Growesco

General Policies & Operational Framework

Operated by

Rouwad Al Tamkeen for Information Technology, Technical Solutions, Information and Communication Technology, Public Services, Marketing, Project Management, Training and Development, Organizing and Holding Exhibitions and Conferences, Agricultural Services, Real Estate Development, General Contracting, Recycling, and Environmental Services LLC.

Republic of Iraq

1

Legal Framework

Growesco operates within the legal and regulatory framework of the Republic of Iraq. The Platform is owned and managed by Rouwad Al Tamkeen LLC, a company legally registered with the Companies Registrar.

All activities on the Platform comply with:

  • Iraqi Civil Code
  • Iraqi Commercial Code
  • Central Bank of Iraq regulations (for payment processing, AML/KYC)
  • Applicable regulations governing digital platforms and online services

Growesco provides digital project participation services and does not offer any financial or investment services.

2

Nature of Services

Growesco functions as a service-based digital participation and project-management platform, specializing in:

  • Project Management & Monitoring: Digital oversight of Company-operated projects across real estate, entertainment, recycling, technology, and other sectors.
  • Opportunity Presentation: Displaying structured participation opportunities supported by verified documentation.
  • Contract Management: Preparing, managing, and notarizing Project Participation Agreements (PPAs).
  • Performance Reporting: Providing dashboards, progress updates, and final performance statements.

Growesco acts solely as the operator and manager of its projects and is not a public investment fund, securities intermediary, or financial broker.

3

Compliance Policy

Growesco follows a strict compliance framework, including:

  • KYC (Know Your Customer): Verification of participant identity through government-issued ID, address proof, and source-of-funds declaration.
  • AML (Anti-Money Laundering): Continuous monitoring of transactions in alignment with Central Bank of Iraq guidelines.
  • Documentation: Secure digital and physical archiving of all PPAs and participation records.
  • Transparency: Clear and consistent disclosure of fees, participation terms, timelines, and risks.

Growesco maintains a low-risk compliance profile as a digital service provider.

4

Risk Management Policy

Before a Project is listed on the Platform, it undergoes:

  • Feasibility assessment
  • Operational, financial, and market risk analysis
  • Evaluation of milestones and timelines

Participants are informed of:

  • Project objectives
  • Participation duration
  • Feasible performance outcomes
  • Risks including operational challenges, market factors, legal factors, and force majeure

Growesco is not responsible for risks arising from circumstances beyond its control.

5

Data Protection & Privacy Policy

Growesco ensures strong protection for all personal data collected through registration and KYC. Data is used exclusively for:

  • Identity verification
  • Contractual processing
  • Compliance purposes
  • Communication with Participants

Data is not shared with third parties unless legally required. All information is stored securely and protected through encryption and controlled access.

6

Transparency & Reporting Policy

Participants receive access to dashboards containing:

  • Project milestones and updates
  • Operational progress
  • Documentation and project records
  • Performance-Based Financial Adjustment (PBFA) summaries
  • Final project close-out statements

Annual internal reports may be generated and audited when applicable.

7

Payment & Settlement Policy

  • All payments are processed via licensed Iraqi banks or regulated payment gateways.
  • Payments are classified strictly as service fees related to Project Participation Units (PPUs).
  • Corporate bank accounts are used exclusively; no personal accounts are involved.
  • Each transaction generates a digital receipt or invoice.

Growesco does not manage pooled user funds or operate financial portfolios.

8

Dispute Resolution Policy

Disputes shall be handled according to the following sequence:

  1. Direct negotiation between the parties.
  2. Mediation through the Platform if required.
  3. Arbitration through recognized Iraqi arbitration authorities, or referral to competent Iraqi courts.

Jurisdiction: Republic of Iraq.

9

Governance & Ethical Standards

Growesco is committed to:

  • Transparency
  • Accountability
  • Responsible conduct
  • Corporate governance principles
  • Compliance with Iraqi laws and regulations

The Platform maintains no political affiliations and prioritizes ethical and lawful operations.

10

Exit & Continuity Policy

As defined in each Project’s participation terms, Growesco may provide:

  • Buy-back options for Project Participation Units (PPUs)
  • Transfer options, subject to Company approval and full KYC compliance
  • Continuity commitments to ensure project completion and issuance of final performance reports

All exit mechanisms operate strictly through the Project Participation Agreement (PPA).