Sanctions Compliance Policy

SANCTIONS COMPLIANCE POLICY

Scope

Neo Kraken Maritime and Ship Services Limited Company (hereinafter referred to as the "Company" or "Neo Kraken Shipping") has developed this Sanctions Compliance Policy as part of its Sanctions Compliance Framework.

The Company adheres to this Sanctions Compliance Policy (the "Policy"), which establishes the minimum standards and guidelines to mitigate the risks associated with sanctions compliance, as well as reputational, legal, and operational risks arising from engaging in business relationships or transactions involving sanctioned individuals, entities, vessels, cargoes, or countries.

As a core principle, the Company is committed to aligning all its operations with the framework outlined in this Policy, taking into account the nature of its maritime and shipping activities and complying with all applicable laws and regulatory requirements in the jurisdictions where it operates.

Regulatory Compliance

The Company is committed to complying with all applicable sanctions laws and regulations in every jurisdiction where it conducts business.

Neo Kraken Shipping integrates sanctions-related regulatory requirements and relevant guidance into its operational and compliance processes, particularly within the maritime and shipping sectors. Sanctions compliance checks are enforced in accordance with, but not limited to, the following authorities and regulatory regimes:

• United States – Office of Foreign Assets Control (OFAC)
• United Nations (UN)
• European Union (EU)
• United Kingdom – Office of Financial Sanctions Implementation (OFSI)

In the event of any conflict between the requirements set out in this Policy and the applicable laws, regulations, or guidance of any jurisdiction, the Company shall document such conflict and escalate the matter to the relevant client or counterparty for advisory and compliance assessment.

Objectives

The objectives of this Policy are to:

• Demonstrate the Company's commitment to full sanctions compliance.
• Define and articulate the Company's sanctions compliance checks in line with its sanctions risk profile.
• Identify higher-risk areas within the Company's maritime, shipping, and operational activities.
• Establish appropriate controls for client, vessel, cargo, and transaction screening.
• Document the obligation to report potential sanctions breaches to competent authorities.
• Define the role of independent testing and review within the Company's sanctions compliance framework.
• Outline the responsibilities of personnel handling sanctions compliance matters.
• Ensure that all departments maintain up-to-date sanctions compliance practices and respond effectively to regulatory changes.

In addition, this Policy aims to:

• Maintain effective controls to prevent and mitigate potential sanctions breaches.
• Establish processes for sanctions-related reviews and risk assessments.
• Protect the Company's reputation from involvement in or facilitation of business with sanctioned countries, organizations, individuals, entities, vessels, or cargo.
• Safeguard the Company against legal, financial, and reputational risks arising from violations of applicable sanctions regimes.

Sanctions Compliance Commitment

Neo Kraken Shipping is fully committed to complying with sanctions laws and regulations applicable to its operations, including those related to maritime, shipping, port agency, transit agency, shipyard, and cargo-related services.

The Company strictly prohibits the establishment or continuation of any business relationship, as well as the execution of any transaction, directly or indirectly, for or on behalf of any sanctioned individual, entity, country, organization, vessel, or cargo, in violation of applicable sanctions laws.

This Policy establishes minimum standards to ensure that:

• No sanctioned individuals, entities, vessels, or cargo are involved in the Company's operations.
• Maritime transactions, shipments, and cargo movements are monitored to prevent sanctions violations.
• Employees, contractors, and service providers do not engage in prohibited transactions or activities.
• Thorough investigations are conducted when potential matches with sanctioned parties are identified.
• Sanctions lists used for screening clients, vessels, and transactions are regularly updated.
• Licensing requirements for transactions involving sanctioned jurisdictions are properly managed.
• Sanctions-related reports and suspicious activity notifications are prepared and submitted where required.
• Employees receive regular sanctions compliance training specific to shipping and maritime operations.
• Accurate records related to sanctions compliance are maintained.
• A risk-based framework is implemented to assess and manage sanctions risks associated with vessels, cargo, and counterparties.

Authorised Person(s) and Executive Management Responsibilities

The Authorised Person(s) and Executive Management of Neo Kraken Shipping are fully accountable for ensuring compliance with all applicable sanctions laws and regulations.

They are responsible for ensuring that sufficient resources, systems, and processes are in place to support effective sanctions risk management across all Company operations, including maritime and shipping-related services.

Authorised Person(s) Responsibilities

• Ensure that the Sanctions Compliance function has adequate authority and independence.
• Oversee the implementation of this Policy and related sanctions controls across all departments.
• Establish direct reporting lines between the Sanctions Compliance function and senior management.
• Recognize the seriousness of potential sanctions breaches and implement preventive measures.
• Address deficiencies or failures in sanctions compliance and ensure corrective actions are taken.

Sanctions Compliance Function Responsibilities

The Sanctions Compliance function is responsible for implementing, maintaining, reviewing, and updating this Policy, subject to approval by the Authorised Person(s).

The Compliance Officer is responsible for overseeing sanctions risk assessments across all Company operations, including shipping, vessel operations, cargo handling, and international trade activities.

Key responsibilities include:

• Keeping the Policy aligned with evolving sanctions regulations.
• Providing sanctions advisory support to operational and commercial teams.
• Reviewing and assessing sanctions-related financial crime risks.
• Delivering sanctions training and awareness programs to employees.

Transparency and Compliance

Employees are strictly prohibited from altering, concealing, or misrepresenting information related to transaction parties, vessels, cargo, or documentation to bypass sanctions controls.

Any request to modify or obscure relevant information must be rejected and immediately reported to the Sanctions Compliance function.

Any deviation from this Policy must be reported without delay. The Sanctions Compliance function will assess the risks and advise on appropriate mitigating actions.

Sanctions Non-Compliance and Violations

Failure to comply with this Policy constitutes a breach and may result in disciplinary action, termination of business relationships, or reporting to competent authorities.

Potential sanctions breaches are identified through screening systems, transaction monitoring, and investigations. All suspected breaches are subject to root cause analysis and remediation measures.

Where appropriate, relationships may be restricted, suspended, or terminated to mitigate sanctions risks.

Documentation and Record Retention

The Company retains sanctions-related records in accordance with applicable legal and regulatory requirements, including:

• Licenses authorizing transactions involving sanctioned jurisdictions.
• Sanctions regulatory filings and reports.
• Training records and attendance lists.
• Screening alerts and investigation records.
• Reports related to potential sanctions breaches.

Audit

Internal audits are conducted periodically to assess the adequacy and effectiveness of sanctions compliance controls.

Where deficiencies are identified, prompt corrective actions and compensating controls will be implemented until the root cause is resolved.

Policy Review and Approval

This Policy is reviewed at least annually or as required to ensure continued alignment with regulatory obligations and Company operations.

The Sanctions Compliance function is responsible for maintaining this Policy, and all amendments are subject to approval by the Authorised Person(s).