TRADE SANCTIONS COMPLIANCE POLICY

1. LCY GROUP¹ will commit to complying with all applicable trade sanctions, anti-money laundering and counter financing of terrorism laws and regulations of UN, EU, the United States, and any jurisdictions where LCY GROUP located. Any legal entities of LCY GROUP shall establish their own trade sanctions compliance policy in line with this Policy. This Policy shall be applied by any legal entities of LCY GROUP if they do not establish their own such policy.
2. This Policy specifies the minimum standards that LCY GROUP must comply with, including:
   
   
   1. Conduct screening on customers and transactions of LCY GROUP against the Sanctions List to identify which may be blocked or prohibited;
   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 refusal of business activities and transactions that are not allowed under 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 laws and regulations which related to this Policy shall immediately notify LCY GROUP management team via email.
   LCY GROUP will report violations to the relevant regulatory agencies when necessary.
5. This Policy will be revised based on the amendment or repeal of relevant laws and regulations, or the needs of facts.