Third Party Due Diligence

1.  Purpose

This process ensures Neutrino Group and its entities knows who it is doing business with, that third parties align with our ethical standards, and that we meet our legal and contractual due diligence obligations.

2.  Scope

This process applies to all new third-party relationships including suppliers, resellers, technology partners, agents, distributors, and consultants. It also applies to material renewals or expansions of existing relationships.

3.  Risk-Based Approach

Due diligence is proportionate to the level of risk. Neutrino AI assesses each third party against the following risk tiers:

Risk Level	Criteria	Due Diligence Required
Low	Small suppliers, low- value contracts, no government involvement	Basic information collection + Code of Conduct acceptance
Medium	New partners, cross- border transactions, reseller relationships	Ownership verification + sanctions check + Code of Conduct + management approval
High	Government-connected parties, high-value contracts, higher-risk jurisdictions	All of Medium + enhanced background check + senior management sign-off

 

4.  Due Diligence Process

The following steps are followed for all new third-party engagements:

 

Step	Stage	Action	Owner
1	Screening	Identify third party & determine risk level (Low / Medium / High)	Management
2	Information Gathering	Collect business name, registration, ownership structure, jurisdiction, and references	Management
3	Sanctions & Integrity Check	Check against UAE, UN, OFAC, and EU sanctions lists. Review for adverse media or legal issues	Management
4	Policy Acknowledgement	Third party reviews and confirms acceptance of Neutrino AI’s Third Party Code of Conduct	Management
5	Approval	Management reviews findings and formally approves or declines the relationship	Senior Management
6	Ongoing Monitoring	Annual review of existing third parties; immediate review if red flags emerge	Management

 

5.  Information We Collect

Depending on the risk level, Neutrino Group and its entities may collect the following information from third parties:

• Legal entity name, registration number, and jurisdiction of incorporation
• Ultimate beneficial ownership (UBO) information
• Names of key directors or principals or representatives in UAE
• Nature of business and services to be provided
• Professional references or client references where appropriate

6.  Sanctions & Adverse Media Screening

All third parties will be screened against:

• UAE Central Bank and local regulatory watchlists
• United Nations consolidated sanctions list
• OFAC (US Office of Foreign Assets Control) SDN list
• EU consolidated sanctions list
• Publicly available adverse media searches
• Any matches or potential matches will be escalated to senior management before the relationship proceeds.

7.  Ongoing Monitoring

Existing third-party relationships are subject to periodic review:

• Low risk: reviewed every 2 years or upon contract renewal
• Medium risk: reviewed annually
• High risk: reviewed annually with enhanced scrutiny

Any significant change in a third party’s ownership, jurisdiction, or business activity, or any adverse news, will trigger an immediate interim review.

8.  Record Keeping

All due diligence documentation, decisions, and approvals will be recorded and retained for a minimum of 5 years. This includes completed questionnaires, screening results, and management sign-offs.

9.  Responsibility

Management is responsible for initiating and overseeing third party due diligence. All relevant staff are expected to cooperate with the process and flag any concerns regarding existing or prospective third parties.