Compliance Statement

Last reviewed and updated: April 2026

1. Corporate Status

Tickflow Capital Limited is a private company limited by shares, incorporated under the Companies Act 2015 of Kenya. Our registration number is PVT-6Y1YWM6V. Our registered office is located in Nairobi, Kenya.

2. Regulatory Status

Tickflow Capital Limited is not regulated by the Capital Markets Authority (CMA) of Kenya or any other financial regulatory body. We operate as a trading technology and quantitative research company, not as a licensed investment advisor, fund manager, broker-dealer, or financial institution.

Our products are software tools for professional traders and researchers. They do not constitute regulated financial services under Kenyan law as defined in the Capital Markets Act or the Finance Act.

3. Data Protection Compliance

We comply with the Kenya Data Protection Act, 2019 (DPA) regarding the collection, processing, and storage of personal data. Key compliance measures include:

• Lawful basis for data processing (consent and legitimate interest)
• Data minimization and purpose limitation
• Security measures including encryption and access controls
• Data subject rights (access, correction, deletion)
• Data breach notification procedures

For international users, we comply with applicable data protection laws including GDPR for EU residents and CCPA for California residents.

4. Anti-Money Laundering (AML) & Counter-Terrorism Financing (CFT)

While not subject to AML/CFT regulations as a non-financial institution, we maintain internal policies to mitigate financial crime risk, including:

• Customer due diligence for commercial engagements
• Screening against sanctions lists
• Transaction monitoring for unusual activity
• Reporting obligations under Kenyan law

5. Know Your Customer (KYC)

For commercial relationships and product access requiring payment, we conduct appropriate KYC verification. This may include:

• Entity verification for corporate clients
• Identity verification for individual qualified investors
• Beneficial ownership identification
• Source of funds verification for larger transactions

6. Intellectual Property Compliance

All software, algorithms, and research materials produced by Tickflow Capital are original works protected by copyright and trade secret laws. We respect third-party intellectual property and use only properly licensed software and data sources.

7. Tax Compliance

Tickflow Capital Limited is registered for tax purposes in Kenya and complies with all applicable tax laws including corporate income tax, VAT (where applicable), and withholding tax obligations.

Tax obligations for our products and services may vary by jurisdiction. Customers are responsible for understanding their own tax obligations.

8. Export Control & Sanctions

Our software and services may be subject to export control laws. We do not provide services to individuals or entities on any sanctions lists maintained by the UN, EU, UK, or US governments.

9. Professional Conduct

Our employees and contractors are bound by a code of conduct that includes:

• Confidentiality and data protection obligations
• Conflict of interest disclosure
• Prohibition on insider trading using non-public information
• Ethical research and development practices

10. Record Keeping

We maintain records as required by Kenyan law, including:

• Company registers (members, directors, charges)
• Financial records (minimum 7 years)
• Data processing records (as required by DPA)
• Transaction and audit logs for our platforms

11. Regulatory Filings

Tickflow Capital Limited files annual returns with the Kenyan Registrar of Companies as required by the Companies Act 2015. Our financial statements are prepared in accordance with applicable accounting standards.

12. Compliance Contact

For compliance-related inquiries, please contact us at info.tickflowcapital@gmail.com. For legal process or regulatory inquiries, please direct correspondence to our registered office in Nairobi.

---

Acknowledgment: This Compliance Statement is provided for informational purposes and does not constitute legal advice. You should consult with qualified legal counsel regarding your specific compliance obligations.