional. Reports may be made anonymously, and MAMA BIA does not attempt to identify anonymous reporters. Where a reporter chooses to identify themselves, their identity is disclosed internally only to the extent strictly necessary to conduct the investigation, and only to individuals bound by confidentiality obligations.

MAMA BIA prohibits retaliation of any kind against a person who, in good faith, submits a report or cooperates with an investigation under this Program. Retaliation includes, without limitation, termination, demotion, harassment, or any other adverse treatment connected to the making of a report. Allegations of retaliation are themselves treated as a serious compliance matter.

How Reports Are Reviewed

Every report received is handled according to a defined process, summarized below. The process is designed to ensure that reports are assessed consistently, impartially, and within a reasonable timeframe, regardless of who is involved.

Receipt and acknowledgment

The report is logged by the Compliance Department. Where contact information was provided, an acknowledgment may be sent to confirm the report was received.

Initial assessment

The Compliance Department reviews the report to determine its scope, the policies or standards potentially involved, and whether immediate action is required.

Investigation

Where warranted, a formal investigation is conducted with technical rigor and impartiality, independent of the seniority or role of the individuals involved.

Resolution and corrective action

Where a violation is confirmed, the Compliance Department determines and coordinates appropriate corrective measures in accordance with applicable policy.

All reports are treated with strict confidentiality and impartiality. This applies regardless of whether the report is submitted anonymously or with contact details provided.

Section 5

Contact

The Compliance Department of MAMA BIA is responsible for all compliance-related activities connected to the KRATOR+ platform, including inquiries regarding this Program, the Code of Conduct, corporate policies, and reports submitted through the Reporting Channel. Correspondence should be directed as follows.

Company: MAMA BIA
Platform: KRATOR+
Department: Compliance Department
Email: compliance@kratorplus.com