Company Policy on Relations with russian federation and republic of belarus

Our company, guided by the principles of transparency, responsibility, and strict adherence to international standards, officially and categorically declares its zero-tolerance position towards the russian federation and the republic of belarus, as well as any cooperation with them.

We condemn russia’s aggression against Ukraine and any support for this crime. Our company stands for justice, peace, and the territorial integrity of Ukraine.

In this regard, we declare that our company strictly does not cooperate with any legal entities or individuals associated with the russian federation or the republic of belarus. This applies to all areas of activity, including but not limited to:

Supply of goods and services: We do not purchase goods and services from companies related to russia/belarus, nor do we supply them with our goods and services.
Financial transactions: We do not conduct financial transactions with companies or individuals associated with russia/belarus, including any payments, fund transfers, investments, or other financial operations.
Investments: We do not invest in companies related to russia/belarus and do not attract investments from these countries.
Partnerships: We do not cooperate with companies that have partnerships with russia/belarus, including joint ventures, distribution agreements, or other forms of collaboration.
Contracts: We do not enter into or fulfill contracts with companies or individuals associated with russia/belarus.
Marketing and advertising: We do not place advertisements on resources related to russia/belarus and do not cooperate with marketing agencies operating in these territories.

We also do not cooperate with any individuals who publicly support russia’s aggression against Ukraine, regardless of their nationality or place of residence.

Any inquiries, proposals, or attempts to establish business relations from entities in these jurisdictions will be automatically and unconditionally rejected without consideration.

Pay attention! If, after signing a contract with any partner, our company receives information about their cooperation with the russian federation or the republic of belarus, such a contract will be automatically terminated unilaterally, without prior notice or any compensation.

This policy is an unchangeable and absolute part of our commitment to complying with international norms, ethical business standards, and protecting our reputation as a reliable and responsible partner on the global stage.

We call on all responsible companies to join us and cease any cooperation with the aggressors.

Commitment to preventing terrorist financing

Our approach is aligned with international standards and relevant legal instruments, including:

The Financial Action Task Force (FATF) Recommendations – the global standard for preventing money-laundering and terrorist financing.
United Nations Security Council resolutions and UN sanctions lists targeting terrorist individuals and entities.
Applicable regional and national laws and directives (for example, EU AML directives including amendments and AMLD6, and national laws such as Ukraine’s Law on Prevention and Counteraction to Legalization (Laundering) of Proceeds of Crime and Financing of Terrorism). Replace with the specific local laws that apply to your operations.

Our company’s key principles:
– Risk-based approach – we identify, assess and mitigate TF risks proportionate to their severity.
– We collect and verify identity and beneficial ownership information where required.
– Sanctions & watch-list screening – all customers and transactions are screened against applicable sanctions and terrorist lists (UN, EU, national lists).
– Suspicious activity reporting – employees must report suspicions to the Compliance Officer and where required we will file Suspicious Transaction Reports (STRs) with the competent Financial Intelligence Unit (FIU).

Anticorruption

Also in this regard, our company affirm that:
1. We have never engaged in any corrupt act.
2. We have not given, made, offered, or received – nor agreed to give, make, offer, or receive – any payment, gift, or other advantage that:

breaches any applicable law;
is intended to influence or reward improper conduct, or undermines good faith, impartiality, or trust;
is made to or for a public official with the purpose of obtaining or retaining business advantage; or
could reasonably be considered unethical, illegal, or improper.

3. We do not and will not request any action, inaction, or service that would violate applicable law.
4. We have not received, attempted to receive, or agreed to receive any benefit or profit derived from a crime or a corrupt act.
5. We have not assisted and will not assist any person in retaining such unlawful benefits or profits.

We are fully committed to acting in strict compliance with the anti-corruption legislation of Ukraine and with internationally recognized standards of ethical conduct.

This commitment reflects not only our legal obligations but also our core values as a responsible and trustworthy business partner.

Foreign Corrupt Practices

At “SUBSIDIARY ENTERPRICE OBERIG IT BY A-TYPE” LLC, we place the highest importance on conducting business ethically, transparently, and in full compliance with applicable laws. We have carefully reviewed the requirements of the U.S. Foreign Corrupt Practices Act (the “FCPA”) (15 U.S.C. Section 78dd-1, et seq.) as well as relevant international and local anti-corruption regulations.

It is our company position that all parties we engage with must act in accordance with these standards. We expect and require strict compliance with the FCPA and any applicable foreign laws relating to anti-bribery, anti-corruption, and similar practices. We are committed to ensuring that our operations and partnerships reflect integrity, accountability, and respect for the rule of law.

This commitment extends to our consultants, partners, and affiliates, who are expected to fully understand these obligations, seek proper legal guidance where necessary, and comply in all material respects at all times.

*** The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (“FCPA”), was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. Specifically, the anti-bribery provisions of the FCPA prohibit the willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.
Since 1977, the anti-bribery provisions of the FCPA have applied to all U.S. persons and certain foreign issuers of securities. With the enactment of certain amendments in 1998, the anti-bribery provisions of the FCPA now also apply to foreign firms and persons who cause, directly or through agents, an act in furtherance of such a corrupt payment to take place within the territory of the United States.