Sanctions compliance policy

Definitions

"Sanctioned Country" refers to any country, state, territory, or region subject to comprehensive sanctions imposed by the United Nations, European Union, United Kingdom, United States of America, or any other applicable competent authority or government. "Sanctioned Party" means any person, entity, body, or vessel designated by a sanctioning authority as subject to sanctions.

The company reserves the right to interpret these definitions in accordance with its risk assessment and legal counsel's advice.

Prohibition of transactions

The company prohibits transactions with Sanctioned Countries or Parties to the extent required by applicable laws. The company shall not, directly or indirectly, sell, supply, transfer, or export any products, goods, or services to or for the benefit of any Sanctioned Country or Sanctioned Party, or for any use, purpose, or activity prohibited under applicable sanctions laws or regulations.

We retain discretion to engage in permissible transactions where legally allowed and aligned with our business interests.

Compliance procedures

We implement risk-based compliance procedures, which may include:

• Screening customers and transactions against relevant sanctions lists
• Conducting appropriate due diligence
• Periodic review and update of compliance procedures
• Monitoring sanctions regime changes
• Risk assessments as deemed necessary
• Adapting processes based on business needs and risk profile

Reporting

Employees are encouraged to report suspected compliance issues through appropriate channels. The company shall address such reports in accordance with internal policies and legal requirements and deny such purchases.

Ongoing compliance

We strive to comply with applicable sanctions laws, subject to permissible exceptions and interpretations that serve our business interests.

Certification and audits

Upon reasonable request and subject to confidentiality agreements, we may provide appropriate assurances of our sanctions compliance efforts. Any audits will be conducted in a manner that protects our proprietary information and business interests.

Supply chain due diligence

We exercise risk-based due diligence in our supply chain and business relationships, balancing compliance obligations with operational efficiency.

Record keeping

We maintain records as required by applicable laws, while preserving our right to determine the scope and format of such records.

Training

Relevant employees receive appropriate training on sanctions compliance, tailored to their roles and our business needs.

This policy is integral to our operations and shall survive any termination or expiration of any business agreements. This policy is subject to change at the company's discretion. It shall be interpreted in a manner that best protects the company's interests while maintaining compliance with mandatory legal requirements.