Institutional Only|Drovix does not deal with individual investors and does not accept deposits or provide retail trading services.

Drovix.
Compliance

Anti-Money Laundering and Investor Due Diligence (IDD) Policy

Drovix (MU) Ltd

Authorized and regulated by the Financial Services Commission (FSC) of Mauritius

Investment Dealer (Full Service Dealer) excluding Underwriting, License No. GB21026813

Registered Address: C/o SALVUS (Mauritius) Ltd, Silver Bank Tower, Ground Floor, 18 Bank Street, Cybercity, Ebene 72201, Mauritius

www.drovix.com

Effective Date: March 2026 | Institutional AML/IDD framework

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1. Important Notice

Available exclusively to institutional investors, professional investors, and qualified counterparties. Not intended for retail investors.

2. Introduction

Drovix (MU) Ltd (the "Company") is an alternative asset manager committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). This Policy describes how the Company applies a risk-based approach to investor due diligence and ongoing monitoring.

The Company complies with the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA), the Prevention of Terrorism Act 2002, the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019, and applicable regulations and guidance issued by the FSC and the Financial Intelligence Unit (FIU) of Mauritius.

3. AML/CTF Governance

The Company maintains the following governance and control arrangements:

  • A designated Money Laundering Reporting Officer (MLRO) and Deputy MLRO;
  • An AML/CTF Committee (or equivalent senior forum) for oversight;
  • Comprehensive Investor Due Diligence (IDD) procedures aligned to institutional relationships;
  • Ongoing monitoring of investors and transactions;
  • Risk-based assessment and classification of relationships;
  • Regular AML/CTF training for relevant staff;
  • Record retention for at least seven (7) years;
  • Internal reporting of suspicions to the MLRO and filing of Suspicious Transaction Reports (STRs) with the FIU where required;
  • Sanctions screening against relevant international lists.

4. Investor Due Diligence (IDD)

The Company shall identify and verify every investor before establishing a business relationship and on an ongoing basis as risk requires.

IDD includes, where applicable:

  • Identifying the investing entity and its legal form;
  • Identifying authorised representatives and verifying their authority to act;
  • Identifying Ultimate Beneficial Owners (UBOs) holding 10% or more of ownership or control (or lower thresholds where required);
  • Understanding the nature and purpose of the relationship and expected activity;
  • Understanding source of funds and source of wealth.

5. Institutional Investor Requirements

For institutional investors, the Company typically obtains and verifies the following (as applicable to the entity and role):

  • Certificate of Incorporation or equivalent registration evidence;
  • Constitutional / organisational documents;
  • Regulatory authorisation where the investor is a regulated financial entity;
  • Register of directors and evidence of ownership/control structure;
  • UBO identification in line with Section 4;
  • Board Resolution (or equivalent) authorising the investment and appointing signatories;
  • Identity verification for authorised signatories and UBOs;
  • Investment mandate or equivalent instructions;
  • Source of funds declaration;
  • Audited financial statements (or equivalent) where available;
  • 4.1 Regulated Financial Institutions: simplified due diligence may be applied where the counterparty is subject to an equivalent AML/CTF regime and verification is satisfied in line with policy;
  • 4.2 Sovereign Wealth Funds: enhanced screening applies, including particular attention to political exposure and sanctions risk.

6. Professional Investor Requirements

Where the investor is a professional investor that is a legal entity, documentation consistent with Section 5 is generally required. For natural persons classified as professional investors, the Company typically obtains:

  • Photographic identity documentation;
  • Proof of address;
  • Evidence of professional investor status in accordance with applicable criteria;
  • Source of funds and source of wealth information.

7. Politically Exposed Persons (PEPs)

Relationships involving PEPs (including family members and close associates where relevant) are subject to Enhanced Due Diligence.

Measures include senior management approval before onboarding, verification of source of wealth, and enhanced ongoing monitoring.

8. Enhanced Due Diligence (EDD)

EDD applies in higher-risk scenarios, including without limitation:

  • PEP relationships;
  • Investors or structures linked to high-risk jurisdictions;
  • Complex ownership or control structures without clear economic purpose;
  • Unusual patterns of subscriptions, redemptions, or instructions;
  • Any other circumstances where the risk assessment indicates elevated AML/CTF risk.

9. Ongoing Monitoring

The Company monitors investor relationships on an ongoing basis to ensure that transactions remain consistent with knowledge of the investor, its risk profile, and source of wealth.

  • Periodic review of the relationship, including at least annually for higher-risk investors unless a different frequency is justified and documented;
  • Monitoring of subscriptions and redemptions for consistency with the investor profile;
  • Continuous or periodic sanctions screening commensurate with risk;
  • Periodic review of risk classification and supporting documentation.

10. Suspicious Transaction Reports (STRs)

Where staff know, suspect, or have reasonable grounds to suspect that activity may involve proceeds of crime or terrorist financing, they must promptly report to the MLRO.

The MLRO assesses internal reports and files STRs with the FIU where required. Tipping off is prohibited.

11. Sanctions Compliance

The Company screens against relevant sanctions regimes and does not onboard or maintain relationships with sanctioned persons or entities.

  • United Nations sanctions lists;
  • European Union sanctions lists;
  • United States sanctions lists (including OFAC);
  • United Kingdom sanctions lists;

12. Record Keeping

The Company maintains complete records of identification, verification, risk assessments, STRs, training, sanctions screening outcomes (as appropriate), and material correspondence for a minimum of seven (7) years, in line with FIAMLA and FSC expectations.

13. Capital Flow Controls

To mitigate financial crime risk, the Company applies strict standards to the movement of capital:

  • Subscriptions must be remitted from the investor's account or that of its appointed custodian;
  • Redemptions are paid to the same account or custodian chain unless otherwise agreed in writing with appropriate verification;
  • Third-party payments are not permitted;
  • The Company may request additional documentation to verify the legitimacy of flows;
  • The Company may delay or refuse instructions or transactions that appear suspicious or inconsistent with the investor profile, subject to applicable law.

14. Employee Training

Employees receive comprehensive AML/CTF training at least annually, covering legal obligations, typologies and red flags, IDD procedures, STR reporting, sanctions compliance, and the consequences of non-compliance.

15. Annual Review

This Policy is reviewed at least annually by the MLRO and senior management to ensure it remains effective and aligned with legal and regulatory developments.

Drovix (MU) Ltd | Financial Services Commission (FSC) of Mauritius | License No. GB21026813

www.drovix.com | C/o SALVUS (Mauritius) Ltd, Silver Bank Tower, Ground Floor, 18 Bank Street, Cybercity, Ebene 72201, Mauritius