Anti-Money Laundering Policies and Procedures Manual

The Turks and Caicos Islands Proceeds of Crime Ordinance and Anti-Money Laundering and Prevention of Terrorist Financing Regulations prescribe certain measures to guard against the Financial Services Providers being used to facilitate money laundering. The Directors, Officers, Management and Staff of EPIC are committed to ensuring that the Company is not used to facilitate money laundering. The Company welcomes and embraces the requirements of the Proceeds of Crime Ordinance 2007 (as amended by the Proceeds of Crime Amendment Ordinance of 2009 and 2010), the Anti-Money Laundering and Prevention of Terrorist Financing Regulations 2010 (“the Regulations”) and the Anti-Money Laundering and Prevention of Terrorist Financing Code 2011 (“the Code”).

EPIC therefore supports the efforts of the Turks and Caicos Islands Government, through the auspices of the Financial Services Commission (“FSC”) and the Money Laundering Reporting Authority (“MLRA”) in endeavoring to prevent the Turks and Caicos Islands (“TCI”) and Epic being used and/or abused by money launderers. The Company has accordingly adopted certain prescribed policies, and procedures aimed at ensuring complete compliance with the regulatory requirements under the Anti-Money Laundering and Prevention of Terrorist Financing Compliance Ordinance, Regulations and Code.

In addition, EPIC, taken appropriate proactive steps to ensure rigid compliance with the Company’s established policies and procedures to safeguard the Directors and shareholders against criminal liability under the relevant provisions of the laws of the Islands.