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This document presents a detailed and expanded summary of the internal manual of NARA CAPITAL PARTNERS SGEIC SA, in accordance with Law 10/2010 and its regulations, with the aim of facilitating its understanding and public dissemination.

1. Introduction

NARA CAPITAL PARTNERS SGEIC SA is a management company of closed-end investment entities, subject to Spanish regulations on anti-money laundering and counter-terrorist financing (AML/CFT). This summary outlines the main commitments, procedures, and measures adopted by the entity to ensure regulatory compliance.

2. Regulatory Framework

The AML/CFT policy is based on Law 10/2010 of April 28 and its implementing regulation approved by Royal Decree 304/2014. It also considers European directives, FATF recommendations, and SEPBLAC provisions.

Example: The entity must apply enhanced due diligence measures to clients linked to countries considered high-risk by the European Commission.

3. Responsible Bodies

The Board of Directors is the governing body of the AML/CFT policy. Additionally, an Internal Control Body (OCI) composed of the company’s partners has been established to oversee the implementation of measures.

Example: The OCI meets quarterly and analyzes suspicious transactions detected by staff or internal systems.

4. Client Admission and Classification

Before establishing business relationships, the client’s identity, beneficial ownership, and source of funds are thoroughly verified. Clients are classified into three risk levels: average, high, and low.

Example: A client operating from a tax haven will be classified as high risk and subject to enhanced measures.

5. Due Diligence Measures

General, simplified, or enhanced measures are applied depending on the risk level. These include client identification, business relationship monitoring, and verification of declared activities.

Example: For average-risk clients, a document review is conducted every two years; for high-risk clients, annually.

6. Reporting Suspicious Transactions

The entity has internal procedures to detect, analyze, and report suspicious transactions to SEPBLAC. Confidentiality and whistleblower protection are ensured.

Example: If an employee detects an unusual transaction, they can report it anonymously to the OCI using an internal form.

7. Document Retention

All AML/CFT-related documentation is retained for at least 10 years in secure digital format, in compliance with data protection regulations.

Example: Client files include copies of identity documents, KYC forms, and transaction records.

8. Staff Training and Protection

All staff receive annual AML/CFT training. Protection against retaliation is guaranteed, and ethical suitability is assessed through honorability questionnaires.

Example: A new employee must complete an online course and sign a responsible declaration about their professional background.

9. Supervision and Review

The internal control system is periodically reviewed by the Board of Directors and an external expert. Corrective measures are adopted when deficiencies are detected.

Example: If the external expert’s report identifies flaws in client classification, the manual is updated and training reinforced.

10. Data Protection

Personal data collected for AML/CFT purposes cannot be used for other purposes without consent. High-level security measures are applied.

Example: Client identification data is stored on encrypted servers and accessible only to the OCI and representative.

11. Conclusion

This expanded summary reflects NARA CAPITAL PARTNERS SGEIC SA’s commitment to legality, transparency, and business ethics. The AML/CFT policy is a fundamental pillar to ensure the integrity of its operations.