LCY GROUP

TRADE SANCTIONS COMPLIANCE POLICY

  1. LCY GROUP1 will commit to complying with all applicable trade sanctions laws and regulations of UN, EU, the United States, and any jurisdictions where LCY GROUP located.
  2. This Policy specifies the minimum standards that LCY GROUP must comply with, including:

    1. Conduct sanctions screening on customers and transactions of LCY GROUP against the Sanctions List of applicable trade sanctions laws and regulations;
    2. Prohibit and restrict business and transactions with individuals or entities listed as a sanctions target by trade sanctions laws and regulations.
    3. Prohibit and refuse business activities and transactions that are not allowed under sanctions laws and regulations.
  3. LCY GROUP will request all directors, executives, officers and employees, as well as agents, distributors, representatives, and other associated persons when acting on behalf of LCY GROUP (collectively“Company Personnel”) to abide by this Policy.
  4. Any individuals and/or entities who find any suspicious transaction or know of any Company Personnel that has violated or is likely to violate this Policy and/or trade sanctions laws and regulations shall immediately notify LCY GROUP management team by clicking here.
    LCY GROUP will report violations to relevant regulatory agencies when necessary.
  5. LCY GROUP will regularly monitor the effectiveness of this Policy and revise it as necessary to ensure that we continue to comply with the provisions of the sanctions laws and regulations.

1 LCY GROUP means LCY CHEMICAL CORP. and its subsidiaries and affiliates.
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