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Best Gold

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Best Bullion LLC

Best Bullion Gold & Jewellery Trading

Best Bullion

Bullion mart - Bahrain

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1.1. The emergence of rapid globalisation and accelerating technological disruption within recent years has caused money laundering, financing of terrorism and proliferation financing to become an issue of unprecedented magnitude. Every day, organisations across the globe see new threats arise due to their global presence and vast diversity of products, services, markets, business lines, and distribution channels. The interconnectedness and integration of the global financial and trade system, ever-changing payment methods, and fewer restrictions on the movement of human capital have given rise to a whole new range of sophisticated methods for criminals to launder money, finance terrorism and facilitate the proliferation of weapons . The need to be more vigilant on an international level has arisen with coordinated and coherent efforts required at various levels to protect the integrity and stability of the international financial system, cut off the resources available to terrorists, and make it more difficult for those engaged in crime to profit from their criminal activities.1.2. Money Laundering Any person shall be deemed to have committed money laundering if they know, or there are sufficient indications or evidence to believe, that the funds, in whole or in part, are the proceeds of a Predicate Offence, and intentionally commit any of the acts defined in Clause (1) of Article (2) of this Decree-Law, including through digital systems, Virtual Assets, or cryptographic technologies, namely:a) converting, transferring, or carrying out any transaction involving the proceeds for the purpose of concealing or disguising their illicit origin;b) concealing or disguising the true nature of the proceeds, their source, location, disposition, movement, ownership, or rights related thereto;c) acquiring, possessing, or using the proceeds upon receipt thereof; ord) assisting the perpetrator of the Predicate Offence in evading punishment therefore. Money laundering is defined as any financial or banking transaction - including its commission through digital systems, virtual assets, or cryptographic technologies - aimed at concealing or changing the identity of illegally obtained funds by passing them through the financial and banking system to make them appear as originating from legitimate sources, and then re-pumping and investing them in a legal manner contrary to their real nature. Simply put, money laundering is the process of making dirty money look clean. Criminals launder money so that they can avoid detection by law enforcement authorities and make personal use of illicit proceeds, including further criminal activity and investment in legitimate businesses. Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (the “AML/CFT/CPF Law”) defines money laundering as engaging in any of the following acts wilfully, or/and having sufficient indications that the funds are the proceeds of a felony or a misdemeanour including the financing of terrorism, the proliferation financing, and evasion of direct and indirect taxes (i.e., a predicate offence):• Converts, transfers, or carries out any transaction involving the Proceeds for the purpose of concealing or disguising their illicit origin.• Conceals or disguises the true nature of the proceeds, source, location, disposition, movement, ownership, or rights related thereto.• Acquires, possesses, or uses the Proceeds upon receipt thereof.• Assists the perpetrator of the Predicate Offence in evading punishment therefor. Stages of Money Laundering: Despite money laundering being a rather complex series of transactions, which are difficult to separate, it can be simplified into commonly consisting of three primary stages:1. Placement: This is the first stage in separating the illicit funds from their illegal source. During this phase, the initial proceeds that are derived from illegal activities are introduced into the financial system through typically, placing the funds into circulation through formal financial institutions, casinos, the real estate sector, the gold and precious metal industry, restaurant, and other legitimate businesses, both domestic and international.2. Layering: Once the proceeds from the illicit activities have entered the financial system, the next stage in the process involves converting the illegal funds into another form, creating complex layers of financial transactions to conceal the original source and ownership of the funds. This makes it difficult to associate the illegal funds with the predicate crime.3. Integration: This is the third stage that completes the money laundering cycle. By this stage, the laundered funds appear to be legitimate, and it is exceedingly difficult to distinguish between legal and illegal wealth. These integration schemes are done to ensure that laundered proceeds are placed back into the economy in what appear to be normal business or personal transactions.1.3. Financing of Terrorism Whoever intentionally provides, collects, or makes available funds by any means, directly or indirectly, including through digital systems, Virtual Assets, or cryptographic technologies, knowing that such funds shall be used, in whole or in part, for any of the following, shall be deemed to have committed Financing of Terrorism:a) the commission of a Terrorist Act or Acts;b) by a Terrorist or Terrorist Organisation;c) financing the travel of individuals to a State other than their residence or nationality to commit, prepare, plan, participate in, or facilitate a Terrorist Act, or providing funds for training on, or receiving training in, Terrorist Acts. For the purposes of this Clause, funds include any funds used in whole or in part, whether from legitimate or illegitimate sources, and regardless of whether they were actually used to commit or attempt a Terrorist Act, or linked to any specific act. Financing of Terrorism is deemed committed irrespective of the location of the accused relative to the Terrorist, Terrorist Organization, or the State where the act is or will be committed. The AML/CFT/CPF Law defines Financing of Terrorism as: Any person who provides, collects, prepares, or obtains funds or other assets, through any means, including digital systems, virtual assets, or encryption technologies, knowing that they will be used wholly or partially in any of the following cases, shall be considered to have committed the crime of financing terrorism:a) Committing a terrorist act or acts of terrorism;b) By a terrorist or terrorist organization; or c) Financing the travel or training of individuals for the purpose of committing, preparing, planning, organizing, participating in, or facilitating a terrorist act. For this definition, “funds used to finance terrorism” means any money or assets used in full or in part to support terrorism even if the money comes from a legal source. It does not matter whether the funds were actually used to carry out a terrorist act, or whether they are linked to a specific act. The offence still applies no matter where the person involved is located, where the terrorist group is based, or where the terrorist act takes place.1.4. Financing the Proliferation of Weapons Proliferation means the illicit and unauthorized trade, as regulated under the applicable legislation in the State, in materials, systems, equipment, components, programs, or technology contributing to the production or development of Weapons of Mass Destruction, related technology, or their means of delivery, including any act stipulated in Clause (3) of Article (3) of this Federal Decree Law. Except in cases permitted or authorized under the legislation in force in the State, or pursuant to treaties and agreements to which the State is a party, Proliferation Financing includes intentionally providing, collecting, or making available funds by any means, directly or indirectly, with knowledge that such funds shall be used, in whole or in part, for:a) the manufacture, possession, acquisition, development, production, sale, supply, export, transshipment, brokerage, transport, transfer, storage, or use of Weapons of Mass Destruction, their means of delivery, or related materials, including dual-use technologies and goods, when employed for said purposes; orb) any other act in accordance with United Nations Security Council resolutions issued under Chapter VII of the Charter of the United Nations concerning the prevention, suppression, and cessation of Proliferation and its Financing. Knowledge, as an element of Financing of Terrorism or Proliferation Financing, may be inferred from the factual and objective circumstances of the act. Proliferation Financing refers to the risk of potential breach, non-implementation, or evasion of targeted financial sanctions related to the proliferation of weapons of mass destruction. It involves the risk that funds, financial services, or other economic resources may be used, directly or indirectly, to support the development, acquisition, manufacture, possession, transfer, or use of weapons of mass destruction. This includes attempts to conceal the true purpose of transactions, the identities of the parties involved, or the ultimate destination of goods or funds in order to circumvent international sanctions and export control requirements. The AML/CFT/CPF Law defines Financing the Proliferation of Weapons as:• The act of providing, collecting, or making available funds or other assets, directly or indirectly, knowing that they will be used, wholly or partially, for the manufacture, acquisition, possession, development, production, sale, supply, export, transhipment, brokering, transfer, conversion, storage, or use of weapons of mass destruction (WMD), their delivery means, or related materials, including dual-use goods and technologies. • These activities are considered illegal unless they are specifically allowed under UAE law or under international agreements that the UAE has formally signed. Any actions covered by United Nations Security Council resolutions issued under Chapter VII of the UN Charter— aimed at preventing, stopping, or addressing the proliferation of weapons and their financing—are also treated as criminal offences. Knowledge and intent may be inferred from factual circumstances in both the crimes of financing terrorism and financing the proliferation of weapons.

DEFINITION OF MONEY LAUNDERING, FINANCING OF TERRORISM, AND PROLIFERATION FINANCING

2.1. National Legislative and Regulatory Framework2.1.1. The UAE is fully committed to combatting money laundering and terrorism financing and detecting deterring them in accordance through established legislation. The competent authorities have put in place an institutional system to oversee, control, and collect information on all practices that may lead to financial crimes, including money laundering and terrorism financing.2.1.2. Underpinned by its commitment to safeguard the UAE’s fiscal landscape from illegal financing and corruption, the National Committee for Combating Money Laundering, the Financing of Terrorism, and Proliferation Financing (NAMLCFTC) was established in 2000 to oversee anti money laundering policies and efforts in the UAE. Specifically, the Compliance Officer serves to enhance the effectiveness of the AML/CFT/CPF framework in the UAE by ensuring continuous adherence to international standards related to combatting money laundering and terrorist financing crimes.2.1.3. In August 2020, the Central Bank of the UAE (CBUAE) established a dedicated department, the Anti-Money Laundering and Combatting the Financing of Terrorism Supervision Department (AMLD), to handle all Anti-Money Laundering and Combatting the Financing of Terrorism matters (AML/CFT/CPF). Through AMLD, the CBUAE coordinates closely with the UAE’s National AML/CFT/CPF Compliance Officer to implement the National Action Plan effectively.2.1.4. As a committed member, the UAE contributes to global anti-money laundering efforts and combatting financing of terrorism and proliferation financing(AML/CFT/CPF) and strives to fully implement the standards set by the International Financial Action Task Force (FATF). In 2018, the UAE, with the extensive participation of all concerned authorities, conducted its first national risk assessment on money laundering and terrorist financing, identifying several areas in which the risks are high. The following Laws and their Implementation regulations have been issued to combat the threat of AML/CFT/CPF.▪ Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing repealing the Federal Decree Law No. (20) of 2018. .▪ Cabinet Resolution No. (134) of 2025 concerning the Executive Regulations of Federal Decree-Law No. (10) of 2025 concerning Combating Money Laundering Crimes, Combating the Financing of Terrorism and the Financing of the Proliferation of Weapons, repealing Cabinet Decision No. (10) of 2019. .▪ Cabinet Decision No. (58) of 2020 Regulating the Beneficial Owner Procedures as amended by Cabinet Decision No. (109) of 2023.▪ Cabinet Decision No. (74) Of 2020 On Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combatting of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its their Financing and Relevant Resolutions.▪ Cabinet Resolution No. (71) of 2024 regulating violations and administrative penalties imposed on violators of measures for confronting money laundering and combating terrorist financing subject to the control of the Ministry of Justice and Ministry of Economy &amp; Tourism, repealing Cabinet Resolution No. (16) of 2021.▪ Federal Law No. 7 of 2014 on Combatting Terrorism Offences.▪ Regulation No. 1/2019 regarding declaration of currencies, negotiable bearer financial instruments, precious metals &amp; precious stones in possession of travellers entering or leaving UAE (issued by the UAE Central Bank on 14/1/2019 pursuant to Article 8 of Federal Law No. 20/2018).▪ Federal Decree-Law No. (34) of 2021 On Countering Rumours and Cybercrimes, repealing Federal Law No. 5 of 2012 on Combatting Cyber Crimes.▪ Federal Law by Decree No. (31) of 2021 Promulgating the Crimes and Penalties Law, repealing the Federal Penal Law No. 3 of 1987, the Penal Code. ▪ Federal Decree by Law No. (38) of 2022, Promulgating the Criminal Procedures Law repealing Federal Penal Procedures Law No. 35/1992, the Penal Procedures Law.▪ Central Bank Board of Directors’ Decision No. 59/4/219 regarding procedures for AML and CTF and Illicit organisations. ▪ Guidelines for Financial Institutions on AML/CFT/CPF and illegal organisations issued by the UAE Central Bank on 23/6/2019.▪ Ministerial Decision No. (532) of 2019 regarding the establishment of the Anti-Money Laundering Department 2019▪ Decision of the Minister of Justice No. 533 of 2019 regarding the procedures for combatting money laundering and financing of terrorism for lawyers, notaries, and professionals.▪ Ministerial Decision No. 534/2019 on the establishment of the Compliance Officer for the management of frozen, seized, and confiscated assets.▪ Ministerial Decision No. 535/2019 on the procedures for the authorisation application presented by those designated on terrorist lists to use a part of frozen assets.▪ Ministerial Decision No. 536/2019 on the mechanism of grievance against the decisions issued regarding listing on local terrorist lists.▪ Ministerial Decision No. 563/2019 on the procedures and conditions of the applications for the international judicial cooperation in the distribution of the proceeds of crime.▪ Circular No. (2) of 2023 Data Disclosure Notice for Dealers in precious metal and stone.▪ Circular No. 1 of 2024 has updated the list of High-Risk Jurisdictions subject to Call for Action and the list of Jurisdictions under Increased Monitoring.▪ Cabinet Decision No. (132) of 2023 regarding the administrative penalties imposed on violators.▪ Ministerial Decision No. (68) of 2024 Regarding adherence to the Policy of Due Diligence Regulations for Responsible Sourcing of Gold.▪ Circular No. (3) of 2024 on updating the list of High-Risk Countries / Jurisdictions subject to a Call for Action, and list of Countries / Jurisdictions under Increased Monitoring, and update the countermeasures to be applied by Designated Non-Financial Business &amp; Professions (DNFBPs).▪ Circular No. (4) of 2024 on updating the list of High-Risk Countries / Jurisdictions subject to a Call for Action, and list of Countries / Jurisdictions under Increased Monitoring, and update the countermeasures to be applied by Designated Non-Financial Business &amp; Page | 12 Professions (DNFBPs).▪ Circular No. (1) of 2025 on updating the list of High-Risk Countries / Jurisdictions subject to a Call for Action, and list of Countries / Jurisdictions under Increased Monitoring, and update the countermeasures to be applied by Designated Non-Financial Business &amp; Professions (DNFBPs).▪ Circular No. (3) of 2025 emphasizing on the importance of screening sanctions and terrorist lists.▪ Circular No. (4) of 2025 on Understanding the Importance of the UAE 2024 National Risk Assessment.▪ Circular No. (5) of 2025 on Jurisdictions subject to a Call for Action, and list of Countries / Jurisdictions under Increased Monitoring, and update the countermeasures to be applied by Designated Non-Financial Business &amp; Professions (DNFBPs)▪ Circular No. 6 of 2025 on Emphasizing the Implementation of Risk-Based Customer Due Diligence Measures (with a Focus on Simplified Due Diligence)2.2. International Legislative and Regulatory Framework2.2.1. Fighting against money laundering, financing of terrorism and proliferation financing is critical for international security, the integrity of the financial system, and sustainable growth. In response to the threats posed by money laundering and terrorist activities, the international community has acted on many fronts, including the creation of various organisations that act as the international standard setters.2.2.2. The UAE’s AML/CFT/CPF legislative and regulatory framework is part of a much larger international AML/CFT/CPF legislative and regulatory framework comprising system of intergovernmental legislative bodies and international and regional regulatory organisations. Based on international treaties and conventions in relation to combatting money laundering, the financing of terrorism, and the prevention and suppression of the proliferation of weapons of mass destruction, intergovernmental legislative bodies create laws at the international level, which participating member countries then transpose into their national counterparts. In parallel, international and regional regulatory organisations develop policies and recommend, assess, and monitor the implementation by participating member countries of international regulatory standards in respect of AML/CFT/CPF.2.2.3. Among the major intergovernmental legislative bodies, and international and regional regulatory organisations, with which the government and the Competent Authorities of the UAE actively collaborate within the sphere of the international AML/CFT/CPF framework are:▪ The United Nations (UN)▪ The Financial Action Task Force (FATF)▪ The Middle East and North Africa Financial Action Task Force (MENAFATF)▪ The Egmont Group of Financial Intelligence Units

AML/CFT/CPF LEGAL AND REGULATORY FRAMEWORK

3.1. NEW BEST GOLD JEWELLERY TRADINGS LLC (“NEW BEST GOLD” or “the Company”), a responsible entity registered with the Dubai Department of Economy and Tourism, is committed to supporting both domestic and international efforts to combat money laundering, the financing of terrorism, and proliferation financing. The Company also implements appropriate internal measures necessary to achieve these objectives.3.2. NEW BEST GOLD team considers commitment to uphold strict standards of ethical conduct to be a source to create sustainable value and essential for preserving the stakeholders’ confidence. Bearing this in mind, the policies that endorse the strict compliance with the legal framework governing the prevention of money laundering and terrorism financing become a top priority for the Company.3.3. NEW BEST GOLD team is directly responsible for compliance with regulatory standards and assisting in efforts to combat money laundering, financing of terrorism and proliferation financing. The Company wants to convey its position on AML/CFT/CPF via this Policy Document and to reaffirm that the Company will only conduct business activities in strict compliance with all relevant laws, regulations, and best global practices in the domain of AML/CFT/CPF. NEW BEST GOLD regards the fight against ML and/or FT or PF as a matter of great importance for the organisation and views it as a collaborative endeavour. NEW BEST GOLD’s commitment to combatting money laundering and terrorist financing is demonstrated through the publication of this Policy, as well as the implementation and operation of the processes and controls included therein.3.4. NEW BEST GOLD is willing to support and cooperate with:• Government agencies; and• Recognised law enforcement agencies, domestic or international, including global regulatory bodies such as FATF, OFAC, UN, EU, and the local regulatory authority, namely the Central Bank of the UAE (CBUAE) and Anti-Money Laundering and Combatting the Financing of Terrorism Supervision Department (AMLD), as part of any effort in combatting money laundering and/or the financing of terrorism.3.5. NEW BEST GOLD shall maintain the highest operating standards to safeguard the interests of all stakeholders, including customers, shareholders, employees, business partners, and the jurisdiction in which the Company operates. This shall be accomplished through constantly staying updated on international and national AML/CFT/CPF policies, ensuring ongoing and continual training of staff members, usage of up-to-date technology and systems that support the efforts to combat money laundering and counter terrorist financing, and other related financial crimes.3.6. As an established organisation conducting business in the gold and precious metals sector, NEW BEST GOLD is committed to responsibly ensuring that none of its activities and acquisition of materials contributes to Money Laundering, Terrorism Financing, or serious Human Rights abuses, by ensuring that risks associated with gold and precious metals during procurement, distribution, transport, explore and sell and/or purchase, are identified and assessed appropriately.3.7. As a responsible organisation in the gold and precious metals sector, NEW BEST GOLD adheres to the following guidelines and codes:● OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas(CAHRA)● Responsible Jewellery Council (RJC) Code of Practice (CoP)● London Bullion Market Association (LBMA) Responsible Gold Guidance● DMCC Rules for Risk-Based Due Diligence in the Gold and Precious Metals Supply Chain ● Due Diligence Guidelines on Responsible Sourcing of Gold by the Ministry of Economy

NEW BEST GOLD JEWELLERY TRADINGS LLC COMMITMENT STATEMENT

4.1. The provisions, procedures, and controls detailed below shall apply to: • All employees, if any, regardless of their function or location of work. • All clients, including Buyers, Sellers, Refiners, Suppliers, Gold &amp; Precious Metals Companies. 4.2. Employees of NEW BEST GOLD are responsible for ensuring that they comply with the standards established by local and international regulatory agencies. They are further expected to protect preventing NEW BEST GOLD and its reputation from being exploited for any illegal activity. 4.3. If any of NEW BEST GOLD’S employees or affiliates violate the provisions contained within this Policy, such violations will be treated as a disciplinary offence, and NEW BEST GOLD reserves the right to take any additional action that it, in its sole discretion, deems necessary to ensure the diligent and proper implementation and enforcement of this Policy. 4.4. If NEW BEST GOLD, its personnel, and/or premises are inadvertently used for money laundering or other illegal activities, NEW BEST GOLD can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee is familiar with and complies with the processes and procedures set forth in this Policy. 4.5. If any client of NEW BEST GOLD is found to have breached any provisions of this Policy, then NEW BEST GOLD may take any of the following measures, in accordance with the severity of the violation: • Warning. • Temporary suspension of the operations of the Client’s account. • Termination of the Client’s account. • Reporting to the relevant Authorities.

SCOPE OF APPLICATION

5.1. The Compliance Officer has been designated as the custodian of this Policy Manual for Anti-Money Laundering and Combatting the Financing of Terrorism and Proliferation Financing. 5.2. Although, the Compliance Officer is the custodian of the Policy, management at NEW BEST GOLD shall have responsibility for enforcement of this Policy within the organisation and with its clients.

POLICY CUSTODIAN

6.1. This AML/CFT/CPF Policy shall be reviewed on at least an Annual basis. Any review shall take into consideration legislative changes regarding AML/CFT/CPF and shall also examine the previous twelve months' implementation of the Policy, how the implementation may be improved, and any subsequent comments made during periodical checks by relevant authorities. Any amendments made to the Policy must have received prior written sign-off from the NEW BEST GOLD Senior Management, and or Team, whereupon they shall take effect immediately.

PERIODICAL REVIEW

7.1. NEW BEST GOLD is a Limited Liability Company registered with the Dubai Economy and Tourism (licensing authority) since 2022, holding Trade License No. 1100729. The Company is exclusively engaged in the trading of precious metals. NEW BEST GOLD is a customer-centric organisation, committed to delivering high-quality, end-to-end services tailored to meet the diverse needs of its clients. 7.2. NEW BEST GOLD does not accept cash transactions. In the event that any cash transaction exceeding UAE Dirhams 55,000 is identified or occurs, the same shall be promptly reported through the goAML Portal in accordance with applicable regulatory requirements. 7.3. NEW BEST GOLD's head office is located at 113 BUILDING 5B AL HIND, AL DHAGAYA, DEIRA, DUBAI, UAE. NEW BEST GOLD ensures a consistent and responsible supply of high-value precious metals for its clients physical and trading requirements. Moreover, NEW BEST GOLD has taken proactive steps to align with regulatory requirements. 7.4. The principal business activity of the company is trading of precious metals, including gold and silver. The company undertakes physical precious metals trading from its office premises and facilitates trading through its online e-commerce platform, including its website and mobile application, under the brand name “Best Gold”. As per their trade licence, the permitted business activities include Trading of Raw Gold, Precious Metals, Jewellery made of Gold and Silver, and Diamonds, Pearls, and Other Precious Stones. 7.5. The Company is registered on the Financial Intelligence Unit’s goAML portal and is also registered with the website of the Executive Office for Control and Non-Proliferation (EOCN). This enables it to receive regular notifications pertaining to the inclusion or removal of entities/individuals from terrorist lists. This registration showcases NEW BEST GOLD’s commitment to compliance with regulations aimed at controlling and prohibiting proliferation. NEW BEST GOLD ensures to take appropriate action whenever any such notification is received.

NEW BEST GOLD JEWELLERY TRADINGS LLC SERVICES

8.1. To mitigate and control the risk involved, the AML programme at NEW BEST GOLD will create three lines of defence.• Operations: This is the first line of defence. As the frontline for Know Your Customer (KYC) and Customer Due Diligence (CDD), the Company will handle customer onboarding, identification, and due diligence – all processes that require the collection and analysis of immense amounts of data, primarily acquired through lengthy customer questionnaires and investigations. Whereas for E-Commerce Platform, customer information obtained through the digital platform and identity and verification (ID&amp;V) documents are requested, such as passports and Emirates IDs, which are authenticated and verified using third-party verification software.• Compliance: This is the second line of defence. It constitutes functions that oversee risks. The Compliance Department will develop policies and procedures, devise customer questionnaires and requirements, and maintain the technologies necessary to streamline KYC and CDD processes. Where deemed necessary, the Company may hire the services of specialist consultants to design the AML/CFT/CPF Policies and Procedures and to attend training to understand the regulatory regime and the process to be followed. The Company will also design the criteria to divide the clients into risk categories and monitor ongoing Suspicious Transactions, if any.• Internal Audit: This is the third line of defence. This function provides independent assurance to determine if proper controls are established. NEW BEST GOLD may appoint an independent compliance internal audit reviewer to conduct a periodic review to ensure that KYC and CDD programmes are based on complete, correct information, and approved protocols have been followed at the time of customer onboarding and during the execution of transactions. In the event of any perceived gaps, the shortfall will be presented to the management, and a remediation action plan will be developed.8.2. AML/CFT/CPF Governance Elements The Company has a Policy to follow the below-mentioned approach to ensure a strong and effective AML/CFT/CPF compliance culture in the Company.8.3. Responsibilities of Senior Management Senior Management of the Company is committed to ensuring that an effective AML/CFT/CPF compliance programme is in place. Further, the senior management has clearly articulated their expectations with regard to the responsibilities and accountability of all staff members in relation to the AML/CFT/CPF compliance programme. As part of this Policy, the Company has defined the responsibilities of the senior management as under:• Appointing a qualified management level AML/CFT/CPF Compliance Officer, possessing appropriate competence and independence duly approved by the Supervisory Authority,• Ensuring a robust and effective independent audit function is in place,• Putting in place and monitoring the implementation of adequate management and information systems, internal controls, and policies, procedures to mitigate risks,• Approval of internal policies, procedures, and controls, including customer acceptance,• Reviewing and providing comments in relation to the CO's periodic reports to the relevant Supervisory Authority,• Approving the establishment and continuance of High-Risk Customer Business Relationships and their associated transactions, including those with PEPs.• Application of the directives of Competent Authorities regarding combating Money Laundering and Terrorism Financing.

GOVERNANCE OF RISK: THREE LINES OF DEFENCE

9.1. NEW BEST GOLD has established an AML/CFT/CPF Compliance Officer, who is responsible for the coordination and implementation of AML/CFT/CPF procedures within the company. The AML/CFT/CPF Compliance Officer has a wide-ranging mandate assigned, including the task of ongoing monitoring and coordinating the identification, assessment, and mitigation of the risks that NEW BEST GOLD is or might be exposed to pertaining to money laundering and terrorism financing. Hence, NEW BEST GOLD ensures that a strong and suitable AML/CFT/CPF structure is in place.9.2. NEW BEST GOLD’s AML/CFT/CPF Compliance Officer plans to hold at least four (4) regularly scheduled meetings each year to discuss AML/CFT/CPF matters, review action plans, and recommend follow-up actions based on outcomes of the reviews. The Compliance Officer shall try to conduct at least one (01) meeting each Quarter, but under no circumstances shall the gap between two (2) AML/CFT/CPF Compliance Officer meetings be more than six (6) months. The Compliance Officer shall discuss initiatives required to be undertaken to continually improve NEW BEST GOLD’s accomplishments within the AML/CFT/CPF area.9.3. The AML/CFT/CPF Compliance Officer shall maintain written minutes or other records of its meetings and activities. Minutes of each meeting of the Compliance Officer shall be distributed to every member of the Compliance Officer.9.4. The Compliance Officer’s key responsibilities will be as follows:• To prepare a Policy and process Manual for implementing the provisions of the UAE’s Federal (10) of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, and Cabinet Resolution No. (134) Of 2025.• To ascertain the proper implementation and effectiveness of the procedures and processes for fighting money laundering and terrorism financing operations within NEW BEST GOLD’s.• To prepare the staff training programme on the methods of controlling financial and banking operations, in accordance with the control procedure guide, and with other legal and regulatory texts in force.• To review the above-mentioned procedures and processes periodically and develop them in line with up-to-date methods and guidance established on combatting money laundering and financing of terrorism.• To periodically assess the Company’s approach to risk identification, assessment, and mitigation plans for the principal legal and regulatory compliance risks facing the company and review the results of it.• To prepare an effective customer identification and due diligence programme for onboarding a new customer, as well as updating CDD throughout the entire relationship with the customer.• To periodically review resources, systems, and tools that are available to the Compliance Officer and ensure that up-to-date with the current international and national standards and are appropriate to the nature, size, and complexity of the business.• To review findings of the internal audit and suggest necessary modifications to the Compliance Programme.• To review ongoing challenges/issues in the implementation of the AML/CFT/CPF procedures and processes and ensure that proper controls are in place to mitigate/solve them.• To take corrective/preventive actions if any gaps are identified.• To discuss information about current and emerging legal and regulatory compliance risks and enforcement trends that may affect the Company’s business operations, performance, or strategy.• To review the reports submitted by the Compliance Unit on adopted procedures, unusual Page | 18 operations, and high-risk customers.• To define the procedures and processes to be followed by the senior management team for approving business relationships with high-risk customers or when executing high-risk transactions.• To discuss developing internal programmes focussed on promoting an ethical culture within the organisation.• To review any data suggesting significant non-compliance involving any of the Company’s officers or staff. The Compliance Officer will report to the Money Laundering Reporting Officer any data suggesting significant non-compliance that could affect the Compliance Programme or the Company.• To review on a regular basis the company’s significant risk exposures or compliance violations and the steps that have been taken to monitor, correct, and/or mitigate such violations or risks.• To discuss the following areas and decide whether any actions need to be taken: • Updates on Sanctions• Notices / Circulars received from the Regulatory Authority • Suspicious Activity Reports (SARs) raised during the Quarter• Enhanced CDD conducted during the Quarter• Training conducted and attendance records of the staff• Feedback / Queries received from the Regulatory Authority• Pattern Analysis conducted during the Quarter• Any new risks associated with AML/CFT/CPF that are identified.

POLICY GOVERNANCE

10.1. The ultimate responsibility for proper supervision, reporting, and compliance pursuant to AML/CFT/CPF shall rest with NEW BEST GOLD and its senior management. 10.2. The Head of the AML/CFT/CPF - Compliance Officer will be responsible for the following: • Oversight of all compliance related activities at NEW BEST GOLD. • Establishing transparency, honesty, and integrity throughout the business activities. • Implement a robust compliance program across all its products, services, suppliers, customers, jurisdictions of operation, and delivery channels, including digital and physical transaction platforms. • Ensuring that NEW BEST GOLD has in place adequate screening procedures to ensure high standards when appointing or employing officers or employees. • Approving the overall business risk assessment for NEW BEST GOLD. • Reviewing the quarterly compliance report along with high-risk areas in case an internal audit review is conducted. • Ensuring that all employees of the organisation are being trained on the AML/CFT/CPF. • Preparing, Approving, and Implementation of the Compliance Policy of the Organisation. • Reviewing any issues identified during the CDD process and resolving them in a timely manner. • Developing a good knowledge of all applicable Laws, Rules, Regulations, Notices, and the Standards related to the Precious Metals and Stones industry in the UAE. • Setting the tone of zero tolerance against fraud. 10.3. NEW BEST GOLD JEWELLERY TRADINGS LLC has appointed Mr. Sajith C.S to act as authorised Money Laundering Reporting Officer (MLRO) of the Company. The MLRO will also be responsible for: • Creating and implementing the AML/CFT/CPF compliance programme for NEW BEST GOLD and ensuring compliance with AML/CFT/CPF Laws, Regulations, Notices, the Standards, and international laws. • Establishing and maintaining AML/CFT/CPF policies, procedures, processes, and controls in relation to the business of NEW BEST GOLD JEWELLERY TRADINGS LLC. • Ensuring compliance by NEW BEST GOLD with the provisions of AML/CFT/CPF Guidelines, its implementing rules and regulations, and NEW BEST GOLD’s AML/CFT/CPF and KYC Policy. • Reading any circulars, resolutions, instructions, and policies issued by the UAE Regulatory Agencies in all matters relating to the prevention of ML/CFT and Financing the proliferation of weapons and Illegal Organisations. • Liaising between NEW BEST GOLD and UAE Regulatory Agencies in matters relating to compliance with the provisions of the AML/CFT/CPF Compliance Guidelines and its rules and regulations. • Preparing and submitting to the UAE Regulatory Authorities written reports on NEW BEST GOLD’s compliance with the provisions of the AML/CFT/CPF Compliance Guidelines and its implementing rules and regulations, in such form as the UAE Regulatory Agencies may determine, and within such period as the UAE Regulatory Agencies may allow in accordance with the AML/CFT/CPF Guidelines. • Create a gap analysis document on existing AML/CFT/CPF Procedures and current Laws, Regulations, Notices, and the Standards of the UAE to determine the extent of the level of compliance and recommend actions if required. • Attending the compliance training programme, particularly when any laws change. • Raising Internal Suspicious Transaction alerts, if any, and investigating the matter along with presenting the findings to report all suspicious cases to the FIU. • Reporting and filing Suspicious Transaction Report (STR) to FIU, if required • Providing support and assistance to FIU with all the information it requires for fulfilling its obligations. • Performing more extensive due diligence for high-risk customers and including proactive monitoring for suspicious types of activities. 10.4. The Compliance Function will be responsible for the following: • Implementing NEW BEST GOLD’s AML/CFT/CPF Policy and Procedures. • Carrying out the compliance officer role to ensure that the functions are adhering to the regulations. • Customer onboarding and KYC documentation. • Conducting Customer Due Diligence and Enhanced Due Diligence. • Liaising with other companies to obtain documents and information as required. • Monitoring day-to-day transactions of NEW BEST GOLD for any unusual, structured, suspicious, and blacklisted ones. • Monitoring trade-based money laundering and tracing structured transactions. • Monitoring of suspicious accounts periodically. • Reviewing and addressing the watch list and alerts. Update the blacklists on a regular basis. • Liaising with the compliance department of other companies. • Creating sound internal controls and monitoring adherence to them. • Maintaining records as required by NEW BEST GOLD’ AML/CFT/CPF Policy &amp; Procedures. • Taking proper remedial actions and informing the Senior Management if violations are identified. • Reporting of unusual or suspicious transactions to the Senior Management. • Educating the staff at NEW BEST GOLD regarding AML/CFT/CPF and 'Know Your Customer’ procedures.

ROLE OF THE COMPLIANCE OFFICER / MONEY LAUNDERING REPORTING OFFICER

11.1. The Compliance Officer will conduct an internal audit to assess the effectiveness of the AML/CFT/CPF Compliance and ensure its processes comply with regulatory requirements. The internal auditor will also play an important role in improving the controls by regularly tracking potentially identified weaknesses. Internal audit employees should have sufficient AML/CFT/CPF expertise and auditing experience. However, given the limited business transactions and small clientele/customers for the Company, an internal auditor may not be required immediately. 11.2. While conducting the Internal Audit, the Compliance Officer will have the following responsibilities: • Conducting periodic assessment of relevant AML/CFT/CPF programme documentation (for example, KYC/CDD/Enhanced Due Diligence (EDD) policies and procedures and procedures related to identifying, investigating, and reporting suspicious transactions); • Conducting testing of AML/CFT/CPF controls and processes carried out by the Company, such as KYC/CDD/EDD, training, suspicious-activity reporting, record keeping, and retention, among others. • Conducting periodic evaluation of NEW BEST GOLD’s AML/CFT/CPF Risk Assessment; and • Following up on any remedial actions arising from independent audit or regulatory findings.

COMPLIANCE INTERNAL AUDIT

12.1. The purpose of this Policy is to set out provisions, procedures, and controls as enacted by NEW BEST GOLD concerning Anti-Money Laundering (“AML”) and Combatting the Financing of Terrorism and Proliferation Financing (“CFT/CPF”). All relevant personnel at NEW BEST GOLD must be aware of its existence and the contents within the Policy and hold the personal and corporate responsibility to bring any AML/CFT/CPF concerns to the attention of the AML/CFT/CPF Compliance Officer and/or any of its members. 12.2. The rationale behind the Policy is unequivocally clear. NEW BEST GOLD JEWELLERY TRADINGS LLC will only accept those Business Relationships: • Whose sources of funds can be reasonably established as legitimate; and • Who do not pose any risk (actual or potential) to NEW BEST GOLD’s reputation and commitment towards AML/CFT/CPF. 12.3. NEW BEST GOLD will also ensure that all its staff is aware of the Policy and its contents, including the penalty for any non-compliance, and will not tolerate any involvement in illegal activities.

PURPOSE & RATIONALE

13.1. The precious metals and stones sector offers opportunities for criminals seeking to conceal, transfer, and/ or invest their illicit proceeds. Like cash, precious metals and stones offer high value by weight, are difficult to trace and identify, and retain their value over time. Dealers in Precious Metals and Stones (DPMS), if they do not apply effective preventive measures, could be vulnerable to abuse by illicit actors engaged in laundering the proceeds of crime, financing of terrorism, arms trafficking, and sanctions evasion. 13.2. Risks Associated with Precious Metals and Stones • Precious metals and stones are generally compact, durable, odourless, and of high value. • Certain metals/stones (e.g., gold/diamond) are widely accepted as a method of exchange or currency. • Precious metals/stones retain their value over time and have roughly similar value all over the world. In addition to these properties, precious metals and stones have characteristics that make them particularly attractive to criminals seeking to launder funds and others engaged in illicit behaviour: • Differentiating precious metals and stones often requires laboratory techniques, so it can be difficult or impossible to track their movement. • Precious metals and stones can be transformed (through re-cutting or recycling) into different objects while retaining their value, interrupting known custody and transfer chains. • Purchase, sale, and exchange of precious metals often take place outside the formal financial system. For these reasons, DPMS may be targeted by illicit actors seeking to abuse their services and exploit the advantages of precious metals and stones. Although most transactions involving DPMS are legal, these businesses may trade in items that could be the proceeds of crime, purchased with the proceeds of crime, and/or used to launder the proceeds of crime, unknowingly or complicitly. DPMS poses a risk to NEW BEST GOLD. Complicit DPMS may knowingly partake in illicit activities and may, in turn, use their business relationships with NEW BEST GOLD to launder the proceeds of crime or carry out other illicit activity. Even DPMS that are not knowingly involved in illicit activities may use their accounts with NEW BEST GOLD to deal in the proceeds of crime. 13.3. Features of DPMS that Increase Risk Not all DPMS pose equal risk. A DPMS is likely to be considered higher risk when it provides products or services that are attractive to illicit actors, has operations in high-risk jurisdictions, or does not apply appropriate anti-money laundering/combatting the financing of terrorism and proliferation financing (AML/CFT/CPF) controls. 13.3.1. Regulatory Environment In many jurisdictions, DPMS are not required to comply with requirements related to the identification of customers and reporting suspicious activities. In other jurisdictions, these requirements are nominal. In jurisdictions where DPMS are not subject to effective supervision and enforcement, or where such oversight is weak, compliance measures are often inadequate. Even in jurisdictions with robust regulations, these requirements typically apply only to DPMS engaging in cash transactions above a certain value threshold. Where DPMS are unregulated or under&nbsp; regulated, they are unlikely to implement effective measures to protect themselves from abuse. In contrast, an effective AML/CFT/CPF framework and supervisory regime for DPMS can protect DPMS by effectively imposing AML/CFT/CPF requirements and by detecting, deterring, and prosecuting ML/TF crimes. It is important to note that certain DPMS in the UAE are required to comply with all requirements of the AML-CFT Decision, including the requirement to perform Customer Due Diligence (CDD) and report suspicious transactions. 13.3.2. Products, Services, and Delivery Channels Products, services, and delivery channels that facilitate the rapid, efficient, anonymous movement of value on a large scale will be more attractive to illicit actors and may put a DPMS at a higher risk of abuse. Such products, services, and delivery channels may include: • Products (such as bullion and uncut stones) that are particularly hard to trace, retain, or even increase in value despite being transformed into new forms (melted down, re-cut, etc.), and offer high value by weight. • Services, such as metal accounts, that allow customers to rapidly purchase and sell precious metals. • Delivery channels that allow transactions to be carried out quickly and anonymously, such as accepting cash or virtual assets and conducting transactions online or through intermediaries. • Digital platforms through which the precious metals are purchased and sold, without any face-to-face identification. 13.3.3. Customer Base The types of customers that a DPMS serves can also impact risk. For example, a DPMS that primarily deals with PEPs may be higher risk than one that serves a lower-profile clientele. 13.3.4. Geography DPMS may be based, or may trade internationally, in jurisdictions that are higher risk for money laundering, the financing of terrorism, and the financing of proliferation. Such DPMS may pose a heightened risk to LFIs. Higher-risk jurisdictions may be characterised by: • A low level of government oversight and regulation of the precious metal and stone value chain; • Low economic and political stability; • High use of the informal banking system; • High levels of corruption; • The presence of terrorists and other non-state armed groups; • Weak border control measures; and/or • Sanctions and embargoes 13.4. ML/TF/PF Risks to be considered by NEW BEST GOLD: When required to apply AML/CFT/CPF measures, NEW BEST GOLD should carefully consider factors such as customer risk, geographic risk, channel risk, and product, service, and transaction risk. Consideration should be given to such factors as: • Country of origin of the Precious Metals and Stones (PMS) — Particularly in relation to whether the country is a known production or trading hub for the type of PMS; has adequate regulations and controls; is a High-Risk Country (e.g. is subject to international financial sanctions, has a poor transparency or corruption index, or is a known location for the operation of criminal or terrorist organisations). • Country of origin or residence status of the counterparty or customer (whether a UAE national or a foreign customer, and in the case of the latter, whether associated with a High-Risk Country), particularly in relation to locations where the transaction is conducted, and the goods are delivered. • Channel by which the counterparty/customer is introduced (e.g., referrals versus walk-in, international versus domestic, in-person or via the digital platform or other media) and communicates (e.g., remote or personal contact, direct or indirect through a proxy). • Type, nature, and characteristics of the products and/or services, including but not limited to quantity, quality/level of purity, price/value, form (whether physical or virtual, raw/rough or processed/finished, etc.), rarity, portability, potential for anonymity. • Type, size, complexity, cost, and transparency of both the transaction (including whether the physical or virtual exchange of merchandise is involved) and the means of payment or financing—particularly in relation to whether they appear to be consistent with the counterparty or customer’s socio-economic profile, local market practices, and the degree of expertise required. • Use of complex trade structures, unnecessary intermediaries, front companies, or opaque ownership arrangements without clear commercial justification. • Inconsistencies or anomalies in trade documentation, including discrepancies between invoices, contracts, shipping documents, quantities, values, or descriptions of goods.

RISK FACTORS OF SPECIFIC CONCERN TO NEW BEST GOLD JEWELLERY TRADINGS LLC

14.1. NEW BEST GOLD is required to establish and implement internal control procedures aimed at preventing and impeding money laundering, financing of terrorism, and Proliferation Financing. This Policy contains, as an integral part of it, certain procedural checks and balances (collectively “Procedures and Controls”) to ensure the vigilant and effective operation of the Policy. 14.2. Such procedures shall, among other things, ensure that all stakeholders are aware of the provisions of the law, its implementing rules, and regulations, as well as all reporting and control procedures established by NEW BEST GOLD and the supervising authority. 14.3. NEW BEST GOLD shall see to it that their respective policies and procedures for dealing with AML/CFT/CPF are clearly set out and reflected in their operating manual. 14.4. The Procedures &amp; Controls are as follows: • Identification, Verification, and Know-Your-Customer (“KYC”) and updating of KYC information • Activity Monitoring • Reporting of Suspicious Activities • Training and Awareness • Record Keeping

PROCEDURES AND CONTROLS (GENERAL)

15.1. Identification (ID), Verification (VR), and Know-Your-Customer (KYC) are effective defences against money laundering and/or financing of terrorism, and all together, form the first key step in the Procedures and Controls. Carrying out ID, VR, and KYC procedures is mandatory.15.2. NEW BEST GOLD shall establish, document, and maintain a written identification, verification, and KYC programme (hereinafter referred to as “Customer Identification Programme”) appropriate for its size and business that, at a minimum, includes each of the requirements under the KYC Checklist. The Customer Identification Programme shall be part of NEW BEST GOLD’s AML/CFT/CPF compliance programme.15.3. NEW BEST GOLD shall obtain and record competent evidence of the true and full identity of the client, Ultimate Beneficiary Owner, representative capacity, domicile, legal capacity, occupation, or business purposes of clients, as well as other identifying information on those clients, whether they be occasional or usual, using documents detailed in the KYC Checklist. Following applicant screening and background information check, along with review of business plan, source of funds, and expected levels of activity, an initial decision will be made with respect to the application status. This includes whether the client may be accepted, rejected, or whether more information may be required.15.4. Clients should be made aware of the NEW BEST GOLD’s explicit policy that business transactions will not be conducted with applicants who fail to provide competent evidence of their activities and identity, but without derogating from NEW BEST GOLD’s legal and ethical obligations to report suspicious transactions. Where initial verification fails to identify the applicant or give rise to suspicion that the information provided is false, additional verification measures should be undertaken to determine whether to proceed with the business transaction. Details of the additional verifications are to be recorded.15.5. If during the business relationship, NEW BEST GOLD has reason to doubt • the accuracy of the information relating to the customer’s identity; or• that the customer is the beneficial owner; or• the intermediary’s declaration of beneficial ownership; or• If there are any signs of unreported changes, NEW BEST GOLD shall take further measures to verify the identity of the customer or the beneficial owner, as applicable. Such measures may include the following:• Referral of names and other identifying information to criminal investigating authorities; and • Review of disciplinary history and disclosure of past relevant sanctions.15.6. The Customer Identification Programme must include procedures for responding to circumstances in which the Compliance Monitoring Team cannot form a reasonable belief that it knows the true identity of a customer. These procedures should describe, among others, the following:• When NEW BEST GOLD should not do business with a client• The terms under which a customer may conduct business transactions while NEW BEST GOLD attempts to verify the customer’s identity.• When NEW BEST GOLD should file a Suspicious Activities / Transaction Report15.7. The Customer Identification Programme must include procedures for providing customers adequate notice that NEW BEST GOLD is requesting information to verify their identities.15.8. For NEW BEST GOLD’s E-Commerce platform, customer identification and verification for individual customers is conducted through onboarding questionnaires and identity and verification (ID&amp;V) documents, such as passports and Emirates IDs, which are authenticated and verified using third party verification software’s.15.9. In rare events or incidences where a Customer fails to provide adequate KYC information or appears hesitant/unwilling to provide information as required to establish adherence to KYC norms, NEW BEST GOLD shall not proceed with a transaction for such a Customer and flag the case as a High-Risk customer. Such cases are marked for reporting to the Regulator through Suspicious Transaction Report (STR), and for increased monitoring.

IDENTIFICATION, VERIFICATION, AND KNOW-YOUR-CUSTOMER (KYC)

16.1. In general, NEW BEST GOLD will have the following as its customers: • Natural persons• Legal persons, including individual members of corporations.16.2. Natural persons and individual members of the corporate customers:16.2.1. NEW BEST GOLD shall obtain from all individual members of corporate customers, including shareholders, beneficial owners, directors, managers, authorised signatories, power of attorney holders, and other key managerial people, the following information: • Individual’s full name (as per passport)• Date and place of birth• Nationality• Passport Number• National Identity Document (Emirates ID, for the UAE nationals/residents)• Physical Address (residential and business/home country and the UAE)• Contact details.• Source of funds and wealth• Declaration regarding Beneficial Ownership, that is, the person who has ultimate ownership.• Whether the customer is a Politically Exposed Person (PEP) or a Close Associate of a PEP The above list is a summary of the information required. A detailed checklist is attached in Appendix A. 16.2.2. As part of the process for identifying and verifying customers, and for authenticating the original documents upon which the verification is based, NEW BEST GOLD will include procedures for the certification of the customer identification and address documentation it obtains. NEW BEST GOLD shall request members of corporate clients to produce or show the original documents for verification purposes. Such procedures will encompass:• Certification by employees (for example, by including the name, title of position, date, and signature of the verifying employee(s) on the copies of documents maintained on file, along with a statement representing that the copy of the document is a “true copy&nbsp; of the original”) and/or,• third parties (for example, by including the name, organisation, title of position, date, and signature of the verifying person, along with a statement representing that the copy of the document is a “true copy of the original”). If physical verification is not possible, or the customer is not in the UAE, NEW BEST GOLD staff may do the verification of original ID on a secured video platform such as Zoom or Google Meet and store a screenshot of evidence of verification.16.2.3. For individual, in case the original ID documents cannot be presented for verification, a duly authenticated document by the UAE Embassy in the home country of the individual or duly attested documents by a UAE Notary Public in case the individual is in the UAE can be acceptable in place of the original documents. In cases where documents are obtained from foreign sources in countries that are members of the Hague Apostille Convention, NEW BEST GOLD may request documents certified by an Apostille seal.16.3. LEGAL PERSONS16.3.1. Before establishing a business relationship, a company search and/or other commercial inquiries shall be made to ensure that the corporate/other business applicant has not been, or is not in the process of being dissolved, struck off, wound up, or terminated. In case of doubt as to the veracity of the corporation or identity of its directors and/or officers, or the business or its partners, a search or inquiry with the relevant Supervising Authority/Regulatory Agency shall be made.16.3.2. Third-party verification software is integrated with the E-Commerce digital platform. Customer onboarding involves submitting a passport or Emirates ID, which is authenticated for validity. The process also includes a selfie for liveliness verification, e-signature capture, and screening against relevant watchlists. Customers are successfully onboarded only after all verification checks are passed.16.3.3. NEW BEST GOLD shall obtain from all corporate customers the following information: • Incorporated name • Shareholders (To include ‘active’ and ‘silent’ or ‘sleeping’ partners) • Ultimate Beneficial Owners (UBO) (the Beneficial Owner shall be whoever person that ultimately owns or controls, whether directly through a chain of ownership or control or by other means of control such as the right to appoint or dismiss most of its Directors, 25% or more of the shares or 25% or more of the voting rights in the Legal Person)• Managers (That person having day-to-day control of the company, if not a shareholder/partner)• Authorised Signatories• Passport of all shareholders, Ultimate beneficial owners, Managers, and Signatories• National Identity Document of shareholders, UBOs, Managers, Signatories (Emirates ID, if a customer is a resident/citizen of the UAE).• Memorandum and Articles of Association.• Power of Attorney (if applicable).• Proof of physical address of the company• Contact details • Business activities (type and volume)&nbsp;• Source of funds and wealth• Tax registration number of the corporate entity The above list is a summary of the information required. A detailed checklist is attached in Appendix B.16.3.4. As part of the process for identifying and verifying customers, and for authenticating the original documents upon which the verification is based, NEW BEST GOLD will include procedures for the certification of the customer identification and address documentation it obtains. NEW BEST GOLD shall request corporate clients to produce or show the original documents for verification purposes. Such procedures will encompass:• Certification by employees (for example, by including the name, title of position, date, and signature of the verifying employee(s) on the copies of documents maintained on file, along with a statement representing that the copy of the document is a “true copy of the original”) and/or,• third parties (for example, by including the name, organisation, title of position, date, and signature of the verifying person, along with a statement representing that the copy of the document is a “true copy of the original”).• In addition, where a customer has a nominal manager, nominee shareholder, or bearer shareholder, NEW BEST GOLD shall require disclosure of such status and obtain relevant information identifying the nominee, representative, or person acting on behalf of another. Customers shall be required to notify NEW BEST GOLD of any changes to such information within fifteen (15) working days of the change, in line with applicable legal requirements, as a measure to prevent and mitigate the risk of financial crime.If physical verification is not possible, or the customer is not in the UAE, NEW BEST GOLD staff may do the verification of original ID on a secured video platform such as Zoom or Google Meet and store screenshot of evidence of verification.16.3.5. For companies or businesses, in case the original ID documents are not available, a duly authenticated document by the UAE Embassy in the home country of the Company or duly attested documents by a UAE Notary Public in case the Company is in the UAE can be acceptable in place of the original documents. In cases where documents are obtained from foreign sources in countries that are members of the Hague Apostille Convention, NEW BEST GOLD may request documents certified by an Apostille seal.16.3.6. NEW BEST GOLD shall take additional care in dealing with cases where customer verification is done without face-to-face contact with the ultimate client for corporate customers.

CUSTOMER ONBOARDING

17.1. NEW BEST GOLD maintains clear customer acceptance policies and procedures, including a description of the types of customers that are likely to pose a higher risk than average risk. Before accepting a client, KYC and due diligence procedures are followed by examining factors such as the customer’s background, country of origin, public or high-profile position, business activities, or other risk indicators.17.2. In case of retail Business NEW BEST GOLD will carry on Simplified Due Diligence on all Low-risk clients and if in case any retail Business transaction exceeds AED 55,000 (whether as a single transaction or Multiple Transactions) in that case Complete Customer Due Diligence process shall be followed.17.3. KYC is to be carried out according to the mandatory Customer KYC checklist: • Natural Person and Individual Members of Corporate Client KYC Checklist (Refer to Appendix A) • Legal Person (Corporate) KYC Checklist (Refer to Appendix B)17.4. NEW BEST GOLD should be required to conduct the KYC and CDD procedure when:• Establishing a new business relationship.• Carrying out occasional transactions above the applicable designated threshold.• There is suspicion of money laundering or terrorist financing.• If NEW BEST GOLD has doubts about the veracity or adequacy of the previously obtained customer identification data.• It is necessary to obtain additional information from existing customers based on the conduct of the account.• When there are changes to signatories, mandate holders, beneficial owners, and other relevant key personnel. If the customer is unable to comply with these requirements, NEW BEST GOLD should:• Not open the account, commence business relations, or perform the transaction.• Terminate the business relationship.• Consider filing a suspicious-transaction report in relation to the customer.17.5. NEW BEST GOLD is strictly forbidden to do business with shell companies. Shell companies shall mean an institution that has no physical presence in any country, no active business and which merely exists on paper.17.6. An integral part of the KYC process is the carrying out of customer screening and relative risk assessment. Screening ensures that a customer is not listed on the official sanction’s lists issued by the Government and law enforcement agencies. Background checking is designed to identify any adverse information about the past conduct of an individual that may influence their suitability as a customer.17.7. When conducting the KYC process, there shall be no reliance on third-party information or “hearsay”. For applicants introduced to NEW BEST GOLD by a third party, NEW BEST GOLD must carry out and perform all identification, verification, and KYC procedures.17.8. It should be borne in mind that KYC is more than a procedure and is a discipline that is to be developed. For example, KYC should become second nature so that any significant information related to the customer obtained during meetings, telephone discussions, visits, online search, etc., and which is deemed to be relevant for the Policy, should be recorded. Fresh due diligence should be undertaken, especially if it appears that the veracity or accuracy of previous information is doubted.

KYC PROCESS

18.1. A risk-based approach is one of the most effective ways to protect against money laundering and terrorist financing. It is imperative to understand that certain risks associated with various elements of a customer’s profile may be indicative of potential criminal activity. This may include geographical and jurisdictional issues, business and product types, distribution channels, and prevailing transaction types and amounts.18.2. Customers will be reviewed, assessed, and allocated an appropriate level of risk of money laundering, divided into High, Medium, or Low Risk.• High-risk customers will be subject to enhanced levels of due diligence that go beyond the core policies and principles contained in this Policy.• Medium-risk customers will be subject to the core Policies and Procedures contained within this Policy.• Low-risk customers may be subject to certain flexibility within the procedures contained in this policy. However, care should be exercised to ensure that the Company continues to meet its legal obligations.18.3. Although it is generally accepted that failure to provide satisfactory due diligence documentation might be indicative of a money laundering concern, it is also recognised that, due to the geographic diversity of businesses, on occasion, it might prove difficult or impossible to obtain documentation that exactly meets the criteria set out within this Policy.18.4. If the situation mentioned in the Clause above occurs, and there are no reasons to suspect money laundering, the customer documentation should be communicated to senior management together with an explanation detailing the types of issues that arose. Senior management, in consultation with the Compliance Officer, will then review the documentation and consider the risks associated with acceptance of identification evidence that falls outside these procedures, thereafter, providing the personnel with advice and guidance, as appropriate.18.5. The risks considered in the assessment and decision process, and the conclusions reached should be properly documented within the customer KYC file, with appropriate sign-off by the individuals involved. Only Senior Management, in consultation with the Compliance Officer, may determine the High-risk level to be attributed to any customer or/ and approve documentation that does not meet the exact requirements of the Company's anti-money laundering Policy.18.6. All customers are subject to a risk assessment and risk ratings will be recorded in the file. Due diligence requirements must be commensurate with the risk level associated with the customer and enhanced due diligence will be necessary for all higher risk customers.18.7. In addition to trigger-based reviews, NEW BEST GOLD shall conduct periodic reviews of the Customer’s KYC and conduct CDD based on the risk profile of the customer:• High Risk Customers: Every 12 months • Medium Risk Customers: Every 18 months• Low Risk Customers: Every 24 months If there is no transaction with a particular account for 6 months, then the account is marked as Dormant and Re-KYC is performed once the client wants to reinitiate the transaction after 6 months. In relation to customers who did not trigger an alert, NEW BEST GOLD may consider refreshing required information and conducting a simplified due diligence by asking the customer to confirm baseline information on file along with documentary proofs. For customers who triggered an alert, an in-depth assessment of the customer activity may be required.

RISK-BASED APPROACH

19.1. A High-Risk Customer presents a higher-than-normal adverse risk of involvement in money laundering, financing of terrorism, Proliferation Financing or any other matter that the Senior Management or the Compliance Officer considers to be significant.19.2. To mitigate the risks associated with High-Risk Customers, it will be necessary to consider the application of a level of enhanced due diligence for those customers. NEW BEST GOLD’s Senior Management, in consultation with the MLRO, will determine whether the level of risk is acceptable.19.3. Enhanced Due Diligence ("EDD") will need to go beyond the normal requirements applied to the approval and monitoring of customers, as contained within this Policy. As the reasons for designation as high risk will vary from customer to customer, the nature and level of enhancement will need to be determined separately as and when high-risk customers are identified, and procedures will need to explain how the increased risks will be minimised.19.4. Should it be determined that a customer who fulfils the criteria for designation as high risk does not warrant enhanced due diligence, the reasons for the decision and the way the risks are mitigated should still be fully documented and placed in the customer's file.19.5. In addition, any EDD procedures carried out during the approval process, together with proposed procedures for future monitoring, should be fully documented and placed in the customer file.19.6. NEW BEST GOLD shall perform Enhanced Due Diligence in the following scenarios:• Customers from High-risk countries.• Politically Exposed Persons (PEPs) and Close Associates of PEPs.• If the customer/transaction is found to be suspicious/unusual.• Any other suspicious cases are alerted based on the rule violation(s). The above scenarios are reviewed periodically and updated as required through the Quarterly Compliance Officer.

ENHANCED DUE DILIGENCE (EDD)

20.1. A Politically Exposed Person or PEP is a term that is used to describe individuals who are, or have been, entrusted with prominent public positions, who can be susceptible to bribery and corruption. The following list contains examples of persons who may be considered PEPs, although this list should not be viewed as exhaustive:• Current and Ex-Head &amp; Deputy Head of state or National Government (President, Prime Minister, Government Ministers, Provincial Governors, Cabinet Members, their Deputies (assistants), Senior Ministerial staff, and Secretaries.• Current and ex-Members of National and Provincial Assemblies and Senate. • Senior Civil Servants, including Senior Government Officials, Heads of Government Departments, and the Police Service.• Senior Judicial &amp; Military officials• Senior Executives of state-owned Corporations.• High-ranking Officers in Diplomatic Service (Ambassadors, High Commissioners, Envoys, Attachés, Consul Generals, Consuls, Honorary Consuls, Counsellors, etc.)• Senior Political Party Officials and functionaries such as Leader, Chairman, Deputy leader, Secretary General, and Compliance officer or any other Senior ranks in the party (does not include middle-ranking or more junior individuals).• Close family members of PEPs, including spouses, children, parents, siblings, and may also include other blood relatives and relatives by marriage.• Closely associated persons, including close business colleagues and personal Advisors / Consultants to the politically exposed person, as well as persons who are expected to benefit significantly by being close to such a person.20.2. Due to their position and influence, it is recognised that many PEPs are in positions that potentially can be abused to commit money laundering (ML) offences and related predicate offences, including corruption and bribery, as well as conducting activity relating to terrorist financing (TF) or find that their public position has been unknowingly used or is being unknowingly used, for their benefit or benefit of others who may be involved in illegal activities such as corruption, bribery, fraud etc.20.3. Risk is increased considerably when a PEP is located in a high-risk country.20.4. NEW BEST GOLD will ensure that each beneficial owner or controller is not a PEP by performing searches on official databases to screen names against its database or by referring to publicly available information. The results of such verification will be recorded within the customer KYC file.20.5. If a PEP is identified, NEW BEST GOLD will:• Assign a rating of high risk to the customer.• Complete PEP Report, ensuring that the Senior Management approves establishing a business with the customer.• Conduct enhanced due diligence and be vigilant in monitoring the business relationship.• Ensure reasonable measures will be taken to establish the source of wealth/funds.• Track PEP relationships for the purposes of reporting and monitoring.

POLITICALLY EXPOSED PERSONS (PEPs)

21.1. NEW BEST GOLD will take all the required steps to ensure that all customers with whom a business relationship is established are screened against relevant notices such as: • United Nations sanctions (UN)• UAE (Local Terrorist List)• the Office of Foreign Assets Control (OFAC)• Her Majesty’s Treasury Department – UK (HMT)• European Union sanctions (EU)21.2. Screening shall also cover Proliferation Financing (PF) designations in accordance with Federal Decree-Law No. (10) of 2025. NEW BEST GOLD shall identify, assess, and mitigate PF risks arising from clients, suppliers, and transactions. Any suspicion or reasonable grounds to suspect PF activities shall be reported to the UAE Financial Intelligence Unit (FIU) via the goAML portal in the same manner as Money Laundering or Terrorism Financing suspicions.21.3. Any confirmed matches to sanctions lists will result in the decline of a business relationship, and the necessary reports will be made to the Financial Intelligence Unit (FIU).21.4. NEW BEST GOLD shall document and record all the actions that were taken to comply with the sanction’s regime, including PF-related measures, and the rationale for such action. Compliance officer will consider if any further action is required such as freezing of funds.21.5. Targeted Financial Sanctions (TFS) Obligations :a. NEW BEST GOLD is registered on the goAML portal and with the Executive Office for Control and Non-Proliferation (EOCN) to receive official notifications relating to the inclusion or removal of persons and entities from the Targeted Financial Sanctions (TFS) Lists, in compliance with Cabinet Resolution No. (74) of 2020.b. NEW BEST GOLD ensures ongoing compliance with TFS requirements by subscribing to sanctions updates issued by the EOCN through its official website. The Compliance Officer shall maintain the subscription using the Company’s official email address.c. Upon any update issued by the EOCN (including additions to or removals from the Local Terrorist List), notifications shall be received by the subscribed email address.d. Upon receipt of an EOCN notification, the Compliance Officer shall, without delay:• Screen all existing customers and beneficial owners against the updated sanctions list;• Conduct screening using automated and/or manual screening methods, as appropriate; and• Maintain a sanctions screening log recording the date of screening, results, and any action taken.e. Reporting to EOCN :If a positive or potential match is identified, the Compliance Officer shall:• Report the match to the EOCN using the prescribed TFS Reporting Form available on the EOCN website;• Submit the report within 24 hours of identification; and• Comply with all instructions issued by the competent authority, including freezing of funds or other measures, where applicable.f. Where no match or relationship is identified, a “No Match / No Relationship” response shall nevertheless be submitted via the prescribed EOCN reporting form.g. Any confirmed match to a sanctions list shall result in the decline or termination of the business relationship, and the necessary reports shall be submitted to the Financial Intelligence Unit (FIU) in accordance with applicable laws and regulations.h. NEW BEST GOLD shall document and retain records of all actions taken to comply with the sanctions regime, including TFS-related measures and the rationale for such actions. Senior Management shall consider whether any further action is required, including the freezing of funds or assets.

TARGETED FINANCIAL SANCTIONS (TFS)

22.1. KYC is an ongoing process. The foundation of any customer due diligence and monitoring procedures lies in the initial collection of KYC information and the ongoing updating of that information. 22.2. NEW BEST GOLD will take reasonable steps to ensure that KYC information and documents are updated as and when required. 22.3. As a minimum standard, KYC information must be updated ongoing for business relationships.

UPDATING KYC INFORMATION

23.1. With regard to established Business Relationships, NEW BEST GOLD is required to undertake ongoing supervision of customers’ activity, including auditing transactions executed throughout the course of the relationship to ensure that they are consistent with the information, types of activity, and risk profiles of the customers. 23.2. In the case of customers or Business Relationships identified as high risk, NEW BEST GOLD will investigate and obtain more information regarding the purpose of transactions that are to be conducted; and enhance ongoing monitoring and review of transactions to identify potentially unusual or suspicious activities. Ongoing Monitoring is performed by using the software known as LSEG World Check Software. 23.3. In keeping with the level of risk involved, NEW BEST GOLD will evaluate the specifics of the transactions examined concerning to the customer’s due diligence information or profile, and obtain sufficient information on the counterparties and/or other parties involved (including but not limited to information from public sources, such as internet searches), to determine whether the transactions appear to be: • Normal (that is, the transactions are typical for the customer, for the other parties involved, and for similar types of customers). • Reasonable (that is, whether the transactions have a clear rationale and are compatible with the types of activities that the customer and the counterparties are usually engaged in). • Legitimate (that is, whether the customer and the counterparties are permitted to engage in such transactions, such as when specific licenses, permits, or official authorisations are required).

MONITORING OF CLIENT’S ACTIVITIES

24.1. Methods which criminals utilise to conduct money laundering, financing of terrorism and financing of proliferation financing are constantly evolving, and as such, in many cases, there exist particularities within a given market or given type of trust and company service that may be beyond the scope of red flags identified within this Policy. Therefore, the following list of red-flag indicators of potentially suspicious transactions should by no means be treated as exhaustive. It is noted that the presence of one or more of the indicators below does not necessarily mean that a transaction involves ML/FT. However, it is an indication that enhanced due diligence, or further investigation may be required, so that an appropriate determination can be made by NEW BEST GOLD’ appointed Compliance Officer as to whether the transaction can be deemed suspicious or not.24.2. A red flag should be raised with respect to trade practices in the following circumstances:• Precious metals/stones originate from a country where there is limited production or no mines at all.• Trade in large volumes conducted with countries that are not part of a specific precious metals and stones pipeline.• An increase in the volume of the activity in a DPMS account despite a significant decrease in the industry-wide volume.• Selling or buying precious metals and stones between two local companies through an intermediary located abroad (lack of business justification, uncertainty as to actual passage of goods between the companies).• Volume of purchases and/or imports that grossly exceed the expected sales amount.• A single bank account is used by multiple businesses.24.3. A red flag should be raised with respect to the Business Relationship, or the Customer in the following circumstances if the customer:• Suddenly cancels the transaction when asked for identification or information.• Is reluctant or refuses to provide personal information, NEW BEST GOLD has reasonable doubt that the provided information is correct or sufficient.• Is reluctant, unable, or refuses to explain:▪ their business activities and corporate history▪ the identity of the beneficial owner▪ their source of wealth/funds▪ why are they conducting their activities in a certain manner▪ who they are transacting with▪ the nature of their business dealings with third parties (particularly third parties located in foreign jurisdictions).• Is under investigation, has known connections with criminals, has a history of criminal indictments or convictions, or is the subject of adverse information (such as allegations of corruption or criminal activity) in reliable publicly available information sources.• Is a designated person or organisation (i.e., is on a Sanctions List). • Is related to, or a known associate of, a person listed as being involved or suspected of involvement with terrorists or terrorist financing operations.• Insists on the use of an intermediary (either professional or informal) in all interactions, without sufficient justification.• Actively avoids personal contact without sufficient justification.• Is a politically exposed person or has familial or professional associations with a person who is politically exposed.• Is a foreign national with no significant dealings in the country, and no clear economic or other rationale for doing business with NEW BEST GOLD.• Is located a significant geographic distance away from NEW BEST GOLD, with no logical rationale.• Refuses to co-operate or provide information, data, and documents usually required to facilitate a transaction, or is unfamiliar with the details of the requested transaction.• Makes unusual requests (including those related to secrecy) of the NEW BEST GOLD or its employees.• Is prepared to pay substantially higher fees than usual, without a legitimate reason.• Appears very concerned about or asks an unusual number of detailed questions about compliance-related matters, such as customer due diligence or transaction reporting requirements.• Is conducting a transaction that appears incompatible with their socio-economic, educational, or professional profile, or about which they appear not to have a good understanding.• Uses legal persons, legal arrangements, or foreign private foundations that operate in jurisdictions with secrecy laws.• Requests services (for example, smelting and reshaping of gold into ordinary-looking items) that could improperly disguise the nature of the PMS or conceal beneficial ownership from competent authorities, without any clear legitimate purpose.• Claims to be a legitimate DPMS but cannot demonstrate a history or provide evidence of real activity.• Is a business that cannot be found on the internet or social business network platforms (such as LinkedIn or others).• Is registered under a name that does not indicate that the activity of the company is related to PMS, or• that indicates activities different from those it claims to perform. • Is a business that uses an email address with a public or non-professional domain (such as Hotmail, Gmail, Yahoo, etc.).• Is registered at an address that does not match the profile of the company, or that cannot be located on internet mapping services (such as Google Maps).• Is registered at an address that is also listed against numerous other companies or legal arrangements, indicating the use of a mailbox service.• Has directors or controlling shareholder(s) who cannot be located or contacted, or who do not appear to have an active role in the company, or where there is no evidence that they have authorised the transaction.• Is incorporated or established in a jurisdiction that is considered to pose a high money laundering, terrorism financing, or corruption risk.• Has a complex corporate structure that does not appear to be necessary or that does not make commercial sense.• Appears to be acting according to instructions of unknown or inappropriate person(s).• Conducts an unusual number or frequency of transactions in a relatively short time period. • Asks for shortcuts, excessively quick transactions, or complicated structures even when it poses an unnecessary business risk or expense.• Requests payment arrangements that appear to be unusually or unnecessarily complex or confusing (for example, unusual deposit or installment arrangements, or payment in several different forms), or which involve third parties.• Provides identification, records, or documentation that appear to be falsified or forged.• Requires that transactions be processed exclusively or mainly through the use of cash, cash equivalents (such as cashier’s cheques, gold certificates, bearer bonds, negotiable third-party promissory notes, or other such payment methods), or through virtual currencies, to preserve their anonymity, without adequate and reasonable explanation.24.4. A red flag should be raised with respect to the transaction if it:• Involves the use of a large sum of cash, without an adequate explanation as to its source or Page | 36 purpose.• Involves the frequent trading of PMS (especially gold) or jewellery for cash in small incremental amounts.• Involves the barter or exchange of PMS (especially gold) or jewellery for other high-end jewellery.• Appears structured to avoid the cash reporting threshold.• Involves delivery instructions that appear to be unnecessarily complex or confusing, or which involve foreign jurisdictions with no apparent legitimate connection to the counterparty or customer.• Includes contractual agreements with terms that are unusual or that do not make business sense for the parties involved.• Involve payments to/from third parties that do not appear to have a logical connection to the transaction.• Involves merchandise purchased with cash, which the customer then requests the merchant to sell for him/her on consignment.• Involves PMS with characteristics that are unusual or do not conform to market standards. • Involves the unexplained use of powers-of-attorney or similar arrangements to transact business on behalf of a third party.• Appears to be directed by someone (other than a formal legal representative) who is not a formal party to the transaction.• Involves a person acting in the capacity of a director, signatory, or other authorised representative, who does not appear to have the required competency or suitability.• Involves persons residing in tax havens or High-Risk Countries when the characteristics of the transactions match any of those included in the list of indicators.• Is carried out on behalf of minors, incapacitated persons, or other categories of persons who appear to lack the mental or economic capacity to make such decisions.• Involves several successive transactions which appear to be linked, or which involve the same parties or those persons who may have links to one another (for example, family ties, business ties, persons of the same nationality, persons sharing an address or having the same representatives or attorneys).• Involves recently created legal persons or arrangements, when the amount is large compared to the assets of those legal entities.• Involves foundations, cultural or leisure associations, or non-profit-making entities in general, especially when the nature of the merchandise or the characteristics of the transaction do not match the goals of the entity.• Involves legal persons that, although incorporated in the country, are mainly owned by foreign nationals, who may or may not be resident for tax purposes.• Involves unexplained last-minute changes involving the identity of the parties (e.g., it is begun in one individual's name and completed in another's without a logical explanation for the name change) and/or the details of the transaction.• Involves a price that appears excessively high or low in relation to the value (book or market) of the goods, without a logical explanation.• Involves circumstances in which the parties: • Do not show particular interest in the details of the transaction;• Do not seem particularly interested in obtaining a better price for the transaction;• Insist on an unusually quick completion, without a reasonable explanation.• Takes place through intermediaries who are foreign nationals or individuals who are tax non residents.• Involves unusually high levels of assets or unusually large transactions compared to what might reasonably be expected of clients with a similar profile.• Involves indications that the counterparty does not have or does not wish to obtain necessary governmental approvals, filings, licenses, or other official requirements.• Involves any attempt by a physical person or the controlling persons of a legal entity or legal arrangement to engage in a fraudulent transaction (including but not limited to over- or under invoicing of goods or services, multiple invoicing of the same goods or services, fraudulent invoicing for non-existent goods or services; over- or under- shipments (e.g. false entries on bills of lading); or multiple trading of the same goods and services).24.5. A red flag indicator for means of payment:• Involves cash, cash equivalents (such as cashier’s cheques, gold certificates, bearer bonds, negotiable third-party promissory notes, or similar instruments), negotiable bearer instruments, or virtual currencies, which do not state the true payer, especially where the amount of such instruments is significant in relation to the total value of the transaction, or where the payment instrument is used in a non-standard manner.• Involves unusual deposits (e.g., use of cash or negotiable instruments, such as traveller’s cheques,• Cashier’s cheques and money orders in round denominations (to keep below the reporting threshold limit) to pay for PMS. The negotiable instruments may be sequentially numbered or purchased at multiple locations and may frequently lack payee information.• Is divided into smaller parts or instalments with a short interval between them.• Involves doubts as to the validity of the documents submitted in connection with the transaction.• Involves third-party payments with no apparent connection or legitimate explanation.• Cannot be reasonably identified with a legitimate source of funds.

INDICATORS OF SUSPICIOUS ACTIVITIES – RED FLAGS

25.1. NEW BEST GOLD shall institute a system for mandatory reporting of suspicious transactions pursuant to the UAE AML/CFT/CPF legislative and regulatory framework. Any suspicious activities/transactions (SARs/STRs) or additional information required in relation to them shall be reported to the FIU through the GOAML system. The same shall be filed within 5 working days after becoming aware of the suspicious transaction. 25.2. All transactions conducted on NEW BEST GOLD’s E-Commerce Digital platform, including buy, sell, are subject to real-time monitoring to detect unusual patterns, structuring, or potentially suspicious activity. 25.3. Where any employee or personnel, director, or officer of NEW BEST GOLD knows that the client has engaged in any of the predicate crimes, the matter must be promptly reported to the Head of Compliance. 25.4. The MLRO will review the matter and if sufficient evidence is available, then the matter will be escalated to the Senior Management to review and decide whether the matter needs to be reported to the FIU as Suspicious Activity. 25.5. If there are reasonable grounds to suspect that the customer has engaged in an unlawful activity, the Compliance Officer, on receiving such a report, must promptly evaluate whether there are reasonable grounds for such belief and then immediately report the case to the FIU, and records an opinion, that such reasonable grounds do not exist. 25.6. NEW BEST GOLD shall maintain a register of all suspicious transactions that have been brought to the attention of its Compliance Officer, including transactions that are not reported to the FIU. The register shall contain details of the date on which the report is made, the person who made the report to the Compliance Officer, and information sufficient to identify the relevant papers related to said reports. 25.7. NEW BEST GOLD acknowledges that failure to report a suspicious transaction, whether intentionally or by gross negligence, is a federal crime. Any person who fails to perform their statutory obligation to report a suspicion of money laundering, or the financing of terrorism or proliferation financing, is liable to a fine and/or imprisonment or both.

REPORTING OF SUSPICIOUS ACTIVITIES

26.1. Funds Freeze Report (FFR)• Reporting entities are supposed to file the Funds Freeze Report to report any freezing measure, prohibition to provide funds or services, and any attempted transactions related to confirmed matches. This report is raised when the reporting entity finds a full match of the customer's name with a name listed in the UAE LOCAL LIST or UN CONSOLIDATED LIST.26.2. Partial Name Match Report (PNMR)• This report is raised when the reporting entity cannot verify if the name of the customer is a full match to the name of a sanctioned person listed in the UAE LOCAL LIST or UN CONSOLIDATED LIST.26.3. Suspicious Transaction/Activity Reporting (STR/SAR)• Transactions that do not match the customer profile, high volumes of transactions being made in a short period, payment of high amounts by cash, cannot provide identification documents and source of funds; these are some examples of suspicious activities/transactions.• If, during the establishment or course of the customer relationship, or when conducting transactions on behalf of a customer or a potential customer, a reporting entity suspects transactions or attempted transactions related to money laundering, fraud or terrorist financing, then the entity should submit an STR/SAR to the FIU at the earliest.• File STR/SAR if a full/partial match of the customer’s name is found on other international sanctions lists (e.g., OFAC, UKHMT, EU, etc.)• If a reporting entity suspects or has reasonable grounds to suspect that funds/activity are the proceeds of a criminal activity, or are related to terrorist financing, it shall, as soon as possible but no later than 5 days, report promptly its suspicions to the Financial Intelligence Unit (FIU). 26.4. High-Risk Countries Report / Activity (HRC/HRCA)• The obligation for reporting, as well as putting on hold, is for cross-border transactions through banking or remittance channels. These transactions may include transactions destined to, originated from, or being routed through jurisdictions that are classified as a ‘High-Risk Jurisdiction subject to a Call for Action’ by FATF. Currently, this includes the Democratic People's Republic of Korea, Iran, and Myanmar.• Such reported transaction(s) may only be executed three working days after reporting such to the FIU, and if the FIU does not object to conducting the transaction within the set period.26.5. Dealers in Precious Metals &amp; Stones Report (DPMSR)• Dealers in Precious Metals and Precious Stones (DPMS) are identified under UAE law as Designated Non-Financial Business and Professions (DNFBPs) when they carry out a single transaction or several transactions, interrelated in appearance, whose value is equal to or greater than AED 55,000. • All cash transactions and international wire transfer Transactions with individuals/entities (B2C/B2B) equal or exceeding AED 55,000 need to be reported in DPMSR. Obtain and verify identification documents (ID or Passport) that need to be reported in DPMSR.

TYPES OF REPORTING ON GOAML PORTAL

27.1. Tipping off a customer is an unauthorised act of disclosing information that: • may result in the customer, or a third party (other than FIU) knowing or suspecting that the customer is or may be the subject of:&nbsp; &nbsp; &nbsp; ▪ a suspicious transaction report; or &nbsp; &nbsp; &nbsp; ▪ an investigation relating to money laundering or terrorist financing; and • may prejudice the prevention or detection of offences, the apprehension or prosecution of offenders, the recovery of proceeds of crime, or the prevention of money laundering or terrorist financing.27.2. NEW BEST GOLD directors, officers, and employees shall not warn customers that information relating to them has been or is in the process of being reported to the FIU, or communicate, directly or indirectly, such information to any person other than the FIU. Any violation of this confidentiality provision shall render them liable for criminal, civil, and administrative sanctions under the UAE AML/CFT/CPF law.

TIPPING OFF AND CONFIDENTIALITY

28.1. NEW BEST GOLD shall provide education and training to all its staff and personnel, including directors and officers, to ensure that they are fully aware of their obligations and responsibilities in combatting money laundering and financing of terrorism and proliferation financing, and so that they are familiar the system in place for reporting and investigating suspicious matters. 28.2. NEW BEST GOLD may, due to the scale and nature of its operations, look to appoint an independent Internal Auditor or Trainer who has relevant experience and expertise in the field of AML/CFT/CPF. 28.3. NEW BEST GOLD shall, at least once a year, conduct refresher training to remind key staff and officers of their AML/CFT/CPF responsibilities and to make them aware of any changes in the laws, national and international, and rules relating to AML/CFT/CPF. 28.4. New employees will receive appropriate training within 30 days of their hire date. Training for all employees must include not only the legal elements of AML/CFT/CPF laws and regulations but should also cover job-specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations. 28.5. To ensure the continued adherence to NEW BEST GOLD’ AML/CFT/CPF and KYC policies and procedures, all employees are required to confirm their awareness of the contents of this Compliance Policy by signing the acknowledgment form annually, or more frequently. 28.6. Completion of AML/CFT/CPF training sessions by all employees, including details such as date of training, type of training (initial, refresher, job-specific), trainer's name, and mode of delivery (in person, online, etc.). 28.7. Receipt of signed AML/CFT/CPF acknowledgment forms from employees confirming their understanding and adherence to the AML/CFT/CPF and KYC policies. 28.8. Training programs shall cover the new obligations introduced under Federal Decree-Law No. (10) of 2025, including Proliferation Financing (PF) risk awareness, governance responsibilities of senior management, and compliance requirements related to Virtual Assets and Virtual Asset Service Providers (VASPs). The Compliance Team shall review training content annually to ensure alignment with the latest Financial Intelligence Unit (FIU) and Ministry of Economy (MoE) guidance and circulars.

TRAINING AND AWARENESS

29.1. The following documents shall be considered as NEW BEST GOLD’s AML/CFT/CPF Documents:● All clients’ documentation as provided in the KYC checklist and/or correspondences, including the documents obtained during CDD and/or EDD.● All documentation concerning a suspicious activity report concerning a client or applicant, together with any response or follow-up.● Records of AML/CFT/CPF training sessions attended by NEW BEST GOLD’s staff, officers, and their affiliates, the dates, content, and attendees.● Records of all AML/CFT/CPF decisions taken by the senior management.● All records, documents, and data for all financial, cash, and local or international commercial transactions and deals.● Relevant CCTV recordings.29.2. The objective of keeping said records is to ensure that NEW BEST GOLD can provide the basic information for the reconstruction or arrangement of individual transactions, facilitate data analysis, enable the tracing of financial transactions, and, where appropriate, provide evidence for prosecution against criminal activity.29.3. Documents may be retained as originals or copies, or as scanned images onto pen drives, hard discs, online systems, cloud-based systems, etc., provided that such forms are admissible in the UAE Court of Law. 29.4. NEW BEST GOLD shall designate at least two (2) persons responsible for the safekeeping of records.29.5. All records must be available for prompt and swift access by the relevant authorities when required. The request for such records by government authorities may be fulfilled within a reasonable time frame, not to exceed fifteen (15) business days.

RECORD KEEPING

30.1. The following document retention periods shall be followed: • The Company will keep all customer-related records for at least five (5) years. This includes documents collected during Customer Due Diligence (CDD), monitoring records, account files, emails or communications with the customer, copies of ID documents, any suspicious transaction reports (STRs), internal analysis, relevant CCTV recording, and any other information related to AML/CFT/CPF compliance. • The five-year period will be counted from the latest relevant event such as when the customer relationship ends, an account is closed, a one-off transaction is completed, a regulatory inspection or investigation finishes, or a final court judgment is issued. • If the records relate to ongoing investigations or transactions that have been the subject of a disclosure, they shall be retained beyond the stipulated retention period until it is confirmed by the FIU that the case has been closed.

RECORD RETENTION POLICY

AML Policy

Best Gold operates a digital gold trading platform that enables eligible users to purchase and sell gold through the Company’s mobile application, in accordance with these Terms and Conditions and applicable laws and regulations of the United Arab Emirates. Through the Services, users may place orders to buy or sell gold at prices linked to prevailing market rates, subject to order acceptance, execution timing, pricing mechanisms, and settlement procedures as described in these Terms and Conditions. The Company facilitates transactions relating to gold and does not provide investment advice, portfolio management services, or financial advisory services. Any information made available through the Services is provided for general informational purposes only. The Company may, from time to time and where permitted by law, introduce, modify, suspend, or discontinue any aspect of the Services, including supported transaction types, operational processes, or technical features. All use of the Services is subject to applicable eligibility requirements, identity verification and compliance checks, transaction limits, pricing rules, settlement procedures, and any other conditions communicated through the Services or set out in these Terms and Conditions. The Services are made available solely for use in jurisdictions where such use is lawful. The information provided through the Services is not intended for distribution to, or use by, any person or entity in any jurisdiction where such distribution or use would be contrary to applicable law or would subject the Company to any registration, licensing, or regulatory requirement. Any person who accesses the Services from outside the United Arab Emirates does so on their own initiative and is solely responsible for ensuring compliance with all applicable local laws and regulations.

OUR SERVICES

Our Intellectual PropertyAll intellectual property rights in and to the Services are owned by, or licensed to, the Company. This includes, without limitation, all software, source code, databases, platform functionality, website and application designs, user interfaces, text, images, graphics, logos, trademarks, service marks, and other content made available through the Services (collectively, the “Content” and the “Marks”).The Content and Marks are protected by applicable intellectual property laws, including copyright and trademark laws, and remain the exclusive property of the Company or its licensors.The Content and Marks are made available solely for your personal and non-commercial use in connection with your lawful use of the Services.Limited Licence to Use the ServicesSubject to your compliance with these Terms and Conditions, including the Prohibited Activities section, the Company grants you a limited, non-exclusive, non-transferable, and revocable licence to:<ul><li>access and use the Services; and</li><li>download or print portions of the Content to which you have lawfully obtained access,</li></ul>solely for your personal, non-commercial use.Except as expressly permitted under these Terms and Conditions, you may not copy, reproduce, modify, distribute, transmit, display, sell, license, create derivative works from, or otherwise exploit any part of the Services, Content, or Marks for any commercial purpose without the Company’s prior written consent.All rights not expressly granted to you are reserved by the Company.Any unauthorised use of the Services, Content, or Marks shall constitute a material breach of these Terms and Conditions and may result in the immediate suspension or termination of your access to the Services.User SubmissionsIf you submit any questions, feedback, suggestions, ideas, or other information relating to the Services (“Submissions”), you acknowledge and agree that all intellectual property rights in such Submissions shall vest in the Company.The Company may use, reproduce, disclose, and exploit such Submissions for any lawful purpose, whether commercial or otherwise, without compensation or acknowledgment to you.By submitting any Submissions, you represent and warrant that:<ul><li>your Submissions are lawful and do not infringe the rights of any third party;</li><li>you have the necessary rights and authority to submit the Submissions;</li><li>your Submissions do not contain confidential or proprietary information belonging to any third party;</li><li>your Submissions comply with these Terms and Conditions and all applicable laws.</li></ul>You remain solely responsible for your Submissions and agree to indemnify the Company against any losses arising from a breach of this section, infringement of third-party rights, or violation of applicable law.

INTELLECTUAL PROPERTY RIGHTS

By using the Services, you represent and warrant that: (1) all registration information you submit will be true, accurate, current, and complete; (2) you will maintain the accuracy of such information and promptly update such registration information as necessary; (3) you have the legal capacity and you agree to comply with these Legal Terms; (4) you are not a minor in the jurisdiction in which you reside; (5) you will not access the Services through automated or non-human means, whether through a bot, script or otherwise; (6) you will not use the Services for any illegal or unauthorised purpose; and (7) your use of the Services will not violate any applicable law or regulation.If you provide any information that is untrue, inaccurate, not current, or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of the Services (or any portion thereof). Use of the Services is subject to the Company’s compliance policies, including its Anti-Money Laundering and Counter-Terrorist Financing Policy, sanctions obligations, and any regulatory requirements applicable under UAE law, as updated from time to time.

USER REPRESENTATIONS

You are required to register to use the Services. You agree to keep your password confidential and will be responsible for all use of your account and password. We reserve the right to remove, reclaim, or change a username you select if we determine, in our sole discretion, that such username is inappropriate, obscene, or otherwise objectionable.

USER REGISTRATION

We make every effort to display as accurately as possible the colours, features, specifications, and details of the products available on the Services. However, we do not guarantee that the colours, features, specifications, and details of the products will be accurate, complete, reliable, current, or free of other errors, and your electronic display may not accurately reflect the actual colours and details of the products. All products are subject to availability, and we cannot guarantee that items will be in stock. We reserve the right to discontinue any products at any time for any reason. Prices for all products are subject to change.

PRODUCTS

We accept the following forms of payment:<ul><li>Visa</li><li>Mastercard</li><li>Bank Transfer</li></ul>You agree to provide current, complete, and accurate purchase and account information for all purchases made via the Services. You further agree to promptly update account and payment information, including email address, payment method, and payment card expiration date, so that we can complete your transactions and contact you as needed.Necessary tax will be added to the price of purchases as deemed required by us. All payments shall be in AED.You agree to pay all charges at the prices then in effect for your purchases and any applicable shipping fees, and you authorise us to charge your chosen payment provider for any such amounts upon placing your order. We reserve the right to correct any errors or mistakes in pricing, even if we have already requested or received payment.We reserve the right to refuse any order placed through the Services. We may, in our sole discretion, limit or cancel quantities purchased per person, or per order. These restrictions may include orders placed by or under the same customer account, the same payment method, and/or orders that use the same billing or shipping address.We reserve the right to limit or prohibit orders that, in our sole judgement, appear to be placed by dealers, resellers, or distributors.

PURCHASES AND PAYMENT

All sales are final, and no refund will be issued.

RETURN/REFUNDS POLICY

The Services are accessed through the Best Gold mobile application and related software components (collectively, the “App”), which are provided to enable users to access and use the Services in accordance with these Terms and Conditions.Subject to your compliance with these Terms and Conditions, the Company grants you a limited, non-exclusive, revocable, non-transferable, and personal licence to download, install, and use the App on a device owned or controlled by you, solely for your personal and lawful use of the Services.You may not copy, modify, distribute, sublicense, reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of the App, except to the extent expressly permitted by applicable law.The App and all related software and documentation are provided on an “AS IS” and “AS AVAILABLE” basis, without warranties of any kind, whether express or implied, including without limitation warranties of merchantability, fitness for a particular purpose, or non-infringement. The Company does not warrant that the App will be error-free, uninterrupted, or compatible with all devices or operating systems.You acknowledge and agree that your use of the App is at your own risk and that the Company shall not be responsible for any loss or damage arising from the installation, use, performance, or inability to use the App, except as required under applicable law.Where the App is downloaded from a third-party platform or app store, your use of the App may also be subject to the terms and conditions of the relevant platform provider.

SOFTWARE

You may access and use the Services solely for the purposes for which they are made available. You must not use the Services for any unlawful, unauthorised, or abusive purpose, or in any manner that could damage, disable, overburden, or impair the Services or the Company’s operations.Without limitation, you agree that you will not:<ul><li>Use the Services in violation of any applicable law, regulation, or regulatory requirement.</li><li>Engage in any fraudulent, deceptive, or misleading activity, including impersonation of any person or entity or misrepresentation of identity or intent.</li><li>Attempt to gain unauthorised access to any account, system, network, or data associated with the Services.</li><li>Interfere with, disrupt, or attempt to interfere with the security, integrity, performance, or availability of the Services, including through the introduction of malware, viruses, or other harmful code.</li><li>Use any automated means, including scripts, bots, scrapers, data-mining tools, or similar technologies, to access, monitor, or interact with the Services without the Company’s prior written consent.</li><li>Copy, modify, reproduce, distribute, reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of the App or any part of the Services, except to the extent permitted by applicable law.</li><li>Collect, harvest, or extract data, content, or information from the Services for any commercial purpose without authorisation.</li><li>Use the Services in connection with any unauthorised commercial activity or in a manner intended to compete with or undermine the Company.</li><li>Harass, abuse, threaten, or intimidate any other user, or any employee, agent, or representative of the Company.</li><li>Misuse customer support channels or submit false, misleading, or abusive reports or complaints.</li></ul>In addition, given the nature of the Services as a digital gold trading platform, you must not:<ul><li>Attempt to manipulate, exploit, or interfere with pricing, order placement, execution, settlement, or valuation mechanisms of the Services.</li><li>Engage in behaviour intended to circumvent or bypass transaction limits, pricing controls, execution safeguards, or internal risk management systems.</li><li>Use the Services to facilitate or attempt to facilitate fraud, money laundering, terrorist financing, sanctions evasion, or any other prohibited financial activity.</li><li>Use multiple accounts or other means to evade compliance checks, identity verification requirements, or regulatory controls.</li><li>Engage in abusive, excessive, or automated trading behaviour that may adversely affect platform integrity or market stability.</li></ul>Any breach of this section may result in the suspension or termination of your access to the Services, cancellation of transactions, and any other action permitted under these Terms and Conditions or applicable law.

PROHIBITED ACTIVITIES

The Services do not currently enable users to publicly post, publish, or share content with other users. However, you may, from time to time, submit information to the Company in connection with your use of the Services, including feedback, inquiries, support requests, suggestions, or other communications (“Submissions”).By submitting any Submissions, you acknowledge and agree that:<ul><li>Your Submissions do not infringe the intellectual property rights, privacy rights, or other legal rights of any third party.</li><li>Your Submissions are accurate to the best of your knowledge and are not false, misleading, or unlawful.</li><li>Your Submissions do not contain confidential information belonging to any third party.</li></ul>You grant the Company a worldwide, irrevocable, royalty-free right to use, reproduce, store, and process your Submissions for the purpose of operating, improving, and supporting the Services, without compensation to you.You remain solely responsible for the content of your Submissions, and you agree that the Company shall not be liable for any claims arising from or related to your Submissions.The Company reserves the right to review, remove, or disregard any Submissions that violate these Terms and Conditions or applicable law.

USER GENERATED CONTRIBUTIONS

Use Licence If you access the Services via the App, we grant you a revocable, non-exclusive, non-transferable, limited right to install and use the App on wireless electronic devices owned or controlled by you, and to access and use the App on such devices strictly in accordance with the terms and conditions of this mobile application licence contained in these Legal Terms.You shall not:<ol><li>Except as permitted by applicable law, decompile, reverse engineer, disassemble, attempt to derive the source code of, or decrypt the App.</li><li>Make any modification, adaptation, improvement, enhancement, translation, or derivative work from the App.</li><li>Violate any applicable laws, rules, or regulations in connection with your access or use of the App.</li><li>Remove, alter, or obscure any proprietary notice (including any notice of copyright or trademark) posted by us or the licensors of the App.</li><li>Use the App for any revenue-generating endeavour, commercial enterprise, or other purpose for which it is not designed or intended.</li><li>Make the App available over a network or other environment permitting access or use by multiple devices or users at the same time.</li><li>Use the App for creating a product, service, or software that is, directly or indirectly, competitive with or in any way a substitute for the App.</li><li>Use the App to send automated queries to any website or to send any unsolicited commercial email.</li><li>Use any proprietary information or any of our interfaces or other intellectual property in the design, development, manufacture, licensing, or distribution of any applications, accessories, or devices for use with the App.</li></ol>Apple and Android Devices The following terms apply when you use the App obtained from either the Apple Store or Google Play (each an 'App Distributor') to access the Services:<ol><li>The licence granted to you for our App is limited to a non-transferable licence to use the application on a device that utilises the Apple iOS or Android operating systems, as applicable, and in accordance with the usage rules set forth in the applicable App Distributor’s terms of service.</li><li>We are responsible for providing any maintenance and support services with respect to the App as specified in the terms and conditions of this mobile application licence contained in these Legal Terms or as otherwise required under applicable law. You acknowledge that each App Distributor has no obligation whatsoever to furnish any maintenance or support services with respect to the App.</li><li>In the event of any failure of the App to conform to any applicable warranty, you may notify the applicable App Distributor, and the App Distributor, in accordance with its terms and policies, may refund the purchase price, if any, paid for the App. To the maximum extent permitted by applicable law, the App Distributor will have no other warranty obligation whatsoever with respect to the App.</li><li>You represent and warrant that you are not located in, organised under the laws of, or acting on behalf of any country, territory, entity, or individual that is subject to applicable sanctions, restrictions, or prohibitions under the laws and regulations of the United Arab Emirates or any other applicable jurisdiction.</li><li>You acknowledge and agree that the App Distributors are third-party beneficiaries of the terms and conditions in this mobile application licence contained in these Legal Terms, and that each App Distributor will have the right (and will be deemed to have accepted the right) to enforce these terms against you as a third-party beneficiary.</li></ol>

MOBILE APPLICATION LICENCE

We reserve the right, but not the obligation, to:<ol><li>Monitor the Services for violations of these Legal Terms.</li><li>Take appropriate legal action against anyone who, in our sole discretion, violates the law or these Legal Terms, including reporting such user to law enforcement authorities.</li><li>Refuse, restrict access to, limit the availability of, or disable (to the extent technologically feasible) any of your Contributions or any portion thereof.</li><li>Remove from the Services or otherwise disable all files and content that are excessive in size or are in any way burdensome to our systems, without limitation, notice, or liability.</li><li>Manage the Services in a manner designed to protect our rights and property and to facilitate the proper functioning of the Services.</li></ol>Without terminating a user’s account, the Company may temporarily restrict or freeze account activity, balances, or withdrawals where necessary to conduct compliance reviews or to meet legal or regulatory obligations.

SERVICES MANAGEMENT

We care about data privacy and security. By using the Services, you agree to be bound by our Privacy Policy, which is incorporated into these Legal Terms. Please be advised the Services are hosted in the United Arab Emirates. If you access the Services from any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United Arab Emirates, then through your continued use of the Services, you are transferring your data to the United Arab Emirates, and you expressly consent to have your data transferred to and processed in the United Arab Emirates.

PRIVACY POLICY

These Legal Terms shall remain in full force and effect while you use the Services.WITHOUT LIMITING ANY OTHER PROVISION OF THESE LEGAL TERMS, we reserve the right, in our sole discretion and without notice or liability, to deny access to and use of the Services (including blocking certain IP addresses), to any person for any reason or for no reason, including without limitation for breach of any representation, warranty, or covenant contained in these Legal Terms or of any applicable law or regulation.We may terminate your use or participation in the Services or delete your account and any content or information that you posted at any time, without warning, in our sole discretion.If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party.In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.

TERM AND TERMINATION

We may change, update, suspend, discontinue, or otherwise modify the Services (in whole or in part) at any time and for any reason, without prior notice.We do not guarantee continuous availability of the Services, and there may be times where access is delayed, limited, interrupted, or unavailable due to maintenance, system updates, technical issues, network outages, or other operational or commercial reasons.You agree that we shall not be liable to you for any loss, damage, or inconvenience resulting from any interruption, modification, suspension, discontinuation, or unavailability of the Services at any time.Nothing in these Legal Terms obligates us to maintain, support, or deliver updates or new releases.

MODIFICATIONS AND INTERRUPTIONS

These Legal Terms shall be governed by and construed in accordance with the laws of the United Arab Emirates. NEW BEST GOLD JEWELLERY TRADINGS L.L.C and yourself irrevocably consent that the courts of Dubai, United Arab Emirates shall have exclusive jurisdiction to resolve any dispute which may arise in connection with these Legal Terms.

GOVERNING LAW

These Terms and Conditions, and any dispute or claim arising out of or in connection with them or their subject matter, shall be governed by and construed in accordance with the laws of the United Arab Emirates.The courts of the United Arab Emirates shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms and Conditions or your use of the Services.

DISPUTE RESOLUTION

There may be information on the Services that contains typographical errors, inaccuracies, or omissions, including descriptions, pricing, availability, and various other information.We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information on the Services at any time, without prior notice.

CORRECTIONS

THE SERVICES ARE PROVIDED ON AN AS-IS AND AS-AVAILABLE BASIS. YOU AGREE THAT YOUR USE OF THE SERVICES WILL BE AT YOUR SOLE RISK. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, IN CONNECTION WITH THE SERVICES AND YOUR USE THEREOF, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE MAKE NO WARRANTIES OR REPRESENTATIONS ABOUT THE ACCURACY OR COMPLETENESS OF THE SERVICES' CONTENT OR THE CONTENT OF ANY WEBSITES OR MOBILE APPLICATIONS LINKED TO THE SERVICES AND WE WILL ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (1) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT AND MATERIALS, (2) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE SERVICES, (3) ANY UNAUTHORISED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (4) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE SERVICES, (5) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH THE SERVICES BY ANY THIRD PARTY, AND/OR (6) ANY ERRORS OR OMISSIONS IN ANY CONTENT AND MATERIALS OR FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE VIA THE SERVICES. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THE SERVICES, ANY HYPERLINKED WEBSITE, OR ANY WEBSITE OR MOBILE APPLICATION FEATURED IN ANY BANNER OR OTHER ADVERTISING, AND WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND ANY THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. AS WITH THE PURCHASE OF A PRODUCT OR SERVICE THROUGH ANY MEDIUM OR IN ANY ENVIRONMENT, YOU SHOULD USE YOUR BEST JUDGEMENT AND EXERCISE CAUTION WHERE APPROPRIATE.

DISCLAIMER

IN NO EVENT WILL WE OR OUR DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOST PROFIT, LOST REVENUE, LOSS OF DATA, OR OTHER DAMAGES ARISING FROM YOUR USE OF THE SERVICES, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, OUR LIABILITY TO YOU FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION, WILL AT ALL TIMES BE LIMITED TO THE AMOUNT PAID, IF ANY, BY YOU TO US DURING THE ONE (1) MONTH PERIOD PRIOR TO ANY CAUSE OF ACTION ARISING. CERTAIN US STATE LAWS AND INTERNATIONAL LAWS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MAY HAVE ADDITIONAL RIGHTS.

LIMITATIONS OF LIABILITY

You agree to defend, indemnify, and hold us harmless, including our subsidiaries, affiliates, and all of our respective officers, agents, partners, and employees, from and against any loss, damage, liability, claim, or demand, including reasonable attorneys’ fees and expenses, made by any third party due to or arising out of: (1) use of the Services; (2) breach of these Legal Terms; (3) any breach of your representations and warranties set forth in these Legal Terms; (4) your violation of the rights of a third party, including but not limited to intellectual property rights; or (5) any overt harmful act toward any other user of the Services with whom you connected via the Services. Notwithstanding the foregoing, we reserve the right, at your expense, to assume the exclusive defence and control of any matter for which you are required to indemnify us, and you agree to cooperate, at your expense, with our defence of such claims. We will use reasonable efforts to notify you of any such claim, action, or proceeding which is subject to this indemnification upon becoming aware of it.

INDEMNIFICATION

We will maintain certain data that you transmit to the Services for the purpose of managing the performance of the Services, as well as data relating to your use of the Services. Although we perform regular routine backups of data, you are solely responsible for all data that you transmit or that relates to any activity you have undertaken using the Services. You agree that we shall have no liability to you for any loss or corruption of any such data, and you hereby waive any right of action against us arising from any such loss or corruption of such data.

USER DATA

Visiting the Services, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications, and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email and on the Services, satisfy any legal requirement that such communication be in writing. YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS, AND OTHER RECORDS, AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES, AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED BY US OR VIA THE SERVICES. You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances, or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by any means other than electronic means.

ELECTRONIC COMMUNICATIONS & SIGNATURES

Opting Out If at any time you wish to stop receiving SMS messages from us, simply reply to the text with 'STOP'. You may receive an SMS message confirming you have opted out. After this, you will no longer receive SMS messages from us.If you want to join again, please sign up as you did the first time, and we will start sending SMS messages to you again.Message and Data Rates Please be aware that message and data rates may apply to any SMS messages sent or received. The rates are determined by your carrier and the specifics of your mobile plan. Carriers are not liable for delayed or undelivered messages.If you have any questions about your text plan or data plan, contact your wireless provider.Support If you have any questions or need assistance regarding our SMS communications, please email us at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a> or call at +971-58-289-9229

SMS TEXT MESSAGING

These Legal Terms and any policies or operating rules posted by us on the Services or in respect to the Services constitute the entire agreement and understanding between you and us. Our failure to exercise or enforce any right or provision of these Legal Terms shall not operate as a waiver of such right or provision. These Legal Terms operate to the fullest extent permissible by law. We may assign any or all of our rights and obligations to others at any time. We shall not be responsible or liable for any loss, damage, delay, or failure to act caused by any cause beyond our reasonable control. If any provision or part of a provision of these Legal Terms is determined to be unlawful, void, or unenforceable, that provision or part of the provision is deemed severable from these Legal Terms and does not affect the validity and enforceability of any remaining provisions. There is no joint venture, partnership, employment or agency relationship created between you and us as a result of these Legal Terms or use of the Services. You agree that these Legal Terms will not be construed against us by virtue of having drafted them. You hereby waive any and all defences you may have based on the electronic form of these Legal Terms and the lack of signing by the parties hereto to execute these Legal Terms.

MISCELLANEOUS

All gold prices displayed on the Platform are indicative only and are based on prevailing market rates at the time of display. Gold prices are subject to continuous fluctuation due to market conditions, liquidity, and volatility. Accordingly, the price shown at the time an order is placed may differ from the price at which the order is ultimately executed.

INDICATIVE PRICING

Any order submitted by a customer through the Platform constitutes an offer to buy or sell gold and does not create a binding contract unless and until the order is accepted and confirmed by Best Gold. We reserve the right, at its discretion, to accept, reject, cancel, or re-quote any order prior to execution.

ORDER SUBMISSION AND ACCEPTANCE

Orders are executed subject to market availability, operational capacity, and applicable trading hours. Orders placed outside normal trading hours, including weekends, public holidays, or after daily cut-off times, may be queued for execution on the next available trading day. Such orders will be executed, if accepted, at the prevailing market price at the t ime of execution.

EXECUTION TIMING AND MARKET HOURS

Where there is a material change in the market price of gold between the time an order is placed and the time it is eligible for execution, Best Gold reserves the right to re-quote the price, reject the order, or cancel the order. In the event of a re-quotation, execution shall occur only upon the customer’s confirmation of the revised price within the timeframe specified by Best Gold. Failure to confirm within such timeframe may result in the order being cancelled.

PRICE MOVEMENT AND RE-QUOTATION

Best Gold does not guarantee that any order will be executed at the indicative price displayed or that an order will be executed at all. Execution is subject to market conditions, price availability, liquidity, system availability, and compliance with applicable laws and internal risk controls.

NO GUARANTEE OF EXECUTION

Best Gold shall not be liable for any loss, damage, or missed opportunity arising from f luctuations in the price of gold, delays in execution, non-execution of orders, or re quotation of prices resulting from market movements, timing of order placement, or operational constraint.

NO LIABILITY FOR MARKET FLUCTUATIONS

By placing an order through the Platform, the customer acknowledges and agrees that: (a) gold prices are not fixed until execution; (b) orders may be executed at a different price than initially displayed; and (c) orders placed outside trading hours may be executed on the next trading day at prevailing market prices.

TRANSPARENCY & CUSTOMER ACKNOWLEDGEMENT

In order to resolve a complaint regarding the Services or to receive further information regarding use of the Services, please email us at: <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a>. The Company will acknowledge receipt of complaints within 2-3 business days and will endeavour to provide a substantive response within 7 business days, subject to the nature and complexity of the matter and any legal or regulatory obligations.

CONTACT US 

Terms of Use

Terms and Condition

Last updated: 16.01.2026 AGREEMENT TO OUR LEGAL TERMS These Terms and Conditions constitute a legally binding agreement between you and NEW BEST GOLD JEWELLERY TRADINGS L.L.C, doing business as Best Gold (“Company”, “we”, “us”, or “our”), a company duly registered and existing under the laws of the United Arab Emirates, with its registered address at 113, Hind Plaza 5B, Deira Waterfront Properties, Deira, Dubai 15411, United Arab Emirates. We operate the website <a target="_blank" rel="noopener noreferrer nofollow" href="https://web.bestgold.ae/en">https://web.bestgold.ae/en</a> (the “Site”), the Best Gold mobile application (the “App”), and any related products or services that expressly refer to or incorporate these Terms and Conditions (collectively, the “Services”). You may contact us by telephone at +971-58-289-9229 or by email at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a> or by post at the address stated above.By accessing, browsing, registering for, or using the Services in any manner, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions. If you do not agree to these Terms and Conditions, you must immediately discontinue access to and use of the Services.These Terms and Conditions apply to all users of the Services, whether acting in a personal capacity or on behalf of an entity. Any updated or revised version of these Terms and Conditions will be indicated by a revised date at the top of this document, and continued use of the Services following such update shall constitute acceptance of the revised terms.The Services are intended solely for individuals who are at least eighteen (18) years of age. Persons under the age of eighteen are not permitted to access or use the Services.We recommend that you retain a copy of these Terms and Conditions for your records.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:▪ names▪ phone numbers▪ email addresses▪ mailing addresses▪ usernames▪ passwords▪ billing addressesSensitive Information.When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:▪ financial data▪ biometric data▪ government identifiersPayment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Network Web Payment Gateaway. You may find their privacy policy link(s)here: <a target="_blank" rel="noopener noreferrer nofollow" href="https://web.bestgold.ae/en/company/privacy-policy">https://web.bestgold.ae/en/company/privacy-policy</a>.Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:▪ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings.▪ Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.Information automatically collectedWe automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.Like many businesses, we also collect information through cookies and similar technologies.The information we collect includes:▪ Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and f iles viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).▪ Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.▪ Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.Google APIOur use of information received from Google APIs will adhere to <a target="_blank" rel="noopener noreferrer nofollow" href="https://developers.google.com/terms/api-services-user-data-policy">Google API Services User Data Policy</a>, including the <a target="_blank" rel="noopener noreferrer nofollow" href="https://developers.google.com/terms/api-services-user-data-policy#limited-use">Limited Use requirements.</a>

WHAT INFORMATION DO WE COLLECT?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including: ▪ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. ▪ To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. ▪ To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. ▪ To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. ▪ To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services. ▪ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. ▪ To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. ▪ To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more. ▪ To post testimonials. We post testimonials on our Services that may contain personal information. ▪ To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. ▪ To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. ▪ To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. ▪ To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. ▪ To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

HOW DO WE PROCESS YOUR INFORMATION?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. We also may need to share your personal information in the following situations: ▪ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. ▪ When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes and other similar information. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device ('cache') your location for 12 months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. ▪ Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.Google AnalyticsWe may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit <a target="_blank" rel="noopener noreferrer nofollow" href="https://tools.google.com/dlpage/gaoptout">https://tools.google.com/dlpage/gaoptout</a>. For more information on the privacy practices of Google, please visit the Google Privacy &amp; Terms page.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than sixty (60) months past the termination of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW LONG DO WE KEEP YOUR INFORMATION?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a>.

DO WE COLLECT INFORMATION FROM MINORS?

Withdrawing your consent.&nbsp;If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us.However, this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.Opting out of marketing and promotional communicationsYou can unsubscribe from our marketing and promotional communications at any time by replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us.You will then be removed from the marketing lists. However, we may still communicate with you to:<ul><li>send service-related messages</li><li>respond to service requests</li><li>support non-marketing operational communication</li></ul>Account InformationIf you would at any time like to review or change the information in your account or terminate your account, you can:<ul><li>Log in to your account settings and update your user account.</li></ul>Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to:<ul><li>prevent fraud</li><li>troubleshoot problems</li><li>assist with investigations</li><li>enforce legal terms</li><li>comply with applicable legal requirements</li></ul>Cookies and similar technologiesMost web browsers are set to accept cookies by default. If you prefer, you can choose to remove cookies or reject cookies. However, doing so may affect certain features or services of our Services.If you have questions or comments about your privacy rights, you may email us at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a>.

WHAT ARE YOUR PRIVACY RIGHTS?

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

CONTROLS FOR DO-NOT-TRACK FEATURES

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy.

DO WE MAKE UPDATES TO THIS POLICY?

If you have questions or comments about this policy, you may email us at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a> or contact us by post at: NEW BEST GOLD JEWELLERY TRADINGS L.L.C 113, HIND PLAZA 5B, DEIRA WATERFRONT PROPERTIES, DEIRA Dubai 15411 United Arab Emirates

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Privacy Policy

Last updated: 16 January 2026This Privacy Policy for NEW BEST GOLD JEWELLERY TRADINGS L.L.C, doing business as Best Gold (“we”, “us”, or “our”), describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:▪ Visit our website at <a target="_blank" rel="noopener noreferrer nofollow" href="https://web.bestgold.ae/en">https://web.bestgold.ae/en</a> that links to this Privacy Policy ▪ Download and use our mobile application (Best Gold) or any other application of ours that links to this Privacy Policy ▪ Engage with us in other related ways, including marketing or events<h2>Questions or Concerns?</h2>Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.If you have questions or concerns, contact us at <a target="_blank" rel="noopener noreferrer nofollow" href="mailto:support@bestgold.ae">support@bestgold.ae</a>.

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