Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing (AML/CFT/CPF) Policy

This policy establishes the framework Peekup Global Express Ltd uses to detect, prevent, monitor, and report money laundering, terrorism financing, proliferation financing, fraud, and other financial crimes conducted through its marketplace and delivery platform.

This policy applies to:

• Customers
• Vendors and merchants
• Riders and delivery personnel
• Employees and contractors
• Third party service providers operating on behalf of Peekup

Peekup operates in accordance with applicable Nigerian laws and compliance obligations, including:

• Money Laundering (Prevention and Prohibition) Act
• Terrorism (Prevention and Prohibition) Act
• Nigerian Financial Intelligence Unit regulations
• Applicable CBN compliance guidelines
• NDPA and applicable data protection obligations

Peekup maintains onboarding and verification procedures for platform users.

Customers

• Mobile number verification via OTP
• Account registration validation
• Transaction monitoring

Vendors

• Business verification
• Identity verification
• Operational review prior to activation

Riders

• Identity verification
• Contact and address verification
• Operational onboarding review

Peekup maintains monitoring systems and operational procedures designed to identify:

• Suspicious transaction activity
• Unusual transaction frequency
• Fraud indicators
• Abnormal payment behaviour
• High risk vendor activity
• Account misuse

Accounts identified as potentially high risk may be subject to:

• Enhanced review
• Additional verification
• Temporary restrictions
• Suspension or termination

Peekup monitors transaction activity internally and through licensed payment processing partners including:

• Flutterwave
• Paystack

Monitoring includes:

• Transaction behaviour review
• Fraud pattern analysis
• Account activity review
• Escalation of suspicious activity

Where required by applicable law or through regulated financial partners, Peekup may cooperate with relevant authorities regarding suspicious activity investigations.

Peekup maintains records relating to:

• Customer onboarding
• Vendor onboarding
• Transaction activity
• Compliance reviews
• Fraud investigations

Records are retained in accordance with operational, legal, and regulatory requirements.

Employees involved in operations, onboarding, compliance, or payment activities may receive periodic compliance and fraud awareness training.

This policy shall be reviewed annually or whenever material regulatory or operational changes occur.

Approved by: Executive Management

Company: Peekup Global Express Ltd