UOA REAL ESTATE INVESTMENT TRUST

ANTI-MONEY LAUNDERING POLICY

This Anti-Money Laundering ("AMLA") Policy serves to affirm UOA Real Estate Investment Trust ("UOA REIT")'s commitment to full compliance with the Anti-Money Laundering, AntiTerrorism Financing ("ATF") and Proceeds of Unlawful Activities Act 2001 ("AMLATFA"). This aligns with our Code of Conduct and underscores UOA REIT's dedication to conducting business with integrity and upholding the highest standards of the AMLA and the ATF compliance.

This policy applies to all employees of UOA Asset Management Sdn. Bhd., being the manager for UOA REIT, and it contains the minimum standards for detecting and preventing money laundering and terrorism financing risks across our operations to safeguard UOA REIT from being misused for AMLA or ATF activities.

We strictly prohibit any practices related to money laundering and terrorism financing, including dealing with criminal proceeds. Appropriate due diligence must be performed to understand the background and business of any customer, vendor, or third-party having business relationship with UOA REIT.

All suspicious activities are to be reported to Bank Negara Malaysia ("BNM") immediately. Prohibited activities include:

  1. Payments in currencies different from amounts in the invoices.
  2. Third-party payments related to contractual obligations
  3. Cash payment inconsistent with standard business practices.

We will conduct Customers Due Diligence (CDD) at the onset of any new business relationship or upon detecting suspicious activity. All written agreements contain an AMLA/ATF clause for the confirmation by the customers, suppliers or business associates. CDD procedures include:

  1. Verifying customers' and beneficial owners' identities
  2. Understanding the nature and purpose of the business relationship.
  3. Screening against sanctions list from the Ministry of Home Affairs ("MOHA") (https://www.moha.gov.my/utama/index.php/en/component/content/article/350-list-of-ministries-of-home-affairs#:~:text=LIST%20OF%20SANCTIONS%20UNDER%20THE,Activities%20Act %202001%20%5BAct%20613%5D).
  4. Screening against sanctions list from the United Nations Security Council (https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list).
  5. Screening against BNM's sanctions list (https://amlcft.bnm.gov.my/sanctions-related-to-tf-pf-and-other-sanctions).

Suspicious transactions must be flagged and reported to the Internal Auditor immediately for further investigation. Suspicious activities include:

  1. Reluctance to disclose income sources
  2. Transactions inconsistent with customer's business
  3. Unjustified payments from third parties or foreign accounts.

The Internal Auditor will investigate such case and if warranted, fill a Suspicious Transaction Report ("STR") with BNM.




Approved by the Board on 21 January 2026