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Envea (“Envea” or the “Group”) is committed to conducting its business in compliance with applicable sanctions and export control laws and regulations. This Trade Compliance Policy (the “Policy”) and the internal controls herein have been designed to prevent violations of potentially applicable sanctions and export control laws and regulations, including those administered by the European Union and its member states, United Kingdom and United States (collectively, “Trade Compliance Laws”). The Policy is applicable to all directors, officers, employees, agents, representatives and other associated persons of Envea (collectively “Group Personnel”).  This Policy applies in addition to any business-unit specific policies that are in place.

Group Personnel must conduct their activities in full compliance with this Policy and all applicable Trade Compliance Laws.  Group Personnel who violate this Policy shall be subject to appropriate and proportionate disciplinary action, up to and including termination.  Any Group Personnel who have any questions concerning the requirements of this Policy should consult with the Designated Officer.[1]

[1] A complete list of Designated Officers and corresponding responsibilities is included in Appendix A of the Envea Code of Conduct.

  1. Embargoed Countries

    Under this Policy, Group Personnel are not permitted to engage in or facilitate any business or dealings, directly or indirectly with Cuba, the Crimea region of Ukraine, Iran, North Korea, or Syria (each an “Embargoed Country”) or a person domiciled in or an entity that is located in or organized under the laws of an Embargoed Country. Engagements with an Embargoed Country must be pre-approved by the Designated Officer, however such engagements are presumed prohibited and approval is unlikely to be granted. A current list of Embargoed Countries is included in Appendix A.

  2. High-Risk Countries

    Under this Policy, engagements with Russia, Myanmar, Venezuela, and Belarus (each a “High-Risk Country”) may be permitted but must be pre-approved by the Designated Officer. A current list of High-Risk Countries or countries subject of at least one type of EU, UK, or U.S. sanctions program is included in Appendix A.

  3. Blocked Persons and Third-Party Screening

    Under this Policy, Personnel are prohibited from engaging in or facilitating any business or dealings, directly or indirectly (e.g., through a third-party intermediary) with any person included on the list of sanctioned parties maintained by:

    • The European Commission, including the Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions (available at https://ec.europa.eu/external_relations/cfsp/sanctions/list/version4/global/global.xml);
    • The United States, Office of Foreign Assets Control, including:
      • the SDN List (available at https://sanctionssearch.ofac.treas.gov/),
      • the Foreign Sanctions Evaders List (available at https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list-non-sdn-lists/foreign-sanctions-evaders-fse-list), and
      • the Sectoral Sanctions Identifications List, (available at https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list-non-sdn-lists/sectoral-sanctions-identifications-ssi-list);
    • The United States, U.S. Department of Commerce, including:
      • the U.S. Denied Persons List (available at https://www.bis.doc.gov/index.php/the-denied-persons-list),
      • the U.S. Entity List (available at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list), and
      • the U.S. Unverified List (available at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/unverified-list);
    • The United Kingdom, including the Consolidated List of Financial Sanctions Targets in the United Kingdom (available at https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets; or
    • Similar lists of sanctioned parties maintained by other applicable governmental entities (including France or other EU member states in which the Group operates) (collectively, “Blocked Persons”).

    This Policy prohibits Group Personnel from engaging in direct and indirect business on behalf of Envea with Blocked Persons unless pre-approved by the Designated Officer. Furthermore, Group Personnel are also prohibited from engaging in or facilitating any business or dealings, directly or indirectly (e.g., through a third-party intermediary) with any person that is owned or controlled by, or acting on behalf of, any Blocked Person.

    To ensure compliance with this Policy, Envea, as part of Envea’s Third-Party Diligence Policy, will screen suppliers, service providers, and third-party intermediaries against restricted party lists prior to initial engagement and on a periodic basis. Any possible hits must be reviewed and cleared by the Designated Officer.

  4. Diversion Risk

    Group Personnel and third-party intermediaries must also stay alert to “red flags” suggesting that a counterparty might seek to divert Envea products to High-Risk Countries or Blocked Persons. Under some sanctions regimes, individuals and entities can face liability if it engages in a transaction and fails to monitor for “red flags” suggesting diversion is likely, even if that individual or entity has no knowledge that diversion will occur. Accordingly, and to avoid such transactions, all Group Personnel are expected to be alert for suspicious activity, to halt potential transactions when any suspicions arise, and to contact the Designated Officer for further guidance if uncertainty exists. “Red flags” warranting follow-up include:

    • A business partner is associated with a High-Risk Country (g., the partner’s website suggests that they do business with one or more High-Risk Countries).
    • The business partner is evasive regarding the destination or ultimate end user of goods or services, or requests that goods be shipped in an unusual fashion (g., to a P.O. box or other anonymous location).
    • The terms of sale are unusual, or the customer requests that the payment be made in a non-transparent fashion.
    • The end user’s name is similar to, or the same as, an entity or individual targeted by list-based sanctions.

    In considering potential diversion risk, Group Personnel and third-party intermediaries should be particularly alert to touch points with the countries listed in Appendix A.

  5. EU & UK Blocking Statutes

    As a result of U.S. investment in Envea, certain OFAC sanctions (e.g., OFAC sanctions targeting Cuba and Iran) could apply to the Group’s business dealings in certain circumstances, even when such dealings do not involve the United States or U.S. individuals or entities. Furthermore, certain U.S. sanctions could apply to the Group regardless of U.S. investment. In particular, U.S. sanctions can target non-U.S. entities for engaging in certain dealings with China/Hong Kong, Iran, North Korea, Russia, Turkey, Myanmar, Belarus, and Venezuela.

    The EU has adopted Council Regulation 2271/96 (as amended by the Commission Delegated Regulation 2018/1100) (the “Blocking Statute”) with the purpose of prohibiting EU persons from complying with certain U.S. sanctions laws targeting non-U.S. persons’ dealings with Cuba and Iran.
    Under certain circumstances, Envea’s obligations under the Blocking Statute (or equivalent laws adopted by EU Member States or the United Kingdom) could come into conflict with certain extra-territorial U.S. sanctions that are designed to apply to non-U.S. persons’ dealings with Cuba and Iran.

    If Group Personnel suspect that a proposed transaction, dealing or course of conduct by Envea or Group Personnel could place Envea in conflict with either the Blocking Statute (or equivalent laws) or extra-territorial U.S. sanctions on Cuba or Iran, Group Personnel must immediately bring the matter to the attention of the Designated Officer. No further action must be taken on the matter unless the action has been pre-approved by the Designated Officer.

The Group may be subject to EU, UK, and U.S. export control laws as well as the export control laws of other countries in which Envea does business.  Export control laws regulate the transfer of items and technology across borders, the disclosure of controlled technology to foreign nationals, and the retransfer of an item from one foreign country to another foreign country.

Group Personnel must inform the Designated Officer without delay if they suspect that the Group’s dealings with third parties may involve items or technology controlled under applicable export controls.  No further action must be taken on the matter unless the action has been pre-approved by the Designated Officer.

To minimize the risk that third-party intermediaries enter into transactions, including transactions that involved the onward sale or distribution of Envea products, all engagements with third parties should comply with the Envea Third-Party Diligence Policy, and contracts with third-party intermediaries should include language prohibiting violations of Trade Compliance Laws (as per the Third-Party Due Diligence Policy).

For sales made on a purchase order or similar basis, the following language should be included in the invoice and any order confirmation communications:

“By accepting these goods, you agree not to give, sell, or otherwise distribute these products, directly or indirectly, (1) to any party located, organized under the laws of, or ordinarily resident in a country or territory subject to comprehensive OFAC sanctions, (2) to any party located, organized under the laws of, or ordinarily resident in a country or territory subject to partial or industry-based OFAC sanctions, or (3) to any individual, entity, or other end user subject to sanctions imposed by the United States, European Union or its Member States, or United Kingdom.”

Any deviations to the language contained in this Policy or the standard templates for third-party engagements must be pre-approved by the Designated Officer. Specifically, the removal of Russia, Myanmar, Venezuela, and/or Belarus from the standard purchase order language is only permissible with pre-approval from the Designated Officer.

Select Group Personnel shall receive and review a copy of this Policy. Envea will provide periodic training programs or modules to educate select Group Personnel about the requirements and obligations of Trade Compliance Laws and this Policy.  Select Group Personnel must participate in this training when required and the Designated Officer will retain attendance and/or completion records establishing compliance with this requirement.

Group Personnel must report misconduct or suspicion of misconduct. Guidance on reporting misconduct is provided in the Envea Speak Up Policy.

All questions regarding this Policy should be directed to the Designated Officer.

Embargoed Countries

Crimea North Korea
Cuba Syria
Iran Venezuela
Belarus Russia

High-Risk Countries

Myanmar Venezuela

Other Countries Subject to U.S./UK/EU Sanctions

Afghanistan Lebanon
Balkans Liberia
Bosnia & Herzegovina Libya
Burundi Mali
Central African Republic Moldova
China Montenegro
Democratic Republic of the Congo Nicaragua
Cote d’Ivoire Serbia
Egypt Somalia
Eritrea South Sudan
Ethiopia Sudan
Guinea Tunisia
Guinea Bissau Turkey
Haiti Ukraine
Hong Kong Yemen
Iraq Zimbabwe

² As of May 31, 2023