Russian Trade Sanctions Policy

Purpose

This policy is to ensure that the company complies with all applicable sanctions laws and regulations relating to Russia.

Scope

This policy applies to all employees, agents, and representatives of the company, wherever located.

Policy

The company shall not:

» Export or re-export any goods, services, or technology to Russia;

» Provide financial services to any person or entity located in Russia;

» Invest in any Russian entity; or

» Engage in any other activity that is prohibited by applicable sanctions laws and regulations.

Procedures

The company shall establish and implement procedures to ensure compliance with this policy. These procedures shall include, but are not limited to:

» Screening all transactions for potential sanctions violations;

» Conducting due diligence on all potential suppliers and customers;

» Maintaining a list of all sanctioned persons and entities; and

» Training employees on the company's sanctions compliance policy.

Violations

Any violation of this policy may result in disciplinary action, up to and including termination of employment.

Updates

This policy may be updated from time to time to reflect changes in applicable sanctions laws and regulations.

Dr Scott Elliott, Managing Director

June