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Export control and sanctions compliance policy

I. INTRODUCTION

This Export Control and Sanctions Compliance Policy (the “Policy“) establishes the framework and requirements for conducting MCS IT Distribution Ltd.’s (the “Company“) business in full compliance with all applicable export control laws and economic sanctions regulations. This Policy outlines the Company’s obligations and expectations to ensure that our products, services, and technologies are not used or transferred in violation of international laws.

II. SCOPE

This Policy applies to all Company’s activities, including:

  1. sale or shipment of goods across borders;
  2. Transmission of technology or software;
  3. Financial transactions involving foreign entities;
  4. Interactions with embargoed or restricted persons, companies, or countries.

III. REGULATORY FRAMEWORK

The Company complies with relevant regulations, including but not limited to:

    1. Parliament and Council Regulation (EU) 2021/821;
    2. Council Regulation (EU) No 833/2014;
    3. U.S. Export Administration Regulations (EAR);
    4. U.S. Office of Foreign Assets Control (OFAC) Sanctions;
    5. United Nations Security Council sanctions;
    6. Any other local export laws applicable in jurisdictions where the Companies we operate.

IV. POLICY REQUIREMENTS

IV.1 Prohibited Transactions

The Company strictly prohibits:

  1. Direct or indirect transactions with sanctioned individuals, entities, or countries;
  2. Exports of controlled goods or technologies without required licenses;
  3. Facilitating third-party violations of export laws or sanctions.

IV.2 Screening Obligations

All counterparties (customers, partners, vendors) must be screened against applicable sanctions lists, including but not limited to:

  1. OFAC SDN List;
  2. EU Consolidated List;
  3. UN Sanctions List.

IV.3 Licensing and Approvals

Where required, the Company will:

  1. Obtain appropriate licenses or authorizations before export and/or import;
  2. Maintain records of all licensing documents and communications;
  3. Seek legal counsel if uncertainty exists regarding licensing requirements.

V. EMPLOYEE RESPONSIBILITIES

All the Company’s personnel involved in activities listed in Clause II (Scope) above must:

    1. Immediately report any suspected or actual violations to the Legal Department;
    2. Understand their roles in complying with export and sanctions laws;
    3. Complete any required export control or compliance training (if any) to be conducted by Legal Department.

VI. RECORD-KEEPING

The Company will take all reasonable steps in order to maintain accurate records of the following (if any):

  1. Export licenses;
  2. End-user certificates;
  3. Screening results;
  4. Compliance training attendance.

Records must be retained for at least 5 (five) years after termination of a relevant contractual relationship and/or relevant event.

VII. VIOLATIONS AND ENFORCEMENT

Violations of this Policy may lead to:

  1. Disciplinary action up to and including termination;
  2. Civil and/or criminal penalties under applicable law;
  3. Suspension of business with non-compliant third parties.

VIII. POLICY REVIEW

This Policy shall be reviewed annually and updated as necessary to reflect changes in applicable laws or Company operations.

IX. CONTACT

For any inquiries regarding the Policy or the export and sanctions control process, kindly submit your request via the feedback form.

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