GetTransfer Sanctions Policy

1. POLICY STATEMENT

GETTRANSFER LTD, the company registered at 57 Spyrou Kyprianou, Bybloserve Business Center, 2nd floor, 6051, Larnaca, Cyprus (hereinafter referred to as the "Company") will comply with all economic sanctions laws, regulations, embargoes or restrictive measures (Sanctions) to which it is subject. The Company will maintain effective measures to ensure compliance with and awareness of its Sanctions related obligations. To give effect to this Policy, the Company has adopted, and will maintain, a sanctions screening procedure. The procedure sets out the key steps and principles for ensuring compliance with applicable Sanctions. Failure to comply with Sanctions can lead to severe civil and criminal penalties, both for our business and individual employees, officers and directors, as well as significant reputational damage for the Company. Noncompliance with this Policy is a serious matter that may lead to disciplinary action, up to and including dismissal. Violations of Sanctions can also have legal consequences for individuals involved, including severe monetary fines. Employees should report any suspected violations of this Policy.

2. TO WHOM DOES THIS POLICY APPLY?

This Policy applies to everyone working for the Company worldwide regardless of location, role or level of seniority. This includes all employees, Managers, Executive Leadership Team Members, and Directors of the Company. We require that temporary and contract employees, consultants, agents and any other third party which acts for and in the Company’s name, comply with the principles of the Policy. It covers all aspects of the Сompany's operations, including client relationships, transactions, procurement, and partnerships.

3. WHAT ARE SANCTIONS?

Sanctions are typically imposed by a government or an international organization to achieve a variety of foreign policy or national security objectives and generally are restrictions on the ability of an entity or individual to engage in certain commercial activities and financial dealings with targeted entities or individuals. Sanctions measures can vary from the comprehensive – prohibiting trade with a target country and freezing the assets of a government, the corporate entities and residents of that country – to targeted asset freezes on specified entities or individuals. The Company will conduct its activities in compliance with the sanctions requirements of the U.S., EU, and any other jurisdiction that the Company determines to be important for its business.

Certain entities and individuals targeted by Sanctions are identified on lists issued by the U.S., EU, United Nations and other governments or international organizations, which are published on websites and are publicly available (“Sanctions Lists”). Sanctions also target certain entities and individuals not included on these Sanctions Lists, including entities owned or controlled by entities or individuals on such lists.

Failure to comply with sanctions can lead to severe civil and criminal penalties, both for the Company’s business and individual employees, officers and directors, as well as significant reputational damage to the Company.

As a general rule, employees and representatives of the Company are not permitted to engage in any transactions or dealings with a party that is the target of applicable sanctions, such as the sanctions programs of the U.S. or the EU, or any jurisdiction that is the target of comprehensive sanctions. That does not, however, mean that all transactions involving a jurisdiction that is targeted by any sanctions will be off limits for the Company; some jurisdictions, are targeted by more nuanced sanctions, and in those cases, certain transactions and dealings may be permissible, although caution is warranted.

U.S. SANCTIONS

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) administers and enforces U.S.-based economic and trade sanctions programs (“OFAC Sanctions Programs”), which are based on U.S. foreign policy and national security goals, as well as on United Nations and other international mandates. Additionally, OFAC publishes lists of individuals, groups and entities, such as terrorists and narcotics traffickers, which are the target of the OFAC Sanctions Programs. These include: the Specially Designated Nationals (“SDNs”) and Blocked Persons List (the “SDN List”).

U.S. sanctions apply to:

• U.S. companies and their overseas branches (and, for certain sanctions, non-US subsidiaries of U.S. companies) in relation to anything they do anywhere in the world;
• U.S. citizens and permanent resident aliens (i.e. “green card” holders) in relation to anything they do anywhere in the world; and
• Certain non-U.S. companies and non-U.S. nationals in relation to anything they do in the U.S. and any business conducted wholly or partly in the United States.

U.S. sanctions can also be applied to transactions that touch or concern the United States, including those that take advantage of the U.S. financial system (e.g. dollar-denominated transactions) and those that involve U.S. companies and individuals or U.S.-origin items.

The United States has also implemented so-called “secondary sanctions” that provide for sanctions against companies and individuals who engage in specific kinds of transactions and dealings, generally targeting specified activities in sanctioned countries, such as Iran, even if the transaction or dealing does not otherwise have a U.S. jurisdictional nexus. These sanctions provide for the imposition of a range of measures designed to exclude or restrict the non-U.S. Person who engages in the conduct from U.S. economic activity.

Overview of US Sanctions:
https://ofac.treasury.gov/sanctions-programs-and-country-information

OFAC Specially Designated Nationals and Blocked Persons List Search:
https://sanctionssearch.ofac.treas.gov/

EU SANCTIONS

The Council of the European Union takes decisions on the adoption of EU sanctions. The European Commission gives effect to these decisions into EU law through proposals for regulations, which are in turn adopted by the Council. There is, however, no central EU enforcement body, and enforcement of EU sanctions is a matter for individual Member States.

EU sanctions comprise a range of financial and trade measures. The main financial sanctions involve the designation of individuals or legal entities, resulting in their assets being frozen and a prohibition on funds or economic resources being made available to them. The EU maintains a consolidated list of individuals and legal entities subject to financial sanctions4 Legal entities that are majority-owned or controlled by a person or entity included in the EU consolidated list are treated as if they were also included in the list. EU trade restrictions differ from country to country, but can extend to prohibitions on the import or export of a wide range of goods and technology, including luxury goods.

EU Sanctions apply to:

• EU companies and EU nationals in relation to activities anywhere in the world – even if an EU national is employed by a non-EU company; and
• Non-EU companies and non-EU nationals in relation to activities in the EU and any business they conduct wholly or partly in the EU.

Overview of EU Sanctions: https://www.sanctionsmap.eu/#/main

4. COMPLIANCE WITH SANCTIONS

The Company, as well as its employees, must comply with all Sanctions applicable to the relevant person and may not engage in any business that could violate applicable Sanctions.

In general, sanctions:

Prohibit dealing with individuals or entities listed on applicable assets freeze lists, such as the US list of specially designated nationals and blocked persons, the EU consolidated list of financial sanctions targets, or any list maintained by any relevant authority (including in Switzerland and the UK).

• Prohibit dealing with entities owned or controlled by entities on the lists referred to above.
• Prohibit or restrict dealing with certain countries or territories.
• Prohibit facilitation of transactions that you cannot engage in directly yourself.

In order to enable compliance with Sanctions, the Company gathers information from its counterparties and clients as specified in Schedule 1 hereto and operates a screening process for its counterparties. The screening process is aimed at determining whether a proposed counterparty is named on assets freeze list or may be owned or controlled by such a person. The Company conducts screening during client/partner onboarding, prior to entering into any business relationship, and on an ongoing basis.

All transactions fall under the screening to ensure compliance with applicable sanctions. This includes:

• Reviewing the details of transactions to identify any links to sanctioned individuals, entities, or countries.
• Blocking or reporting any transactions that may violate sanctions regulations.

The Company should also be mindful of the Sanctions-related obligations in its financing agreements, such as investment agreements, which can extend beyond the legal obligations imposed by Sanctions.

5. RISK ASSESSMENT

The Company will perform regular risk assessments to evaluate the potential; exposure to sanctions-related risks. This includes:

• Assessing the geographical areas of operation and business sectors involved.
• Reviewing the effectiveness of existing controls and procedures.
• Identifying any new or emerging risks related to sanctions.

The list of Restricted Territories is attached hereto as Schedule 2.

6. TRAINING AND AWARENESS

The Company will provide regular training to employees on sanctions regulations, the identification of potential sanctions risks, and the company's compliance procedures. The training program will ensure that employees understand their responsibilities and the importance of adherence to this Policy

7. REVIEW AND UPDATES

This Sanction Policy will be reviewed and updated periodically to ensure its effectiveness and compliance with current regulations. Any changes to the Policy will be communicated to all relevant employees and stakeholders.

8. RESPONSIBLE OFFICER

The Company’s Director is responsible for overseeing the implementation and enforcement of this Sanction Policy (the “Responsible Officer”). The Responsible Officer will ensure that the Company remains compliant with all relevant sanctions regulations and will serve as the point of contact for any sanctions-related inquiries or issues.

9. CONCLUSION

The Company is committed to conducting its business in full compliance with all applicable sanctions regulations. By implementing this Sanction Policy, the Company aims to protect its clients, itself, and the integrity of the global financial system.

The Company will consider non-compliance of this Policy as a serious matter warranting disciplinary action, up to and including dismissal, where allowable by law. Violations of Sanctions can also have legal consequences for individuals involved, including severe monetary fines and imprisonment.

SCHEDULE 1
TO SANCTIONS POLICY

INFORMATION AND DOCUMENTATION REQUIRED FOR THE DUE DILIGENCE PROCESS

Details of the entity

It is mandatory to gather all the supporting documentation that accredits the information collected.

Details of the natural person/individual:

Enhanced due diligence (EDD) will be conducted for high-risk clients/Third Parties and transactions, which may involve:

• Obtaining additional information about the client's business activities and source of funds.
• Consulting external experts or utilizing third-party verification services.
• Seeking approval from senior management before proceeding with the business relationship or transaction.

SCHEDULE 2
TO SANCTIONS POLICY

RESTRICTED TERRITORIES

The Company doesn’t carry its business in and enter into relevant agreements with any client, counterparty or third party from the territories listed below:

• Afghanistan;
• Burma (Myanmar);
• Burundi;
• Central African Republic;
• Côte d'Ivoire;
• Crimean Peninsula;
• Democratic People's Republic of Korea;
• Democratic Republic of the Congo;
• Haiti;
• Islamic Republic of Iran;
• Kuwait;
• Liberia;
• Libya;
• Mali;
• Nicaragua;
• Donetsk and Luhansk regions of Ukraine;
• Republic of Cuba;
• Republic of Guinea;
• Republic of Guinea-Bissau;
• Republic of Iraq;
• Sierra Leone;
• Somalia;
• South Sudan;
• Syrian Arab Republic;
• The northeastern portion of the island of Cyprus;
• Yemen;
• Zimbabwe.