Prohibited Activities Policy

1.1 Overview. To ensure the integrity, legality, and security of its card program, Tiva Finance Services Ltd., a company registered in Nigeria under registration number RC 8542671, with its registered office at P10 Henry Ojogho Crescent, Lekki, Lagos, Nigeria ("Tiva," "Company," "we," "us," or "our"), maintains this Prohibited Activities Policy ("Policy"). This Policy sets forth the types of businesses, transactions, jurisdictions, and activities that are prohibited or restricted on the Platform, including the website at www.tivafinance.com (the "Site"), application cards.tivafinance.com (the "App"), and all services provided or facilitated thereby (collectively, the "Platform" or "Services"). This Policy is the Prohibited Activities Policy referred to in Section 11.1 of our Cardholder Terms of Service, available at cards.tivafinance.com/card-terms, and forms part of those Terms. Capitalized terms not defined in this Policy have the meanings given to them in the Cardholder Terms of Service.

1.2 Applicability. This Policy applies to all Cardholders, applicants, and transactions conducted on or through the Platform, including every Card issued through the Platform. You are responsible for ensuring that your activities comply with this Policy and all applicable laws and regulations in your jurisdiction.

1.3 Card Program Infrastructure. Platform technology is provided by SquareFi Inc., a Delaware corporation ("Technology Provider"). Card program infrastructure and regulated financial services accessed through the Platform are provided by BUYEASY TECHNOLOGY CO., LTD, a company incorporated in Ontario, Canada (the "Infrastructure Partner"), our sole Infrastructure Partner, together with its licensed financial partners, including card issuers. The Infrastructure Partner, its financial partners, the applicable payment networks, and regulators impose compliance requirements on the use of Cards. This Policy sets out the restrictions that apply to the card services offered through the Platform. Where this Policy and the requirements of the Infrastructure Partner, its financial partners, or a payment network differ, the stricter restriction applies.

1.4 Policy Updates. This Policy is subject to change based on regulatory, legal, and operational requirements, including updates from international bodies such as the Financial Action Task Force (FATF), the U.S. Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and other relevant regulatory authorities, and changes required by the Infrastructure Partner. We reserve the right to update this Policy at any time without prior notice. The current version is always published at cards.tivafinance.com/prohibited-activities with its "Last Updated" date.

2.1 Universally Prohibited Businesses. The following categories of businesses or activities are strictly prohibited from accessing or using the Platform: (a) any business engaged in illegal activities or the sale of illegal products or services under applicable law; (b) production, distribution, or sale of controlled substances without valid licensing from the appropriate governmental authority; (c) human trafficking, forced labor, prostitution, escort services, or similar exploitative businesses; (d) manufacturing, distribution, or sale of counterfeit goods, pirated software, music, movies, or other intellectual property violations; (e) deceptive, misleading, or predatory business models, including pyramid schemes, Ponzi schemes, multi-level marketing schemes, get-rich-quick schemes, or fund aggregation and factoring services; (f) activities involving illegal content, including child sexual abuse materials (CSAM) or any form of exploitation of minors; (g) businesses promoting unlawful violence, terrorism, or extremism; and (h) shell banks or entities designed to obscure the beneficial ownership of funds.

2.2 Activities Prohibited for Cards. In addition to the universally prohibited categories above, you may not use the Platform or any Card for, or in connection with, any of the following activities: (a) illegal drugs and drug paraphernalia, including pseudo-pharmaceuticals and prescription drugs without a prescription; (b) fraudulent identification, including fake IDs, forged government documents, identity fraud, and bearer shares; (c) violence, hate, human trafficking, and exploitation, including unlawful violence, hate groups, human trafficking, modern slavery, child exploitation, and trade in human body parts; (d) unlawful products and services, including stolen property, embargoed goods, and any activity in violation of law; (e) intellectual property infringement and counterfeit goods, including illicit streaming of copyrighted media; (f) sanctions and licensing violations; (g) money laundering, fraud, and AML/KYC control failures, including money laundering and fraud facilitation, anonymous or no-KYC card programs and card resale, online marketplaces with limited KYC, and refusal of due diligence; (h) terrorist financing and proliferation financing; (i) unregulated or unlicensed money services businesses (MSBs), remittance services, and payment processors; (j) shell banks and shell companies lacking verifiable economic substance, including nominee or opaque ownership structures; (k) bribery, corruption, and facilitation payments; (l) criminal facilitation of tax evasion; (m) wildlife and cultural artefact trafficking, including trafficking in animals and livestock; and (n) environmental crime or repeated environmental violations, including illegal logging, mining, and waste dumping.

2.3 Personal Use; No Card Resale. Each Card is issued to the verified Cardholder for that Cardholder's own use. You may not sell, rent, lend, transfer, or otherwise make your Card, Card details, or Account available to any other person, operate a Card on behalf of an unidentified third party, or use the Platform to run a card program or card resale service for others.

2.4 Gambling. You may not use the Platform or any Card for gambling transactions except as expressly permitted after compliance approval, as provided in Section 11.1 of the Cardholder Terms of Service.

3.1 Prohibited Transactions. The following types of transactions are not permitted on the Platform or with any Card: (a) purchase or sale of illegal drugs, narcotics, or controlled substances without proper authorization from the relevant governmental authority; (b) use of stolen, forged, or unauthorized financial instruments, identification documents, or credentials; (c) funding or engagement in cybercrime, malware distribution, hacking services, or dark-web-related payments; (d) purchase, sale, or distribution of weapons, ammunition, or explosives for unauthorized purposes; (e) operation of unlicensed online pharmacies or participation in illicit pharmaceutical trade; (f) unlawful access to, trafficking in, or sale of personally identifiable information (PII) or sensitive data; (g) offering payday loans, high-interest unlicensed lending, or debt collection without applicable licensing and compliance; (h) trade or sale of endangered species or products derived from them; (i) drug-related purchases, including drug paraphernalia and substances mimicking illegal drugs; and (j) any transaction designed to circumvent sanctions, export controls, or other regulatory restrictions.

3.2 Structuring and Evasion. You are prohibited from structuring transactions to avoid reporting thresholds, circumventing internal controls, or engaging in any activity intended to evade compliance with applicable laws, regulations, or this Policy.

3.3 Sanctions Compliance. You shall not engage in any transaction or activity involving: (a) individuals or entities designated on sanctions lists maintained by OFAC, the United Nations, or the European Union; (b) individuals or entities owned or controlled by sanctioned parties; or (c) any activity that would cause us, the Infrastructure Partner, or its financial partners to violate applicable sanctions laws.

4.1 Overview. We restrict access to Cards in certain jurisdictions subject to sanctions, regulatory restrictions, or elevated financial crime risks. You may not apply for, hold, or use a Card if you are located in, resident in, or hold a passport or national identity document issued by any jurisdiction listed in Sections 4.2 or 4.3, and you may not use a Card for transactions with persons, merchants, or counterparties in those jurisdictions.

4.2 Prohibited Jurisdictions. Card services are not available in, and may not be used in connection with, the following jurisdictions: Afghanistan; Belarus; Central African Republic; Cuba; Democratic Republic of the Congo (DRC); Haiti; Iran; Iraq; Libya; Myanmar (Burma); North Korea (DPRK); Russia; Somalia; South Sudan; Sudan; Syria; Ukraine; Venezuela; Yemen; Zimbabwe; and any unrecognised or occupied territory, including Crimea, Abkhazia, Zaporizhzhia, South Ossetia, Nagorno-Karabakh, Luhansk (LNR), Donetsk (DNR), the Kherson occupied areas, and Kosovo.

4.3 Jurisdictions Not Currently Supported. Card services for the following jurisdictions may be possible only on a case-by-case basis, subject to enhanced due diligence and compliance approval: Albania; Bosnia-Herzegovina; Ethiopia; Lebanon; Mali; Nicaragua; and North Macedonia. The Platform does not currently accept applications from persons located in, resident in, or holding a passport or national identity document issued by these jurisdictions. If you believe you qualify for an exception, contact support@tivafinance.com.

4.4 Ukraine and Occupied Territories. Ukraine is prohibited for card services. Unrecognised or occupied territories listed in Section 4.2, including Crimea, Donetsk, Luhansk, Zaporizhzhia, and the Kherson occupied areas, are also prohibited. Applications from Ukrainian nationals who hold citizenship or a valid residence permit in a permitted jurisdiction may be considered only on an exceptional basis, outside the standard application flow, subject to enhanced due diligence and senior management approval. Such requests must be sent to support@tivafinance.com.

4.5 Changes to Restricted Jurisdictions. We reserve the right to add or remove jurisdictions from these lists at our sole discretion, including in response to updates from FATF, OFAC, the United Nations, the European Union, or other relevant regulatory authorities, or to requirements of the Infrastructure Partner. You will be notified of material changes to the restricted jurisdictions list through Platform notifications or email.

4.6 User Responsibility. You are responsible for ensuring that you do not use the Platform in violation of the geographic restrictions applicable to your Account. We reserve the right to immediately suspend or terminate any Account that is found to be operating from, or facilitating transactions to or from, a restricted jurisdiction.

5.1 Application Screening. When you apply for a Card, we ask for your country of issue and the country that issued your passport. We do not submit an application to the Infrastructure Partner where either is a jurisdiction listed in Section 4.

5.2 Applicant Declaration. Before a Card is requested, you must confirm that you are not located in, resident in, or a national of a jurisdiction listed in Section 4, and that you will not use the Platform or any Card for any business, transaction, or activity prohibited or restricted under this Policy.

5.3 Verification by the Infrastructure Partner. The checks described in this Section 5 are in addition to, and do not replace, the identity verification, sanctions screening, and AML monitoring performed by the Infrastructure Partner, which determines verification outcomes as described in the Cardholder Terms of Service.

6.1 Monitoring. We, the Infrastructure Partner, and our service providers employ automated and manual monitoring systems to detect potential violations of this Policy. Monitoring includes, but is not limited to: (a) transaction monitoring for suspicious activity; (b) sanctions screening of Cardholders, counterparties, and transactions; (c) periodic reviews of Accounts and Card activity; and (d) analysis of usage patterns for potential circumvention of restrictions.

6.2 Investigation and Remediation. We reserve the right to investigate any suspected violation of this Policy. During an investigation, we or the Infrastructure Partner may: (a) suspend your Account and freeze your Card or funds; (b) request additional documentation or information from you; (c) restrict access to certain features or services; and (d) engage external counsel or forensic specialists as necessary.

6.3 Consequences of Violation. Violations of this Policy may result in: (a) immediate suspension or termination of your Account and Card; (b) forfeiture of funds in accordance with applicable law and our Cardholder Terms of Service; (c) reporting to applicable regulatory bodies, law enforcement authorities, or financial intelligence units; and (d) pursuit of civil or criminal remedies as appropriate.

6.4 Cooperation with Authorities. We cooperate fully with law enforcement agencies, regulatory authorities, and judicial bodies in connection with investigations of violations of this Policy, applicable laws, or regulations, and shall provide information as required by lawful requests, court orders, and regulatory inquiries.

7.1 Compliance. You are required to: (a) comply with this Policy and all applicable laws and regulations; (b) provide accurate and complete information during onboarding and throughout your relationship with us; (c) promptly notify us of any changes to your country of residence, nationality, or other information relevant to your eligibility; and (d) cooperate with our compliance inquiries and requests for information.

7.2 Reporting. If you become aware of any activity on the Platform that may violate this Policy, you are encouraged to report it to us at legal@tivafinance.com. Reports may be made confidentially.

Compliance Inquiries:

Tiva Finance Services Ltd.

P10 Henry Ojogho Crescent, Lekki

Lagos, Nigeria

Email: legal@tivafinance.com

General Support:

Email: support@tivafinance.com

Website: www.tivafinance.com

For questions about permitted activities, restricted jurisdictions, or this Policy, please contact us using the details above.