Our approach to Sanctions Compliance is guided by the following key principles:

• Compliance with Legislation: We strictly abide by the requirements of U.S., UN, EU, and U.K. sanctions regimes.
• Avoidance of Violations: We refrain from engaging in any activity that could violate the aforementioned sanctions regimes.
• Adherence to Local Sanctions: We are committed to adhering to sanctions regimes in all jurisdictions where our company operates.
• Prohibition of Business Involvement: We do not conduct business with or involve sanctioned countries, territories, entities, individuals, goods, or services.
• Thorough Due Diligence: The Compliance Team conducts comprehensive screening and clearance of any new business or relationship, ensuring full due diligence is conducted.
• Mitigation of Compliance Risks: We avoid participating in transactions that could expose our company or counterparties to compliance and reputational risks.
• Risk Management: We train our employees on sanctions compliance, conduct due diligence on all counterparties, and continually monitor sanctions regimes to manage our exposure to sanctions risks.
• Reporting Suspicious Activities: All employees are required to remain vigilant regarding sanctions risks and report any suspicious activities or third parties to the Compliance Team.
• Prohibition of Business Relationships: We strictly prohibit establishing new business relationships with individuals, legal entities, ultimate beneficial owners (UBOs), or organizations subject to U.S., U.N., EU, and U.K. sanctions or other regulatory bodies or authorities’ sanctions.
• Avoidance of Close Associations: Engaging in business with close family members, close associates, or related entities of sanctioned names is strictly forbidden.

In addition to the above measures, Navinkor Marine SA’s standard Terms and Conditions include a Sanctions Compliance Undertaking, which is required to be signed by all counterparties.
By adhering to these principles and implementing robust sanctions compliance measures, Navinkor Marine SA demonstrates its commitment to responsible and ethical business practices.