1. SANCTIONS POLICY SUMMARY
To guarantee a sound commercial practice to Fameline Holding Group Ltd. together with its subsidiary and affiliate company Marlab Ltd, we must comply with laws of various governments and requirements of supra-national organizations, such as the United Nations and Europeans Union. The policy provides our employees, contractors and customers with guidance about the meaning of economic and trade sanctions and how to comply with them. It also outlines the key roles and responsibilities in relation to sanctions. In the jurisdiction where the Company normally carry on its operations, it is mandatory to give effect to United Nations Security Council (UNSC) sanctions, in addition to the compliance with the autonomous sanctions, such as the United States Department of Defense and Trade Control (DDTC), and the European Union- Union’s Common Foreign and Security Policy (CFSP).
2. WHAT ARE SANCTIONS?
Sanctions are tools used by governments, international organizations (such as the United Nations) and supranational bodies (such as the European Union) to: limit the adverse consequences of a situation of international concern (for example, by denying access to military or paramilitary goods, or to goods, technologies or funding that are enabling the pursuit of programs such as the proliferation of weapons of mass destruction);
Sanctions seek to influence those responsible for giving rise to a situation of international concern to modify their behavior (by motivating them to adopt different policies); and to penalize those responsible (for example, by denying access to international travel or to the international financial system). By Principle sanctions are intended to deter a range of activities, which may include providing safe sanctuary for international criminals (such as terrorists), nuclear development and abuses of fundamental human rights.
Sanctions regimes may be subject to frequent and sometimes sudden change. They can also be imposed at any time by any country, international organization or supranational body, and in general the effect is immediate.
3. POLICY APPLICATION AND EFFECTS
The implementation of this policy is supported by a set of procedures which all executives, employees and contractors are to be aware of and receive training appropriate on the relevant issue. Breaches of this policy may lead to disciplinary action, including dismissal, as well as criminal, civil or regulatory consequences if/when applicable.
4. KEY OBLIGATIONS OF THE COMPANY
Under this policy the Company aims to:
a. Implement a risk-based preventive approach, using practices that identify, manage and mitigate sanctions risk in all jurisdictions of Company’s operations.
b. Not enter or remain involved in transactions that have any connection with countries and regions which are or come to be included in the sanctions of UNSC, DDTC and/or CFSP, while international sanctions are applicable to such countries.
c. Not enter, or remain involved in, a transaction that directly or indirectly involves a sanctioned party or product.
d. Conduct customer identification and verification activities in proportion to the sanctions risk posed by that customer or product.
e. Monitor targeted customers with suspicious activity, and report such activity when it suspects this customer may be acting illegally.
f. File all reports it deems appropriate with the relevant authorities of the jurisdictions.
g. Ensure that third parties acting for the Company comply with this policy.
h. Retain all records that may be relevant to this policy for a minimum of 5 years.
5. ROLE OF COMPLIANCE OFFICER
To provide leadership, guidance, advice and give direction to promote compliance with the implementation and observance of the present policy, as well as;
To ensure effective reporting, escalation and resolution of sanctions “compliance issues”, via its local managers under the guidance of the Head of Compliance, person whom shall be responsible to collect and process all reports received from the Company’s personnel.
The Head of Compliance shall be Mr. Demetris Hadjigeorgiou as duly appointed by the Board of Directors.
For avoidance of any doubt in regard to the above mentioned procedures, I confirm that I have read and understood the present “Economic and Trade Sanctions Policy”