COMPLIANCE AND DUE DILIGENCE POLICY

Last Updated: September 14, 2026

This Compliance and Due Diligence Policy ("Policy") sets forth the operational standards, evaluation protocols, and regulatory compliance framework applied by Wide Wings Consultancy DMCC ("Company", "we", "us", or "our"), operating under Dubai Multi Commodities Centre commercial license number DMCC-870296, with its registered office at:

Unit No: BA1151, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, United Arab Emirates.

The Company operates the Premier International Real Estate Investors Association (PIREIA) platform and network ("Platform"). All operations, project reviews, event hosting, and commercial introductions conducted under PIREIA are executed strictly within the registered business activity of Commercial Information Services.

1. COMPLIANCE PURPOSE AND OPERATIONAL SCOPE

1.1. Objective: This Policy establishes transparent rules for screening real estate issuers, projects, developers, independent advisors, and accredited investors who participate in the PIREIA ecosystem.

1.2. Institutional Boundaries: Wide Wings Consultancy DMCC operates as an information media infrastructure and B2B marketing platform. The Company is NOT a regulated bank, financial institution, broker-dealer, investment advisor, or regulatory authority under the DFSA, SCA, SEC, or equivalent international bodies.

1.3. Information Integrity: While PIREIA applies rigorous internal standards to maintain high-quality data across its capital corridors (Central Asia, MENA, South Asia), our due diligence procedures serve information curation purposes and do NOT constitute formal financial underwriting or regulatory endorsement.

2. ISSUER AND PROJECT DUE DILIGENCE FRAMEWORK

Prior to feature publication, email distribution, webinar hosting, or inclusion in PIREIA private VIP dinners and roadshows, real estate projects and issuers undergo a multi-tiered information screening process.

2.1. Corporate & Track Record Verification:

• Verification of legal registration, corporate governance, and valid operating licenses of the issuing developer or fund sponsor.
• Review of executive leadership track record, past completed developments, and history of capital delivery.
• Background checks against international litigation, insolvency registries, and regulatory sanction lists.

2.2. Project Documentation & Asset Curation:

• Inspection of property title deeds, land ownership records, zoning permissions, and master construction permits issued by relevant local government authorities.
• Review of financial modeling premises, capital stack structures (equity, debt, mezzanine), and independent third-party feasibility studies.
• Examination of escrow account arrangements and local compliance structures governing buyer/investor funds.

2.3. Cross-Border Tax & Legal Compliance:

• Confirmation that investment terms match local foreign ownership laws and currency export protocols.
• Review of structural compliance for international investors (including capital repatriation mechanisms and double taxation treaty considerations).

3. INVESTOR ACCREDITATION & AML/KYC COMPLIANCE

PIREIA maintains strict standards to ensure that its networking environment remains safe, compliant, and tailored to sophisticated capital allocators.

3.1. Investor Qualification Standards:

• Access to private project pitch sessions, detailed financial models, and roadshows is restricted to individuals and institutions meeting the definition of Accredited Investor, Qualified Purchaser, High-Net-Worth Individual (HNWI), Family Office, or Institutional Capital Representative under applicable laws in their home jurisdiction.
• Participants must confirm their capacity to evaluate cross-border real estate risks independently.

3.2. Anti-Money Laundering (AML) & Know Your Customer (KYC):

• Wide Wings Consultancy DMCC enforces zero tolerance for illicit financial activities in accordance with UAE Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT).
• We reserve the right to verify the identity of event attendees, platform members, and partners through standard KYC procedures, including passport/ID verification, corporate registry extracts, and source-of-wealth compliance declarations.
• Individuals or entities flagged on international sanction lists (OFAC, UN, EU, UK, UAE Local Terrorist List) are strictly prohibited from participating in any PIREIA activities.

4. INDEPENDENT DUE DILIGENCE MANDATE FOR INVESTORS

4.1. No Reliance Clause: Curation of projects by PIREIA does NOT substitute for an investor’s obligation to perform independent due diligence. Every investor participant agrees that they are solely responsible for conducting their own technical, financial, legal, structural, and tax evaluation of any opportunity presented.

4.2. Retention of Professional Advisors: We strongly mandate that all prospective investors retain independent legal counsel, certified public accountants (CPAs), and qualified financial advisors within the relevant project jurisdiction prior to executing binding agreements or transferring capital.

4.3. Forward-Looking Financial Statements: Pro-forma projections, target yields, capitalization rates, estimated Internal Rates of Return (IRR), and construction timelines provided in association presentations are forward-looking estimates submitted by project issuers. PIREIA does not guarantee these figures, and actual results may vary significantly based on market conditions.

5. CONFLICT OF INTEREST & FEES DISCLOSURE

5.1. Service Compensation: Wide Wings Consultancy DMCC receives compensation from real estate developers, issuers, and project sponsors for rendering Commercial Information Services, including campaign management, event organization, digital marketing distribution, and roadshow execution.

5.2. No Success-Fee Brokerage: As a commercial information provider, the Company does not act as a licensed financial broker, does not handle client investment funds, does not manage escrow accounts, and does not execute securities transactions on behalf of third parties.

5.3. Transparency: All commercial relationships between PIREIA and featuring developers are conducted transparently without imposing hidden fees on end investors.

6. INTELLECTUAL PROPERTY & DATA PRIVACY IN COMPLIANCE

6.1. All compliance document submissions, corporate records, and financial disclosures provided by developers or investors are handled in accordance with our Privacy Policy and UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection.

6.2. Proprietary deal documentation shared during private pitch sessions remains the strictly confidential intellectual property of the respective issuer or Wide Wings Consultancy DMCC and may not be distributed without prior written consent.

7. COMPLIANCE MODIFICATIONS AND UPDATES

Wide Wings Consultancy DMCC continuously reviews its compliance protocols to adapt to evolving legal and regulatory frameworks in the UAE, DMCC, CIS, MENA, and international financial jurisdictions. Updated policies will be published on the Platform with a revised "Last Updated" timestamp.

8. COMPLIANCE OFFICER CONTACT INFORMATION

For compliance inquiries, legal verification requests, KYC document submissions, or regulatory notices, please contact our Compliance Department at:

Wide Wings Consultancy DMCC

Attn: Legal & Compliance Department

Unit No: BA1151, DMCC Business Centre, Level No 1

Jewellery & Gemplex 3, Dubai, United Arab Emirates

Commercial License No: DMCC-870296

Licensed Activity: Commercial Information Services

Compliance Email: info@pireia.com

Website: www.pireia.com