LAST UPDATED 4 APRIL2025

SANCTIONS COMPLIANCE POLICY AND PROCEDURE

1. Policy Introduction

This document establishes the policy and procedures of Bale Capital Pty Ltd (hereafter referred to as “the Company”) for ensuring compliance with the obligations under targeted financial sanctions. These sanctions are issued by the United Nations Security Council, the United Arab Emirates (UAE), and other applicable international and national bodies. This policy is in strict adherence to the UAE Cabinet issued Resolution (74) of 2020 concerning the implementation of targeted financial sanctions.

2. Policy Objective

The primary objective of this policy is to prevent the Company and its employees from engaging in transactions that violate targeted financial sanctions. It aims to:

1. Identify and screen customers, clients, and beneficial owners against sanction lists.
2. Ensure compliance with legal and regulatory requirements.
3. Mitigate the risk of legal, financial, and reputational damage associated with sanctions violations.

3. Scope of the Policy

This policy applies to all business units, employees, and officers within the Company. It covers all aspects of the Company’s operations, including client onboarding, ongoing client relationship management, and transaction processing.

4. Legal Framework

The policy is designed to ensure compliance with:

1. United Nations Security Council sanctions.
2. UAE Cabinet Resolution (74) of 2020.
3. Other relevant sanctions lists issued by international and national bodies.

5. Sanctions Compliance Officer (SCO)

The Company will appoint a Sanctions Compliance Officer (SCO) responsible for:

1. Overseeing the implementation of the sanctions compliance program.
2. Serving as the primary contact point for all sanctions-related inquiries.
3. Ensuring regular updates of sanctions lists and compliance procedures.

6. Client and Transaction Screening Procedures

1. Initial Screening: All new clients, including beneficial owners, must be screened against the applicable sanctions lists before establishing a business relationship.
2. Ongoing Screening: The Company will conduct regular screenings of existing clients and their beneficial owners against updated sanctions lists.
3. Transaction Screening: All transactions will be screened to ensure they do not involve sanctioned parties or countries.

7. Handling Matches

1. Initial Detection: Any match or potential match with a sanctioned entity will trigger an immediate halt to the transaction or business engagement.
2. Investigation: The SCO will investigate the match to confirm its validity, consulting additional information or documentation as necessary.
3. Reporting: Confirmed matches will be reported to the relevant authorities as per the legal and regulatory requirements.
4. Record-Keeping: Documentation of the screening process, investigation, and reporting will be maintained for a minimum of seven years.

8. Training and Awareness

The Company will implement an ongoing training program for all employees, focusing on:

1. The importance of sanctions compliance.
2. Recognition of potential sanctions issues.
3. Procedures for reporting matches or potential matches.

9. Audit and Compliance Monitoring

The Company will conduct regular audits of its sanctions compliance program to assess its effectiveness and identify areas for improvement. The SCO will review and update the compliance procedures in response to changes in sanctions legislation or business activities.

10. Policy Review and Updates

This policy will be reviewed annually or more frequently if significant changes occur in the sanctions regulatory environment or the Company’s operations. The SCO is responsible for ensuring the policy remains up-to-date and compliant with current laws and regulations.

Bale Capital Pty Ltd is committed to maintaining the highest standards of compliance with targeted financial sanctions. Through the implementation of this policy, the Company seeks to uphold its legal obligations and contribute to global efforts against terrorism financing and other threats to international peace and security.