SANCTIONS COMPLIANCE POLICY

1. Introduction

MarketParts MENA Hub W.L.L. ("MarketParts," "we," "our," or "the Company") is a global provider of automotive spare parts and related services. Given the international nature of our business, we are subject to sanctions, export controls, and trade embargoes enforced by various governmental and international authorities, including the United Arab Emirates (UAE), European Union (EU), United Nations (UN), and United States (US). Compliance with these regulations is essential to safeguarding our business integrity and reputation.

This Sanctions Compliance Policy is designed to ensure that MarketParts fully adheres to all applicable sanctions and restrictive measures, mitigating risks and preventing any violations that could lead to severe legal, financial, or reputational consequences for the Company or its employees.

2. Purpose

The purpose of this Sanctions Compliance Policy is to provide a clear framework and set of guidelines for ensuring that MarketParts complies with global sanctions regimes. This policy seeks to:

• Mitigate risks related to international sanctions.
• Ensure compliance with all applicable legal requirements.
• Educate employees, contractors, and partners on how to identify and address potential sanctions risks in the course of our operations.

By adhering to this Policy, we can effectively manage sanctions risks, protect our business from violations, and maintain our reputation as a responsible and compliant organization.

3. Scope

This Policy applies to all employees, officers, directors, contractors, and third-party associates of MarketParts MENA Hub W.L.L. globally. It also extends to all business activities, including those involving partners, suppliers, and customers, whether directly or indirectly controlled by the Company.

We expect all employees and business partners to uphold the principles outlined in this Policy, and we exert influence over our third-party suppliers and clients to encourage them to act in accordance with global sanctions laws.

4. What Are Sanctions?

Sanctions are regulatory measures imposed by governments or international organizations to influence behavior or restrict activities that pose threats to national security or breach international obligations. Sanctions can target:

• Countries or territories (e.g., comprehensive trade embargoes).
• Individuals, businesses, or entities (e.g., asset freezes or travel bans).
• Industries, goods, or technologies (e.g., export/import restrictions).

Sanctions aim to prevent activities such as:

• Terrorism and money laundering.
• Weapons proliferation (e.g., development of weapons of mass destruction).
• Human rights abuses.
• Drug trafficking and other illegal trade activities.

5. Policy Statement

MarketParts MENA Hub W.L.L. is fully committed to complying with all applicable sanctions, export controls, and trade embargoes. We do not conduct or facilitate business activities that would directly or indirectly violate sanctions laws, including transactions involving:

• Countries, territories, or regions under comprehensive trade embargoes or sanctions.
• Entities or individuals subject to sanctions, such as those listed on the Specially Designated Nationals (SDN) list by OFAC or similar lists by the EU or UN.
• Restricted technologies, goods, or services.

We have implemented strict controls to avoid any involvement in sanctionable activities and continuously monitor regulatory changes to ensure ongoing compliance.

6. Sanctions Overview

Sanctions can include:

• Comprehensive embargoes on specific countries (e.g., North Korea, Iran).
• Targeted sanctions on specific individuals, entities, or industries.
• Asset freezes, import/export restrictions, or capital controls.

These sanctions are imposed to enforce international norms, including those related to national security, foreign policy, and human rights protection. We ensure that all employees understand how these measures can affect our operations and transactions globally.

7. Prohibited Activities

The following activities are strictly prohibited under this Policy:

• Direct or indirect dealings with individuals, entities, or governments located in sanctioned countries or regions.
• Exporting, re-exporting, or supplying goods, technologies, or services to restricted regions.
• Engaging in financial transactions or investments that involve sanctioned individuals or territories.
• Circumventing or facilitating a breach of sanctions by engaging in transactions designed to evade or bypass restrictions.

We ensure that all employees, contractors, and third-party partners are fully aware of these prohibitions and adhere strictly to them.

8. Due Diligence and Compliance Measures

MarketParts conducts rigorous due diligence to mitigate sanctions risks, including:

• Screening all counterparties (e.g., customers, suppliers, and partners) against global sanctions lists, including those maintained by the UAE, EU, UN, and US authorities.
• Ongoing monitoring of business activities to ensure that no violations occur through indirect associations with non-compliant third parties.
• Enhanced due diligence for high-risk jurisdictions or individuals/entities subject to targeted sanctions.

We continually update our screening procedures and ensure that our Compliance Team stays informed about changes to the global sanctions landscape.

9. Compliance Monitoring and Reporting

MarketParts has implemented a comprehensive sanctions compliance monitoring program that includes:

• Regular sanctions compliance training for all employees, ensuring they understand the risks and their responsibilities.
• Ongoing monitoring of international sanctions regimes, with immediate updates to internal policies as needed.
• Internal reporting mechanisms for employees to raise concerns about potential sanctions violations. Any suspicious activities must be reported to the Compliance Team immediately for investigation.

10. Consequences of Non-Compliance

Violations of this Sanctions Compliance Policy can result in severe consequences for both individuals and MarketParts, including:

• Disciplinary action, up to and including termination of employment or contracts.
• Severe financial penalties or legal consequences, including asset freezes and criminal charges.
• Reputational damage to the Company, potentially resulting in loss of business relationships and exclusion from the global financial system.

Third parties found to be in violation of this Policy will have their contracts terminated immediately.

11. Training and Education

To ensure that all employees and contractors are well-informed about sanctions compliance, MarketParts commits to:

• Conducting regular training programs that educate staff on sanctions risks and their role in ensuring compliance.
• Providing up-to-date resources and guidance on how sanctions laws may impact daily business operations and decision-making.

All employees are expected to complete this training and apply the knowledge to their work.

12. Speaking Openly and Raising Concerns

We encourage all employees, contractors, and third-party partners to speak openly and report any concerns about possible breaches of this policy through our whistleblowing channels. MarketParts guarantees protection from retaliation for anyone who raises concerns in good faith, even if their concerns are later found to be unsubstantiated.

We take all reports seriously and handle them promptly, in line with our commitment to ethical business practices.

13. Policy Review and Updates

This Sanctions Compliance Policy will be reviewed annually, or more frequently if required by changes in global sanctions regulations or business activities. The latest version of the Policy will be made available on our website and communicated to all employees and relevant third parties.

Version Tracking:

August 2024