Sanctions Compliance Policy

1. Introduction

RECYBOVER AE is committed to conducting its business in full compliance with applicable international sanctions laws and regulations. As an international trading company involved in the purchase and sale of food commodities such as seeds, grains, sugar, and other agricultural products, RECYBOVER AE recognizes the importance of ensuring that its operations do not involve sanctioned individuals, entities, or jurisdictions.

This Sanctions Compliance Policy establishes the framework through which the company identifies, assesses, and mitigates sanctions-related risks in its commercial activities.

2. Legal and Regulatory Framework

RECYBOVER AE complies with sanctions and restrictions issued by relevant international and national authorities, including but not limited to:

• the United Nations Security Council
• the UAE Financial Intelligence Unit
• relevant regulatory authorities in the United Arab Emirates

The company also aligns its compliance practices with international standards issued by the Financial Action Task Force. These sanctions programs may include restrictions related to:

• specific individuals
• companies or organizations
• vessels or transport operators
• countries or territories subject to embargoes
• financial transactions and trade activities

3. Scope of the Policy

This policy applies to all activities conducted by RECYBOVER AE, including:

• international commodity trading
• commercial negotiations and contracts
• supply chain and logistics arrangements
• financial transactions
• partnerships with suppliers, brokers, and agents

It applies to all:

• employees
• management
• consultants
• intermediaries acting on behalf of the company

4. Sanctions Risk in Commodity Trading

International commodity trading may present specific sanctions-related risks, including:

• transactions involving sanctioned jurisdictions
• counterparties acting on behalf of sanctioned entities
• vessels or shipping routes linked to restricted parties
• payments routed through sanctioned financial institutions
• the use of intermediaries to circumvent sanctions

RECYBOVER AE actively monitors these risks in order to prevent any direct or indirect involvement in restricted activities.

5. Counterparty Due Diligence

Before entering into a commercial relationship, RECYBOVER AE may conduct sanctions screening on:

• customers and buyers
• suppliers and producers
• brokers and intermediaries
• logistics providers
• shipping companies
• financial institutions involved in payments

This screening may include verification against sanctions lists issued by:

• the United Nations Security Council
• UAE regulatory authorities
• other internationally recognized sanctions programs

Where necessary, enhanced due diligence may be conducted.

6. Restricted Transactions

RECYBOVER AE strictly prohibits participation in any transaction that involves:

• sanctioned individuals or entities
• companies owned or controlled by sanctioned parties
• trade involving embargoed jurisdictions where prohibited
• financial transfers involving restricted institutions

If a potential sanctions match is identified, the company will suspend the transaction until appropriate verification is completed.

7. Monitoring and Compliance Controls

To ensure compliance with sanctions regulations, RECYBOVER AE may implement internal controls including:

• sanctions screening of counterparties
• verification of ownership structures and beneficial owners
• review of shipping documentation and trade flows
• monitoring of payment structures and financial intermediaries

The company may also request additional documentation from counterparties to confirm compliance.

8. Reporting Obligations

If RECYBOVER AE becomes aware of a potential sanctions violation or suspicious transaction, the matter may be escalated internally and, where required, reported to the appropriate authorities in the United Arab Emirates. The company cooperates fully with competent authorities in matters related to financial crime prevention.

9. Employee Responsibilities

Employees and representatives of RECYBOVER AE are expected to:

• comply with this policy
• report any potential sanctions concerns
• avoid entering into agreements that may violate sanctions regulations
• follow internal compliance procedures

Failure to comply with sanctions requirements may result in disciplinary measures and may expose individuals to legal consequences.

10. Record Keeping

RECYBOVER AE maintains appropriate records relating to:

• due diligence conducted on counterparties
• sanctions screening procedures
• documentation supporting compliance checks

These records are retained in accordance with applicable regulatory requirements.

11. Policy Review

This Sanctions Compliance Policy may be reviewed periodically to reflect updates in sanctions regimes, regulatory requirements, or changes in the company’s operational activities. Updated versions will be made available through the company’s official channels.