Anti-Fraud Policy

BACKPACK, LLC ANTI-FRAUD POLICY

Backpack LLC ("Backpack") is prohibited from engaging in or permitting fraudulent activity. Infurtherance of this goal, Backpack takes reasonable steps to detect and prevent fraud, includingby establishing and maintaining this Anti-Fraud Policy. This Backpack Anti-Fraud Policyincludes: (1) the identification and assessment of fraud; (2) procedures and controls to protectagainst and prevent identified risks; and (3) allocation of responsibility for monitoring, detecting,and reporting on risks. Backpack also takes steps to provide education to users relating to fraudand fraudulent activities. Backpack has effective processes to identify and manage fraud risks as well as effective internalcontrol mechanisms to protect against those risks. This Backpack Anti-Fraud Policy is anoverview of the systems and controls in place that:

  1. Identify fraud risks wherever they arise in its activities;
  2. Measure and control the different types of risk;
  3. Allocate responsibility for risk management to persons with appropriate knowledge and expertise;
  4. Provide sufficient, reliable information to key individuals

Backpack recognizes that fraud risks are continually evolving as fraudsters execute new novelschemes. Fraud may be defined as any act that for gain uses deception as its principal method ofoperation. For the purposes of the Backpack Anti-Fraud Policy, “fraud” may include, but is notlimited to:

  1. Manipulation of trading markets or other violative or disruptive trading practices;
  2. Manipulation, falsification or alteration of records or documents;
  3. Misappropriation of assets such as fiat currency or digital assets;
  4. Bribery and corruption;
  5. Usurpation of corporate interests for personal gain;
  6. Payment or receipts of bribes, kickbacks or other inappropriate payments; and
  7. Identity theft or fraud as further described below.

The following is a non-exhaustive list of identity fraud risks or methods of identity fraud:

Identifying Fraudulent Transactions

Fraudulent activity may be identified from a variety of sources including system alerts,complaints, and personnel referrals. Once identified, the potentially fraudulent activity will beinvestigated and, if determined to be true fraud, addressed.

Investigations

If the investigation substantiates fraudulent activities, Backpack will determine appropriateaction to take, based on the nature of the identified fraud. Decisions to report or refer theinvestigation results to the appropriate law enforcement and/or regulatory agencies will be madein conjunction with Legal Counsel.

If during the course of the investigation, evidence of other potential money laundering orfinancial crimes is uncovered, the case will be escalated for further investigation and disposition.Investigations into potentially fraudulent activity, including those that may involve an employeeof Backpack, are to be conducted without regard to the suspected wrongdoer’s length of service,position/title, or relationship to Backpack.

Terminating and Divesting Relationships

If an investigation results in a recommendation to terminate and divest an end-user relationship, the recommendation will be reviewed for approval by the designated Compliance personnel.Legal Counsel may also be consulted before any such action is taken.

Support & Fraud Prevention Education

Upon the conclusion of an investigation into an instance of fraud, whether committed by aParticipant or an employee of Backpack, and such investigation finds fraudulent activity, a conclusion report or summary will be sent to applicable regulatory authorities.

We encourage all fraud victims to report fraud to relevant regulatory authorities.

If you believe you have been the victim of fraud, please contact Backpack at: info@mybackpack.app