Sanctions Compliance Policy

Scope

Transbosphor Maritime Transport and Trade Ltd. (hereafter referred to as “the Company”) has developed this policy as part of its Sanctions Compliance Framework. The Company adheres to the Sanctions Policy (the “Policy”). This Policy sets the minimum standards and guidelines to mitigate the risks associated with sanctions compliance, as well as the reputational risks arising from engaging in business relationships or transactions with sanctioned individuals and entities.

As a core principle, the Company is committed to aligning its operations with the framework outlined in this Policy, considering its specific characteristics and complying with the applicable laws and regulatory requirements of its area of operation.

Regulation Compliance

The Company will comply with all applicable sanctions’ check in every jurisdiction where it operates. As a law company, we incorporate sanctions regulatory requirements and relevant guidance into our practice. These sanctions are enforced by, but not limited to, the following authorities and countries. Our commitment is to provide legal advice and assistance to ensure that our clients comply with these regulations and manage the risks associated with non-compliance. These checks are enforced by, but not limited to, the following authorities and countries:

• United States (OFAC)
• United Nations (UN)
• European Union (EU)
• United Kingdom (OFSI)

In case of conflict of the requirements established in this policy with any country’s law enforcement, regulation or guidance, the Company must document and escalate the conflict to the Client for advisory.

Objectives

The objectives of the Policy are the following:

• Demonstrate the company’s commitment to sanctions compliance.
• Articulate the company’s sanctions compliance checks, which aligns with its sanctions risk profile.
• Identify higher-risk areas within the company’s operations and legal practice.
• Establish proper controls for client and transaction screening processes.
• Document the requirement to report potential sanctions breaches to competent authorities.
• Define the role of independent testing in the company’s sanctions compliance check.
• Outline the responsibilities of the company’s Associate handling sanctions compliance matters.
• Describe how the company, across all its departments, will maintain an up-to-date sanctions compliance check and respond effectively to legal and regulatory changes.
In addition, the policy aims to:
• Ensure that the company maintains effective controls to prevent and mitigate potential sanctions breaches.
• Outline the processes the company will follow to conduct sanctions-related reviews and assessments.
• Protect the company’s reputation from being involved in or facilitating business with any sanctioned countries, organizations, activities, individuals, or entities.
• Safeguard the company from legal and reputational risks associated with penalties arising from breaches of applicable sanctions checks.

Sanctions Compliance Commitment

The Company is committed to full compliance with sanctions laws and regulations in all jurisdictions where it operates, including the maritime and shipping sectors.

The Company must prevent the opening or maintenance of relationships, or the execution of transactions for, on behalf of, or for the benefit of, any sanctioned individual, entity, country, organization, or vessel in violation of applicable sanctions laws and regulations.

This policy establishes the minimum standards for:

• Ensuring that no sanctioned individuals, entities, or vessels are involved in the Company’s operations or legal transactions.
• Monitoring shipments, cargo, and other maritime-related transactions to prevent any sanctioned goods, individuals, or entities from being involved.
• Ensuring that the Company’s employees, contractors, and service providers are not engaged in any prohibited transactions or activities under applicable sanctions.
• Conducting thorough investigations when a potential match with a sanctioned party is found, including for vessels and shipping companies.
• Regularly updating and maintaining the sanctions lists used for screening clients, vessels, and related transactions.
• Handling any necessary licenses for transactions involving sanctioned countries or entities, ensuring compliance with licensing requirements.
• Generating and submitting reports related to sanctions compliance, including any suspicious activities related to maritime operations.
• Ensuring that the Company’s staff is fully aware of the sanctions compliance requirements related to ships, cargo, and shipping transactions, with regular training.
• Maintaining and providing accurate records and reports related to sanctions compliance for internal and external purposes.
• Developing and implementing a framework to assess and manage the risks associated with the involvement of sanctioned vessels, cargo, and companies.

Sanctions Compliance Policy Statement – Authorised Person(s) and Executive Management Responsibilities

The Authorised Person(s) and Executive Management are accountable and fully committed to ensuring compliance with all sanctions laws and regulations applicable to the Company’s operations, including maritime and shipping-related transactions.
The Authorised Person(s) is responsible for ensuring that sufficient and effective resources, systems, and processes are in place to support the Company’s compliance efforts in mitigating sanctions risks across its operations, including legal services related to shipping, vessel transactions, and cargo operations, while adhering to local laws and regulations.

Authorised Person(s) Responsibilities:

• Ensure that the Sanctions Compliance function within the Company has sufficient authority and autonomy to implement and enforce the Company’s Sanctions Policy and Procedures.
• Oversee the implementation of the Sanctions Policy and applicable sanctions controls across the Company’s legal departments, shipping-related legal services, and operational areas.
• Ensure the existence of direct reporting lines between the Sanctions Compliance functions and senior management, including the appropriate forum for discussion and reporting of sanctions matters.
• Demonstrate recognition of the seriousness of potential sanctions breaches, including violations of relevant sanctions laws and regulations administered by appropriate sanction authorities, and implement necessary measures to prevent breaches.
• Address any malfunctions, deficiencies, or failures by the Company and its staff to comply with the Sanctions Compliance

Check, ensuring that systemic solutions are implemented where needed.

Sanctions Compliance Function Responsibilities:

The Sanctions Compliance function is responsible for the implementation, development, and review of this Policy, which has been approved by the Authorised Person(s). The Authorised Person(s) are ultimately accountable for ensuring the fulfillment of the Company’s obligations under relevant sanctions laws and regulations. The Chief Compliance Officer is responsible for overseeing risk assessments related to sanctions compliance across the Company’s operations, including maritime and shipping transactions.

Sanctions Compliance Function Responsibilities Include:

• Ensuring that the Sanctions Compliance Policy is regularly updated and aligned with relevant sanctions developments affecting the Company’s operations, particularly in relation to shipping and cargo activities.
• Providing consistent and effective sanctions advisory services to the Company’s various departments, including maritime, shipping, and international trade legal services.
• Overseeing, reviewing, and assessing the financial crime compliance risks related to sanctions within the Company’s shipping and maritime operations.
• Developing and delivering sanctions training and awareness checks for Company employees to strengthen their understanding of sanctions risks and best practices for mitigating such risks, with a focus on the shipping and maritime industries.

Transparency and Compliance Policy

Employees of the Company are prohibited from modifying, removing, or concealing any data, documents, or details related to transaction parties in order to bypass sanctions or prevent the detection of any sanctions-related issues. Requests from any party to alter or hide pertinent information, such as names, addresses, or other details in transaction records, documents, or sanctions lists, should be rejected. These requests must be immediately reported to the Sanctions Compliance function or the designated compliance officer.

Any instances of non-compliance or deviations from this policy must be reported to the Sanctions Compliance function, which will evaluate the risks involved and advise on implementing alternative controls to address and minimize the sanctions risks.

Sanctions Non-Compliance and Violations

Any failure to adhere to the Company’s sanctions controls is considered a breach. A breach may be classified as a policy breach or a potential regulatory breach. A policy breach occurs when the Company’s standard controls to mitigate sanctions risks are not followed, which increases the likelihood of non-compliance with sanctions laws and regulations, potentially leading to a regulatory breach.

Potential sanctions breaches are identified through automated sanctions screening of clients and transactions, as well as the investigation of rejected payments. A root cause analysis and thorough examination of all potential sanctions breaches are conducted. As part of remediation, clients may be notified of the potential breach and reminded of the Company’s Sanctions Policy. In certain cases, the termination of a relationship or restriction of specific services or products (e.g., “ring-fencing”) may be considered.

All potential breaches (whether policy-related or regulatory) must be communicated to the Sanctions Compliance function, which will review the situation, advise on the necessary corrective actions, and report to the relevant authorities if required.

Documentation and Retention Requirements

The Company must retain records related to client accounts, transactions, and compliance actions, in accordance with applicable legal and regulatory requirements.

The key sanctions-related records include:

• Specific licenses authorizing transactions or actions involving clients or shipping operations.
•Sanctions regulatory reports.
• Attendance lists and content for sanctions compliance training.
• Automated screening alerts for clients and maritime transactions.
• Reports related to potential sanctions breaches or violations.

Audit

The Company’s internal audit function regularly conducts audits to assess the adequacy and effectiveness of the measures implemented to identify, monitor, and manage both national and international sanctions risks.

The Company must ensure that, upon discovering a confirmed issue or audit finding related to its sanctions compliance check—whether identified internally or by an external party—prompt and effective action is taken. This includes implementing compensating controls as needed until the root cause of the issue can be identified and addressed.

Policy Reviews and Approvals

The adequacy and effectiveness of this policy will be reviewed annually or as needed to ensure it remains aligned with the Company’s operations and compliance obligations. The policy is created in accordance with national and international regulations and the Company’s obligations related to sanctions compliance. In cases of non-compliance, more stringent measures will be implemented.

The Sanctions Compliance function is responsible for ensuring that this policy remains valid and is updated regularly. The policy, as well as any subsequent amendments, will be approved by the Authorised Person(s) within the Company.