Vestra Inc. ("Vestra," "we," "us," or "our") is committed to maintaining the highest standards of regulatory compliance, ethical conduct, and investor protection in all aspects of its operations. This Compliance Statement outlines Vestra's comprehensive approach to adhering to applicable laws, regulations, and industry best practices in the fractional real estate investment sector. Our commitment extends to ensuring transparency, safeguarding user data, preventing illicit activities, and fostering a secure and trustworthy investment environment for both novice and seasoned investors.

The U.S. Securities and Exchange Commission (SEC) plays a crucial role in regulating investment platforms and ensuring investor protection. For platforms dealing with fractional ownership of real estate, especially those that might be considered securities, compliance with federal securities laws, such as the Securities Act of 1933 and the Investment Company Act of 1940, is paramount. Companies like Millrose Properties, Inc., which engage in real estate financing and development, are subject to rigorous SEC oversight, including filing registration statements (e.g., Form S-11) to disclose comprehensive information about their business, financial condition, and risks to potential investors. This includes details about their operational models, such as Millrose's Homesite Option Purchase Platform (HOPP'R), and their intent to qualify as a Real Estate Investment Trust (REIT) for tax purposes. The SEC's regulations aim to ensure transparency and prevent fraud, requiring companies to provide clear and accurate information to the public.

1. Regulatory Framework and Jurisdictional Compliance Vestra operates under full compliance with all applicable investment and real estate regulations in every jurisdiction where it conducts business. Our legal and compliance teams continuously monitor changes in regulatory landscapes to ensure proactive adaptation and adherence. This includes, but is not limited to, compliance with:

1.1 Securities Laws: Depending on the nature of the fractional real estate offerings and the specific jurisdiction, Vestra assesses whether its offerings constitute "securities" under relevant securities laws (e.g., the Securities Act of 1933 in the United States. If determined to be securities, Vestra will undertake all necessary registration, disclosure, and reporting obligations with relevant regulatory bodies, such as the U.S. Securities and Exchange Commission (SEC), or operate under applicable exemptions.

1.2 Real Estate Laws: Compliance with local, state, national, and international real estate laws governing property ownership, transactions, disclosures, and property management is paramount. This includes adherence to property transfer laws, landlord-tenant regulations (where applicable for income-generating properties), and zoning ordinances.

1.3 Consumer Protection Laws: Vestra adheres to consumer protection laws designed to ensure fair practices, transparent communication, and protection against deceptive advertising or unfair terms.

1.4 Data Protection and Privacy Regulations: Vestra is committed to protecting user data in accordance with global privacy regulations such as the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant data protection frameworks. Our Privacy Policy details our data collection, usage, storage, and protection practices.

2. Know Your Customer (KYC) and Know Your Business (KYB) Protocols Vestra implements robust and dynamic KYC and KYB systems to prevent fraud, money laundering (AML), and terrorist financing (CTF). These protocols are integral to maintaining the integrity and security of our platform.

2.1 Individual Investors (KYC): All individual investors are required to complete a comprehensive KYC verification process. This typically includes:

Identity verification (e.g., government-issued ID, passport).

Proof of address (e.g., utility bill, bank statement).

Source of funds declaration.

Sanctions screening against global watchlists (e.g., OFAC, UN, EU).

Politically Exposed Person (PEP) screening.

Age verification to ensure compliance with minimum age requirements (18 years old).

2.2 Business Entities (KYB): For institutional investors or businesses listing properties, a thorough KYB process is conducted, which includes:

Verification of legal entity registration and corporate documents.

Identification of beneficial owners and key management personnel.

Sanctions and PEP screening of beneficial owners and key personnel.

Verification of business address and operational legitimacy.

2.3 Dynamic Forms and Admin Controls: Our customizable forms and robust admin controls allow for flexible and adaptive verification processes, ensuring full compliance and responsiveness to evolving regulatory requirements.

2.4 Ongoing Monitoring: Vestra conducts ongoing monitoring of user accounts and transactions to detect and report suspicious activities to relevant authorities, in accordance with AML/CTF regulations.

3. Property Due Diligence and Verification Vestra maintains a stringent due diligence process for all properties listed on the platform to ensure legitimacy, accurate representation, and compliance with legal and regulatory standards.

3.1 Ownership Verification: Only verified property owners or licensed agents are permitted to list properties. Comprehensive documentation, including title deeds, property registrations, and proof of ownership, is rigorously reviewed and verified by independent legal counsel or third-party verification services.

3.2 Legal Valuations: All listed properties must undergo independent legal valuations by certified appraisers to ensure fair market pricing and accurate investment projections. These valuations must meet Vestra's stringent listing criteria.

3.3 Regulatory Compliance of Properties: Vestra ensures that properties comply with all relevant building codes, environmental regulations, and local zoning laws. Any known encumbrances, liens, or legal disputes associated with a property are fully disclosed to potential investors.

3.4 Disclosure of Risks: Each property schema provides detailed information, including potential risks associated with the investment, market fluctuations, and specific property characteristics. Vestra is committed to transparently disclosing all material information to investors.

4. Financial Operations and Security Vestra employs advanced security measures and adheres to strict financial protocols to protect user funds and ensure the integrity of all transactions.

4.1 Secure Payment Gateways: All payment processing, including deposits and withdrawals, is conducted through secure, PCI DSS compliant payment gateways. Vestra supports various payment methods globally, including cards, wallets, mobile money, crypto, and bank transfers, with both manual and automated processing capabilities.

4.2 Fund Segregation: Investor funds are held in segregated accounts, separate from Vestra's operational funds, to ensure protection in the event of insolvency.

4.3 Anti-Money Laundering (AML) Controls: Vestra implements robust AML controls, including transaction monitoring, suspicious activity reporting (SARs), and adherence to international AML guidelines to prevent the use of the platform for illicit financial activities.

4.4 Automated and Manual Deposit/Withdrawal Management: Our system supports both automated and manual deposit and withdrawal management, allowing for flexibility while maintaining strict oversight and reconciliation processes.

4.5 Profit Distribution: Profit distributions are executed according to the terms specified in each property schema, with clear schedules (weekly, monthly, or yearly) and transparent reporting.

5. Data Security and Privacy Vestra prioritizes the security and privacy of user data through a multi-layered approach.

5.1 Encryption: The platform utilizes bank-grade encryption (e.g., TLS 1.2 or higher) for all data in transit and at rest, protecting sensitive information from unauthorized access.

5.2 Two-Factor Authentication (2FA): 2FA is mandatory for all user accounts to provide an additional layer of security against unauthorized access.

5.3 Access Controls: Strict internal access controls are in place to limit access to sensitive user data to authorized personnel only, based on the principle of least privilege.

5.4 Regular Security Audits: Vestra conducts regular security audits, penetration testing, and vulnerability assessments to identify and remediate potential security weaknesses.

5.5 Incident Response Plan: A comprehensive incident response plan is in place to address and mitigate the impact of any data breaches or security incidents promptly and effectively, with timely notification to affected users and regulatory bodies as required.

6. Transparency and Disclosure Transparency is a cornerstone of Vestra's operations. We are committed to providing clear, accurate, and comprehensive information to our users.

6.1 Clear Terms of Service and Privacy Policy: Our Terms of Service and Privacy Policy are readily accessible and clearly outline user rights, obligations, platform functionalities, and data handling practices.

6.2 Detailed Property Schemas: Each property listing includes a detailed schema providing all material information necessary for an informed investment decision, including share price, profit schedule, investment duration, and associated risks.

6.3 Performance Reporting: Vestra provides insightful reports on user activity, investment statistics, and system health, enabling investors to track their portfolio performance.

6.4 Risk Disclosures: All investment opportunities are accompanied by explicit risk disclosures, emphasizing that investments carry inherent risks and that past performance is not indicative of future results.

7. Anti-Fraud Measures Vestra employs advanced anti-fraud technologies and processes to detect and prevent fraudulent activities on the platform.

7.1 Behavioral Analytics: Monitoring user behavior for anomalies that may indicate fraudulent intent.

7.2 Transaction Monitoring: Real-time monitoring of transactions for suspicious patterns or high-risk activities.

7.3 Collaboration with Authorities: Vestra cooperates fully with law enforcement and regulatory bodies in investigations related to fraud or other illicit activities.

8. Complaint Resolution and Investor Protection Vestra is dedicated to providing excellent customer support and a fair process for resolving disputes.

8.1 Customer Support: We offer comprehensive customer support via live chat, email, and WhatsApp to assist users with inquiries, technical issues, and investment-related questions.

8.2 Dispute Resolution: In the rare event of unforeseen issues or disputes, Vestra commits to full disclosure and ensures refunds or equivalent value transfers in accordance with its investor protection policy and terms of service. Our dispute resolution process is designed to be fair, transparent, and efficient.

8.3 Investor Education: Vestra provides educational resources to help investors understand the intricacies of fractional real estate investment, associated risks, and best practices.

9. Internal Controls and Audit Vestra maintains a robust system of internal controls to ensure operational efficiency, financial reporting reliability, and compliance with laws and regulations.

9.1 Internal Audit Function: An independent internal audit function regularly assesses the effectiveness of our internal controls and compliance programs.

9.2 Employee Training: All Vestra employees receive regular training on compliance policies, ethical conduct, data security, and AML/CTF procedures.

9.3 Whistleblower Policy: Vestra maintains a whistleblower policy to encourage employees to report any suspected violations of laws, regulations, or company policies without fear of retaliation.

This Compliance Statement is a living document, subject to periodic review and updates to reflect changes in regulatory requirements, technological advancements, and business operations. Vestra is unwavering in its commitment to upholding the highest standards of compliance and integrity, thereby building and maintaining trust with our valued investors and partners.