Sun International Anti-Money Laundering,
Anti-Terrorism and Proliferation Financing Statement

Approved by the Sun International Limited Board on 12 July 2022.

Sun International remains committed towards playing its role in combatting and preventing activities and crimes related to money-laundering, terror financing and proliferation financing (collectively referred to as "Prohibited Activities") within its organisation.

It is the policy of Sun International and its subsidiaries (collectively referred to as the "Group") the latter of whom are Accountable Institutions in terms of Schedule 2 of the Financial Intelligence Centre Act to implement risk-based measures that are practical and reasonable to prohibit and actively prevent, where known, activities related to the Prohibited Activities from occurring within the Group. Where suspicion arises from clients and counterparties concluding transactions that may be linked to Prohibited Activities, the Group will report such suspicious activity to the Financial Intelligence Centre.

The Group summarises the meaning of money laundering as engaging in acts specifically designed to conceal or disguise the true origins of criminally obtained proceeds so that unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets of perpetrators. It further summarises terrorism and proliferation financing to mean the funding of acts of terrorism and weapons of mass destruction.

Our policy is based on the following principles which are embodied in our Anti-Money Laundering, Anti-Terrorism and Sanctions Policy ("AML/CTF Policy"):

• Establish a risk-based risk management compliance programme ("RMCP"), policies, procedures and internal controls based on our assessment of the risks associated with our gambling businesses activities.
• Appoint a Group Anti-Money Laundering Compliance Officer ("Group AMLCO") to advise the boards and senior management of each Accountable Institution and to lead each Accountable Institution’s Anti-Money Laundering Compliance Officers ("AMLCO").
• Appoint AMLCOs within each Accountable Institution who are responsible for ensuring that (i) the AML/CFT Policy and RMCP is effectively implemented; (ii) the RMCP is updated as necessary to reflect changes in products and services, and changes in risk to the business; and (iii) that relevant employees are trained in the RMCP and related procedures.
• To implement adequate risk-based client due diligence processes and to keep accurate records contemplated in the Financial Intelligence Centre Act.
• To verify the clients of its Accountable Institutions and counterparties against the UN Sanctions List at a minimum, and to further identify clients who are Politically Exposed Persons and Prominent Influential Persons.

The Group will conduct independent testing to ensure that the programme is functioning as designed. Also, all employees will be encouraged to report suspicious activities to the AMLCOs for further investigation and reporting.
The public is also encouraged to utilise the Group’s independently managed Ethics Hotline to anonymously report any suspicious conduct of its clients and counterparties that may be linked to Prohibited Activities.