53_ Política de sanciones internacionales_1_2023

Compliance Policy for International Sanctions imposed on third parties

Reference

53 _ International sanctions policy _ 1 _ 2023

Title of the Regulation

Compliance Policy for International Sanctions

mposed on

hird

parties

Geographical scope

Global

Category

Policy

Date approved

27 February 2023

Approved by

Board of Directors

Current version

Important information about this document

Document identification

Compliance Policy for International Sanctions Imposed

on third parties

Reference

53 _ International sanctions policy _ 1 _ 2023

Geographical scope Global

Section of other Regulations it implements

Regulations it replaces

Regulations it repeals

Main body responsible for oversight Audit Committee

Proposing body or department Compliance Committee

Drawn up by Compliance Committee

Approved by Board of Directors

Current text approval date 27 February 2023

Date of application 27 February 2023

Published and accessible Online and on the Intranet

Change Control

Version Date Approved by Drawn up by Summary of changes

1 27 February

2023

Board of Directors Compliance Committee

Contents

1. Introduction ............................................................................................................ 4

2. Scope .................................................................................................................... 5

2.1 Territorial ............................................................................................................. 5

2.2 Subjective ............................................................................................................ 5

2.3 Framework regulations (benchmarks) ................................................................. 5

3. Objectives and scope............................................................................................. 5

4. Core principles ....................................................................................................... 6

5. Due diligence, filtering, and authorisation............................................................... 6

5.1 Introduction ......................................................................................................... 6

5.2 Due Diligence ...................................................................................................... 7

5.3 Filtering obligations ............................................................................................. 7

5.3.1 Filtering obligations for new Business Partners ............................................. 7

5.3.2 Continuous filtering obligations ..................................................................... 8

5.4 Authorisation procedure ...................................................................................... 8

5.4.1 If the Due Diligence and filtering procedure is positive .................................. 8

5.4.2 If the Due Diligence and filtering procedure is negative ................................. 9

6. Statement of Compliance ....................................................................................... 9

7. Supervision, communication, and training .............................................................. 9

8. Monitoring, evaluation, and review ....................................................................... 10

9. Archiving and controlling documentation .............................................................. 11

10. Communication of conduct and investigation ....................................................... 11

11. Understanding and declaration of agreement ...................................................... 12

12. Consequences of non-compliance ....................................................................... 12

Annex I: Concept of international sanctions ................................................................ 14

Annex II: Information and documentation required for the due diligence procedure .... 16

Annex III: Questionnaire on exposure to international sanctions ................................. 17

1. Introduction

ACS Actividades de Construccion y Servicios, S.A. and its group of companies

('ACS' or ‘the Organisation') are firmly committed to complying with all applicable

laws and standards in all the territories in which it operates, based on the spirit and

purpose thereof, and observing ethical behaviour in all our actions.

ACS has defined a corporate model based on the values of Integrity, Excellence,

Trust, Sustainability, and Profitability, observing at all times conduct aligned with

our values, rooted in our firm conviction regarding the benefits of such conduct.

ACS considers integrity to be the Group's foremost value. We demand integrity by

promoting and recognising behaviour amongst our people in accordance with

ethics and compliance with laws and standards, regardless of the post held and

the Group company where they work. We believe that it all begins with strict

compliance with internal and external regulations and standards, based on the

spirit and purpose thereof, and observing ethical behaviour in all our actions.

In accordance with the principle of Integrity included in our Code of Conduct, ACS

Group companies must not only ensure the correct application of different

regulations on international transactions, but also consider any restrictions or

embargoes on certain persons, organisations or countries, which may affect them,

issued by countries and international platforms. For this purpose, they will pay

special attention to possible payments made by third parties as a way of

circumventing international restrictions or embargoes, since this may represent a

potential infringement of these limitations.

Therefore, any breach of International Sanctions defined in Annex I ('International

Sanctions') is one of the risks against which the Group protects itself by adopting

internal procedures.

Failure to comply with regulations on International Sanctions may expose ACS

Group companies, and executives and employees individually, to civil, regulatory,

and criminal sanctions, including significant economic fines and/or custodial

sentences. In addition, any conduct contrary to regulations on International

Sanctions will constitute a breach of ACS Group values, which will not be tolerated.

Consequently, in compliance with the sanctions applicable to the ACS Group and

adopted by the EU, any individual EU State, the United Kingdom, the UN, the US

and any other sanctioning authority of a country in which the ACS Group operates

or has or may have any type of interest, the Group will refrain from performing any

business that infringes International Sanctions.

To this end, ACS has developed a specific policy that, in line with the Code of

Conduct, the General Risk Control and Management Policy, the General

Compliance Policy, and the rest of the Global Compliance Management System,

provides general guidelines to support the Organisation's efforts to comply with

international regulations on International Sanctions and to end any conduct that

does not comply as soon as reasonably possible after its discovery (the 'Policy').

2. Scope

2.1 Territorial

This Policy is mandatory and applies globally to the whole Organisation.

2.2 Subjective

All ACS members must comply with its content, regardless of their position and the

territory in which they are located, unless the applicable legislation in the territory

in which they operate establishes stricter provisions, which must prevail over this

Policy.

This Policy may be fully or partially extended to business partners, in accordance

with the specific circumstances of each individual case.

2.3 Framework regulations (benchmarks)

This Policy must be interpreted in the context of the following ACS Regulations,

and in accordance with the law applicable to ACS:

 ACS Code of Conduct.

 Code of Conduct for Business Partners

 Internal and External Due Diligence Procedures.

 General Compliance Policy.

 Risk Management and Control Policy.

 The Structural Document regulating the Global Compliance Management

System.

3. Objectives and scope

The purpose of this Policy is to establish a regulatory framework for International

Sanctions for all scenarios in which ACS may be involved in the performance of its

business activities and to establish an authorisation procedure that allows ACS to

maintain control of all relationships with third parties (as defined below) and those

responsible for these processes.

ACS also aims to protect entities within the ACS Group from being involved in

commercial activities with third parties such as employees, commercial providers,

financial providers, agents, distributors and investors ('Third Party' or 'Third

Parties') that may be subject to international sanctions. This includes obligations

acquired under trade sanctions legislation, and a description of the internal

organisation in relation to International Sanctions, and the consequences of

breaching this Policy.

International Sanctions are directed against activities, countries, organisations, or

individuals included on certain lists. This Policy requires, as a general rule, that all

potential business partners or any new activities or businesses to be performed by

ACS be cross-checked against the corresponding International Sanctions lists

before establishing a commercial relationship with them and regularly supervised

during the course of the commercial relationship.

This Policy does not provide detailed guidance on the specific restrictions that exist

under different national sanctions regimes, or the extent to which licences or

authorisations are available to perform activities prohibited by international

sanctions.

4. Core principles

The policy's guiding principles are as follows:

1. Comply with current legislation and internal regulations, acting in accordance

with values and the Code of Conduct.

2. Provide the human and material resources required for this Policy to be

enforced efficiently, and to implement methods for preventing and detecting

illegal actions.

3. Implement models for monitoring and preventing undue conduct in relation to

international sanctions regulations for all companies that are part of the ACS

Group.

4. Analyse and investigate, as swiftly as possible and in accordance with the ACS

Whistleblower Channel Operation Policy and the Complaints and Breach

Investigation Procedure in ACS, any complaint regarding conduct that is

contrary to this Policy.

5. Collaborate and cooperate with State Security Forces and Bodies and with

any judicial or administrative body in relation to the investigation of alleged

infringements by members of the Organisation.

6. Provide adequate ongoing training, either face-to-face or via e-learning, to all

ACS directors, executives and employees, with special emphasis on

obligations related to International Sanctions.

7. Impose the appropriate disciplinary measures on the persons responsible for

any breach of this Policy, and those who, with their conduct, obstruct or

hamper the investigation or clarification of the alleged infringements, all in

accordance with the Compliance Disciplinary System and applicable

sanctions.

5. Due diligence, filtering, and authorisation

5.1 Introduction

Due diligence and selection obligations are established to help identify restricted

persons and organisations, and the restricted activities to which ACS may be

exposed. These obligations help identify areas of potential risk in relation to

International Sanctions and help make risk decisions that are within the framework

of the organisation's strategy.

It is important for all members of the Organisation to be aware that any goods or

services provided to or by ACS that may be linked to restricted or sanctioned

persons or entities may pose a threat to ACS' reputation and give rise to the

relevant responsibilities, economic sanctions, embargoes, or disqualification from

operating or trading.

5.2 Due Diligence

Before entering into a contract with any third party, it is mandatory to perform a due

diligence process to obtain the information/documentation included in Annex II of

this Policy, in addition to the Internal and External Due Diligence Procedure. In

addition, the Third Party must duly complete the questionnaire regarding exposure

to International Sanctions included in Annex III. With this questionnaire, ACS

intends to obtain additional information as regards any relationship or connexion

of the Third Party with any activity, country, organisation, entity or persons affected

by International Sanctions to the extent that this may entail a risk for ACS business.

Steps must be taken to ensure that all information and documentation obtained on

the Third Party and the goods or services to be provided to the Group is adequate

and accurate.

All information and documentation obtained from the Third Party, and the

questionnaire regarding exposure to International Sanctions, must be stored as

detailed in the clause on archiving and controlling documentation set out within this

Policy, and with full respect for the procedure for archiving and controlling

documented information. The person in charge of performing the transaction or

responsible for the commercial relationship with the Third Party ('Responsible

Person') is responsible for performing all tasks related to the due diligence process

and ensuring that the questionnaire regarding exposure to International Sanctions

is duly completed by the Third Party. ACS must have a database with all this

information.

The Compliance Committee will at all times monitor the actions of the Responsible

Person, who must duly report their action in accordance with this Policy.

Any other documentation or information in addition to the above may be requested

if it is considered relevant or applicable.

5.3 Filtering obligations

5.3.1 Filtering obligations for new Business Partners

Once the due diligence process has been completed, and before signing a contract

with the Third Party or initiating any kind of relationship, a selection process will be

performed to reduce or eliminate the risk of breaching International Sanctions.

The Responsible Person must collate the data from the documentation/information

collected with the International Sanctions lists by means of the computer tool

designated for that purpose.

If the Third Party, its activities or its commercial or professional partners are not

included on the International Sanctions lists, as defined in Annex I, they will be

considered a 'secure party', and the transaction will be authorised in accordance

with section 5.4.1 of this Policy.

However, if the Third Party is included on the International Sanctions lists or has

commercial or professional ties with any activity, entity, organisation or person

included on the International Sanctions lists, the transaction must be authorised in

accordance with the authorisation process in section 5.4.2. All employees must do

everything possible to ensure - taking into account the risks - that any agreement

signed by ACS contains a description of the services to be provided and adequate

wording to guarantee compliance with International Sanctions in a manner

consistent with this Policy.

A report with the results of the selection process must be kept with all the

information resulting from the due diligence process as described in section 5.2

above and in the documentation archiving and control clause of this Policy, and

with full respect for the procedure for archiving and controlling documented

information.

5.3.2 Continuous filtering obligations

If the Organisation maintains a continuous commercial relationship with a Third

Party, the Responsible Person must perform a periodic review process in addition

to the initial scrutiny indicated in section 5.3.1 above and update the ACS database

with any new information about the Third Party. Specifically, the name and key

details must be reviewed and, if necessary, added to or updated, and the Third

Party must be cross-checked with the sanctions lists by means of the computer

tool used by ACS based on the new information obtained.

This additional control will take place:

 before each contract renewal;

 when ACS becomes aware of changes in the information contained in Annex

II; and

 at least, once a year.

5.4 Authorisation procedure

5.4.1 If the Due Diligence and filtering procedure is positive

If no risk is identified in accordance with section 5.3 above, the authorisation

procedure for new third parties will be performed as follows:

- Once the due diligence and selection process has concluded, the Responsible

Person must ensure that all the information required by this Policy has been

collected.

- After this review, the Responsible Person will notify the Compliance

Committee, if the process has been duly completed, and the latter will

determine whether the operation can be performed or whether, conversely,

any additional information is required to complete the due diligence and

selection process.

The Responsible Person must prepare a half-yearly report that will include at least

a list of authorised transactions identifying the Third Party involved, and all details

of the due diligence, selection, and authorisation process followed.

The report will be sent to the Compliance Committee for its information and

acknowledgement.

5.4.2 If the Due Diligence and filtering procedure is negative

If a risk or a potential risk is identified, the Responsible Person must immediately

notify the Compliance Committee, which will make enquiries as required to

determine whether the relationship, agreement, or transaction with the Third Party

is permitted or not in accordance with International Sanctions.

The Compliance Committee will therefore prepare a report outlining the main

aspects of the proposed authorisation, or the reasons why authorisation should be

denied and no commercial relationship with that Third Party should be maintained.

To prepare its report, the Compliance Committee will assess the level of risk

entailed by the transaction with the Third Party, and may require the Responsible

Person to provide additional information on the Third Party. As a result of this

analysis, the transaction may be approved directly by the Compliance Committee

or, if considered necessary, it may be submitted to the Audit Committee for review.

The Audit Committee will analyse all information relating to the transaction and will

inform the ACS Board of Directors to approve or reject the transaction.

Once the transaction has been approved by the ACS Board of Directors, the

Compliance Committee will inform the Responsible Person.

Once the transaction with the Third Party has been authorised, the name and key

details of the Third Party must be included in the ACS database for Third Party

contracts.

6. Statement of Compliance

Each contract or operation performed by ACS with Third Parties must contain a

signed copy of the statement of compliance contained in the ACS Code of Conduct

for Business Partners.

The statement of compliance may be adapted to each case or transaction, and

more restrictive clauses may be added, but in no case may its scope of application

be reduced, nor may its main content be modified if by doing so its purpose is

distorted.

Any questions regarding the statement of compliance must be addressed to the

Compliance Committee.

7. Supervision, communication, and training

The Compliance Committee is responsible for enforcing this Policy, ensuring

compliance and controlling its effectiveness.

ACS will provide adequate training on the applicability of the Policy.

Therefore, all employees will receive training in relation to this Policy, which must

include at least the following:

- Regulations relating to international sanctions.

- This Policy and any other specific procedures that may be approved.

- Risk identification.

- Prevention of sanctions risk.

- Sanctions risk management.

- How to mitigate sanctions risk.

New employees will receive training as part of their induction. Training will be

provided at least once a year or whenever there is a substantial change in

legislation or in this policy.

Records will be kept of all members who have received training on this Policy and

sanctions risk.

Any questions regarding this Policy should be directed to the Compliance

Committee.

8. Monitoring, evaluation, and review

To ensure that the Policy is kept up-to-date and reflects the reality of ACS and all

changes in the applicable regulations, this Policy will be reviewed periodically, at

least once a year.

The Compliance Committee will be responsible for reviewing and updating this

Policy.

The Compliance Committee will prepare an annual report informing the Audit

Committee of the level of compliance achieved by ACS as regards this Policy, and

providing information on the training received by ACS employees in this area. The

annual report will also include any anomalies detected by the Compliance

Committee and any amendments to this Policy.

The ACS Compliance Committee is responsible for assessing sanctions risks for

the organisation and will ensure that the risk assessment is reviewed at least once

a year. Further reviews may also be conducted whenever appropriate in

accordance with the circumstances.

Risk audits and assessments must be performed to monitor compliance with and

the effectiveness of this policy. These reviews will also aim to identify any

anomalies or problems that may arise as regards compliance with this Policy and

the degree of training provided to employees to mitigate the potential risk of

International Sanctions.

The results obtained will be used to help identify and implement adequate systems

and controls to mitigate and/or resolve any potential or actual risks identified.

9. Archiving and controlling documentation

Archiving and controlling any documentation generated and obtained in relation to

the application of this Policy will be performed in accordance with the Procedure

for archiving and controlling documented information.

Any information required in the future in relation to this Policy or its compliance will

be duly archived. The Compliance Committee will also keep records of any

information related to Third Parties such as suppliers, customers, and/or

employees that has been requested or obtained during the due diligence,

selection, or authorisation procedure, and the refusal, suspension, or termination

of the commercial relationship.

ACS will keep these records for the duration of the relationship with Third Parties

and for at least five years after the relationship ends. The Compliance Committee

may increase this period if deemed appropriate.

10. Communication of conduct and investigation

All members of the Organisation have the obligation to report individual or

collective behaviour or activities that occur in the context of their activities within

the Organisation and which may involve a breach of the contents of this Policy,

regardless of whether such behaviour has been ordered or requested by a

superior.

For this Policy to be effectively applied, and with the aim of obtaining an immediate

response by ACS when it becomes aware of potential breaches of the Global

Compliance Management System, ACS has implemented the Company's

Whistleblowing Channel (“Whistleblowing Channel”), which is in line with current

national and EU regulations, and with best market practices. The Whistleblowing

Channel allows for various forms of communication, which operate in a

professional and confidential manner. These means of communication allow

potential whistleblowers to report events that represent a violation of the system to

the ACS personnel designated for this purpose. ACS guarantees the confidentiality

and protection of the whistleblower.

Any complaint included in this Policy may be submitted through one of the channels

detailed below, which are included in the ACS Whistleblowing Channel Operating

Policy:

a) Ordinary Channels:

1. Direct supervisor or a member of ACS management;

2. Compliance Committee member;

3. The Regulatory Compliance Department.

4. By post:

FAO: Canal Ético Grupo ACS

Avda. Pío XII 102, 28036 Madrid, Spain.

b) b) Alternative Channels: The following 'Alternative Channels' are also

available:

5. Online channels accessible through the website www.grupoacs.com

Whistleblower Channel - Compliance - ACS Group

If a breach of International Sanctions is suspected, the Compliance Committee will

conduct an investigation in which:

The investigation must approached as follows:

1. Identify which area or department may be affected.

2. Compile all information in relation to the transaction and, in particular, verify

whether due diligence and selection processes have been correctly

performed.

3. If the suspected breach is confirmed, identify its cause.

4. Prepare recommendations on the corrective measures to be taken to tackle

the breach or mitigate its possible adverse effects and prevent the same or a

similar breach from occurring in the future.

Once the investigation has concluded, the Compliance Committee will prepare a

report outlining the facts related to the breach and its recommendations on

corrective measures. A copy of that report will be sent to the Audit Committee.

In the case of special risk situations, the Audit Committee will inform the ACS Board

of Directors to take appropriate action.

11. Understanding and declaration of agreement

This Policy is provided and made available to all Members of the Organisation on

the corporate Intranet. ACS will also make this Policy available to its Business

Partners on its corporate website www.grupoacs.com.

The Compliance Committee will ensure that all ACS members are familiar with and

aware of this policy and annually confirm their knowledge and understanding of it.

Any Business Partners with which ACS has a commercial relationship will also be

informed of the existence of this Policy.

12. Consequences of non-compliance

Any breach of this Policy will give rise to appropriate legal sanctions in accordance

with the Code of Conduct and the ACS Compliance Disciplinary System.

Any measures adopted from an employment perspective will be respectful of

applicable regulations, although they will always be forceful and proportional to the

seriousness of the events that gave rise to the breach, informing the Legal

Representatives of Workers if appropriate.

If any action performed by a Third Party can be considered a breach of or

incompatible with the Compliance Policy for International Sanctions imposed on

third parties or might expose ACS to any type of liability in accordance with these

Sanctions, the Third Party must notify ACS within 48 hours of becoming aware of

it.

ACS may terminate this agreement immediately by writing to the other party at any

time if it has reason to believe, based on credible indications, that the Third Party

has breached or is breaching any of the above guarantees and declarations of this

clause in relation to Sanctions.

The Third Party will be solely responsible for any breach of its obligations related

to Sanctions detailed here and, therefore, ACS cannot be held liable in any way for

a breach committed by a Third Party. If ACS is penalised for breaching sanctions

regulations due to the information received through this clause, ACS may take this

matter up with the Third Party, which must hold ACS harmless from any sanctions,

liability, or in general any type of damage suffered by ACS.

If it is confirmed that the actions of any Member of the Organisation could constitute

a criminal offence attributable to the legal entity, this circumstance will be brought

to the attention of the competent public authorities for their knowledge and

prosecution. This communication will include any evidence and/or information that

may have been gathered.

Annex I: Concept of international sanctions

The terms 'International Sanctions,' 'Trade Sanctions' or simply 'Sanctions' refer to laws

and regulations that restrict relationships with certain individuals, governments,

organisations, groups and non-state entities, with the aim of modifying certain behaviour

or weakening the position of all those that pose a threat to international peace and

security.

These restrictions may include:

- General or partial prohibitions to trade with persons or entities included in the

applicable asset freezing lists, or with entities owned or controlled by entities

included on those lists.

- Travel prohibitions

- Restrictions related to exporting telecommunications and software services

- Financial liabilities that prohibit making assets of any type available to the sanctioned

parties or providing them with financial services of any kind.

These measures are imposed by States and supranational organisations, such as the

European Union (EU), which often apply the sanctions of the United Nations Security

Council (UN) through a raft of legal measures, applied by the imposing party with a

greater or lesser degree of severity, as necessary to achieve the ultimate objectives for

which they have been imposed.

Furthermore, the objectives of International Sanctions and the nature of the restrictions

imposed by International Sanctions are subject to periodic changes, and such

amendments do not always respond to changes in the regulated realities, but rather to

political (and, indirectly, economic) interests and events, so they are particularly exposed

to rapid and (sometimes) unforeseeable changes.

Therefore, for the purposes of compliance, it is essential to keep up-to-date information

on all the International Sanctions applied to the business, since sentences for breaching

Commercial Sanctions may be serious, including high fines or custodial sentences, in

addition to posing a substantial risk to the reputation of the Organisation.

Of particular importance are UN, EU and US sanctions, given that the latter apply the

restrictions proposed by the former, either by transposition or extension, and that the

Group performs a significant part of its activity in those territories.

 UN sanctions regime

Chapter VII of the Charter of the United Nations provides the legal basis for imposing

coercive measures within the United Nations. Sanctions are adopted by a Security

Council Resolution.

They apply to any entity or national citizen of a UN Member State.

 EU sanctions regime

Within the EU, restrictive measures are configured as a key tool of the Common Foreign

and Security Policy (CFSP) to defend its strategic interests and protect its fundamental

objectives abroad.

Sanctions are imposed by the Council's decision and are implemented by means of

regulations that must be applied by Member States, which will be responsible for taking

action against violations of international sanctions.

EU sanctions apply to:

- EU companies and nationals;

- Non-EU companies and non-EU employees in relation to everything they do in the

EU and any business performed totally or partially in the EU.

Further information on the EU sanctions regime can be found here:

https://www.sanctionsmap.eu/#/main

 US sanctions regime

The US sanctions regime is particularly complex, so it is essential to cross check with

the lists of sanctioned subjects published by the Office of Foreign Assets Control

(OFAC). In general, this refers to Specially Designated Nationals and Blocked Persons

List (SND). The OFAC also publishes specific lists.

US sanctions apply to:

- US companies and their branches abroad, including non-US subsidiaries, US

citizens and permanent residents, in relation to anything they do anywhere in the

world; and

- Non-US companies and non-US citizens in relation to anything they do in the US

and in relation to any transaction that may affect the US (so-called 'secondary

sanctions').

General or specific licences may be granted to perform transactions with sanctioned

countries or entities.

Further information on the US sanctions regime can be found here:

US Office of Foreign Assets Control (OFAC):

https://www.treasury.gov/about/organisational-structure /:/Pages/Office-of-Foreign-

AssetsControl.aspx

Overview of US sanctions:

http://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/Programs.aspx

Search the OFAC list of specially designated nationals and blocked persons:

http://sdnsearch.ofac.treas.gov/Default.aspx

Annex II: Information and documentation required for the due

diligence procedure

Third-Party data (legal person)

 Company name

 Information on the incorporation of the

company

 Address

 Sector of activity

 Countries in which the activity is

performed

 Director names

 Authorised signatories

 Beneficial owner

All supporting documentation that verifies the information compiled must be gathered.

Third-Party data (individual):

 First and last name(s)

 Address

 Company sector/activity

 Countries in which they operate

Annex III: Questionnaire on exposure to international sanctions

New third parties

You are receiving this questionnaire in compliance with the ACS Compliance Policy for

International Sanctions imposed on third parties.

ACS agrees to comply with all applicable international laws, regulations, and conventions

in all territories in which it operates. ACS has established a procedure to prevent and

mitigate possible international sanctions.

The purpose of this form is to ask a series of questions to better identify and understand

the nature of ACS suppliers and customers' activities and their scope with certain

sensitive sanctioned countries and sanctions regimes based on lists.

Sanctioned countries infringe internationally accepted conduct and regulations, since

they have been identified as being involved in the proliferation of weapons, as terrorists

or supporters of terrorist organisations, as human rights violators, or involved in

corruption and bribery.

Answer all questions as appropriate.

Name of Legal Entity/Person:

Country of incorporation/residence:

Location of Subsidiary (if applicable):

Activity sector:

1. Do you/does the company have any subsidiaries, branches, permanent

establishments, offices, or other presence in a sanctioned country? If yes, specify

the sanctioned country, the nature of the activity/operations and offer any details

you feel are relevant.

Company/Operation Country Details

2. Do you/does the company sell goods or services that directly or indirectly involve

people, entities, organisations or States that are currently subject to international

sanctions? If yes, specify the details.

Yes

3. Do you/does the company have any business activities

involving directly or

indirectly persons, entities, organisations or States currently subject to

international sanctions? If yes, specify the details.

Yes

4. Do you/does the company conduct business/transactions on behalf of third

parties involving individuals, entities, organisations or assets that are currently

subject to international sanctions? If yes, specify the details.

Business activities refer to any activity performed by a company for the main purpose of obtaining profits.

In general, this may include suppliers, customers, agents, investments in bonds and/or securities, transport,

lenders, trustees, transactions with State or State controlled entities, etc.

Yes