bring. It sets the boundaries for the risks we can tolerate in our activities and helps us find the balance
between risk taking and risk avoidance.
2.3. Virtual Currency – means a value represented in the digital form, which is digitally transferable, reservable
or tradable and which natural persons or legal persons accept as a payment instrument, but that is not
the legal tender of any country or funds for the purposes of Article 4(25) of Directive (EU).
2.4. Virtual Currency Exchange Services – rmeans a service with the help of which a person exchanges a virtual
currency against a fiat currency or a fiat currency against a virtual currency or a virtual currency against
another virtual currency.
2.5. Virtual Currency Wallet Services - means a service in the framework of which keys are generated for clients
or clients’ encrypted keys are kept, which can be used for the purpose of keeping, storing and
transferring virtual currencies.
2.6. High-Risk Third Country – means a country specified in a delegated act adopted on the basis of Article 9(2)
of Directive (EU) 2015/849 of the European Parliament and of the Council on the prevention of the use
of the financial system for the purposes of money laundering or terrorist financing, amending
Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive
2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.
2.7. Money Laundering – means the conversion or transfer of property derived from criminal activity or property
obtained instead of such property, knowing that such property is derived from criminal activity or from
an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the
property or of assisting any person who is involved in the commission of such an activity to evade the
legal consequences of that person’s actions; the acquisition, possession or use of property derived from
criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such
property was derived from criminal activity or from an act of participation therein; and the concealment
or disguise of the true nature, source, location, disposition, movement, rights with respect to, or
ownership of, property derived from criminal activity or property obtained instead of such property,
knowing that such property is derived from criminal activity or from an act of participation in such an
activity.
3. Core Principles
3.1. Overall, the Company has a balanced approach to risk. Our risk appetite is based on our core values and
aligned to our strategic objectives. It is important to remember that risk management is not purely
about avoidance of risk. Our vision and strategic objectives require that we manage risk based on value.
3.2. We accept that risk is commensurate with potential reward such as growth, transformation and
innovation.
3.3. The key aspects of achieving balance are:
3.3.1. Ensuring ethical and effective governance practices, including responsible management of
resources.
3.3.2. Capitalizing on opportunities that promote growth, transformation and innovation, while
avoiding unnecessary negative impacts.
3.3.3. Preventing a culture that is risk averse and stifles growth, transformation and innovation. 3.3.4.
Fostering a culture that supports value-based assessment and management of risks. 3.4. The following core
principles provide context for decision-makers in applying the RAS: 3.4.1. The RAS is not an exhaustive list that
addresses every situation but provides general guidelines. 3.4.2. Everyone is empowered to interpret the RAS
to make pragmatic, risk-based decisions in the best interest of the Company and its shareholders.
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3.4.3. The RAS is a forward-looking expression of risk appetite. It reflects our tolerance for accepting new
or developing risks (in addition to current risks) in achieving the Company's strategic objectives.
3.4.4. Our risk appetite and risk tolerance are dynamic and will change over time in response to
different drivers.
3.4.5. All decisions align with the Company's Strategy and Mission, Vision and Values.
4. Key Risk Appetite Concepts
4.1. Our risk appetite is a reflection of the Company's risk profile and capacity to take risks.
4.2. We use the following concepts in defining appetite:
4.2.1. Risk profile — this is our overall position on risk. It considers the type and amount of risk the
Company is exposed to across all risk categories.
4.2.2. Risk capacity —the maximum level or ‘ability' of the Company to accept risk in each risk
category.
4.2.3. Risk appetite — the amount and type of risk the Company is comfortable to accept to achieve its
objectives.
4.2.4. Risk tolerance (upper and lower limits) — the level (generally quantitative) of risk which, if reached,
would require an immediate escalation and corrective action. A breach of tolerance is a breach