Entity: Stonehill Learning and Energy Systems LLC (Parent)

Principals: Stephen Vicinanza, Dr. Lynne Hartman (Co Founders)

Effective Date: March 14, 2026

1. Policy Statement

Stonehill Learning and Energy Systems LLC is committed to the highest standards of integrity. Our policy is to prohibit and actively prevent money laundering and any activity that facilitates the funding of terrorist or criminal activities. As a consultancy firm that facilitates renewable energy financing, our primary AML/KYC role is Identification, Verification, and Ethical Oversight.

2. Roles and Responsibilities

• Compliance Officers: Stephen Vicinanza and Dr. Lynne Hartman act as the designated officers responsible for reviewing regulatory background checks shared by funding sources.
• Third-Party Funding Sources: As the financial transactors, our funding partners maintain the primary Customer Identification Program (CIP) and handle all government-mandated regulatory filings (e.g., SARs).
• The Bridge Protocol: Stonehill maintains a “Dual-Review” system. No project moves to funding until both the funding source’s regulatory check and Stonehill’s internal “Background & Libel Check” are reconciled.

3. The “Stonehill Standard” Background Check

Before a project or entity is shared with a funding source, Stonehill conducts an exhaustive internal screening of the company and its key staff. This goes beyond basic criminal records to protect the Stonehill reputation from “Libel and Association Risk.”

A. Criminal & Regulatory Screening

• Global Sanctions: Checking the OFAC Specially Designated Nationals (SDN) list.
• Criminal Records: National and international criminal history (Felony/Financial Crime focus).
• Regulatory Actions: Searching SEC, FINRA, and OCC enforcement databases for past debarments or censures.

B. Libel, Reputation, and “Adverse Media” Screening

To ensure Stonehill and its subsidiaries are not tied to entities with public trust issues, we perform:

• Adverse Media Search: Scanning global news archives for allegations of fraud, environmental negligence, or unethical business practices.
• Libel/Defamation Review: Reviewing active and past civil litigation involving the entity to ensure there is no history of malicious litigation or public record of libelous behavior.

4. KYC: Know Your Client (Corporate Due Diligence)

We require every prospective project partner to submit:

1. Proof of Identity: Government-issued IDs for all beneficial owners with 25% or more equity.
2. Corporate Charter: Certified Articles of Incorporation and current business license.
3. Source of Equity: A written declaration of the initial capital source for the project.

5. Professional Recommendations & Independent Testing

To maintain the validity of this framework, Stonehill operates under the guidance of our external professional team:

Advisor	Function
Registered CPA	Conducts annual “Financial Integrity Audits” to ensure no unauthorized transactions are occurring under the Stonehill tax ID. (Determined on a rolling basis according to need)
Legal Counsel	Provides an annual “Regulatory Update” to ensure our libel and background check parameters meet current 2026 standards. (Determined according to funding source requirements)

6. Information Sharing & Confidentiality

• Receiving Data: Stonehill acknowledges that funding sources share highly sensitive regulatory background checks with Stephen Vicinanza or Dr. Lynne Hartman.
• Storage: These reports are stored in an encrypted vault ($AES-256$) and are never shared with subsidiary staff or third parties without written legal authorization.