Anti Money Laundering (AML)

It is the Policy of TMP Software, Inc. and its affiliates (hereinafter referred to as “the Company”) to

prohibit and actively pursue the prevention of money laundering and any activity that facilitates

money laundering or the funding of terrorist or criminal activities. The Company requires its officers,

employees, and affiliates to adhere to these standards in preventing the use of its products and

services for money laundering purposes.

For the purposes of this Policy, money laundering is generally defined as engaging in acts designed

to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds

appear to have been derived from legitimate origins or constitute legitimate assets.

Generally, money laundering occurs in three stages. Cash first enters the financial system at the

“placement” stage, where the cash generated from criminal activities is converted into monetary

instruments or deposited into accounts at financial institutions. At the “layering” stage, the funds are

transferred or moved into other accounts or other financial institutions to further separate the money

from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and

used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal

the origin or intended use of the funds, which will later be used for criminal purposes.

Each employee of the Company, whose duties are associated with the provision of products and

services of the Company and who directly or indirectly deals with the clientele of the Company, is

expected to know the requirements of the applicable laws and regulations which affect his or her job

responsibilities, and it shall be the affirmative duty of such employee to carry out these

responsibilities at all times in a manner that complies with the requirements of the relevant laws and

regulations.

The laws and regulations include, but not limited to: “Customer Due Diligence for Banks” (2001) and

“General Guide to Account Opening and Customer Identification” (2003) of Basel Committee on

Banking Supervision, Forty Recommendations for Money Laundering of FATF, USA Patriot Act

(2001), Prevention and Suppression of Money Laundering Activities Law (1996).

To ensure that this general policy is carried out, management of the Company has established and

maintains an ongoing program for the purpose of assuring compliance with the relevant laws and

regulations and the prevention of money laundering. This program seeks to coordinate the specific

regulatory requirements throughout the group within a consolidated framework in order to effectively

manage the group’s risk of exposure to money laundering and terrorist financing across all business

units, functions, and legal entities.

Each of the affiliates of the Company is required to comply with AML.

All identification documents and services records shall be kept for the minimum period of time

required by local law.

All new employees shall receive anti-money laundering training as part of the mandatory new-hire

training program. All applicable employees are also required to complete AML training

annually. Participation in additional targeted training programs is required for all employees with

day-to-day AML responsibilities.