Latest update: 20-02-2026

1. Commitment to Compliance

Sova Trading B.V. is dedicated to conducting its international trade activities ethically and in full compliance with all applicable sanctions laws and regulations. We expect our stakeholders and clients to share this commitment and to prioritize compliance in all business interactions.

Compliance with sanctions law is not treated as a peripheral legal formality. It is a condition of doing business with Sova Trading B.V., and it is embedded in how we select partners, structure transactions, and train our people.

2. Purpose and Scope

Sova Trading B.V. is a company established under the laws of the Netherlands. As such, its primary and legally binding sanctions framework consists of EU sanctions regulations, which apply directly in the Netherlands as EU law without the need for national implementing legislation; UN Security Council sanctions, implemented into Dutch law where not already covered by an EU regulation; and the Sanctions Act 1977 (Sanctiewet 1977), the Dutch domestic law that gives these regimes force in the Netherlands and makes their violation a criminal offense under the Economic Offenses Act (Wet op de economische delicten), with liability that can extend to both the company and the individuals responsible for the breach.

We also take account of sanctions regimes of other jurisdictions, including those administered by the U.S. Office of Foreign Assets Control (OFAC), where they apply to our activities because of a genuine connection to that jurisdiction (for example, U.S. persons, U.S.-origin goods or technology, or transactions clearing in U.S. dollars). Such regimes do not override Dutch and EU law, but we screen against them as a matter of prudent business practice.

This policy defines our responsibilities and procedures to ensure that our activities do not contravene sanctions laws or support prohibited activities. It applies to all employees, suppliers, and clients involved in international trade on behalf of, or in connection with, Sova Trading B.V., regardless of location or business unit. It covers all transactions, products, services, and counterparties involved in our international trade activities, and it operates alongside, and does not replace, any additional obligations arising under local law or contract.

3. Definitions

Sanctions

Restrictive measures imposed by a competent authority (such as the United Nations, the European Union, the Netherlands, or another relevant government) that prohibit or restrict trade, financial transactions, or other dealings with specified countries, regions, entities, or individuals.

Restricted Party List

Any list of sanctioned, denied, debarred, or otherwise restricted individuals, entities, or vessels maintained by a relevant authority, including the UN Consolidated List, the EU Consolidated List, the Dutch National Terrorism List (Nationale Sanctielijst Terrorisme, maintained under the Sanctieregeling terrorisme 2007-II), and, where relevant, the lists maintained by the U.S. Office of Foreign Assets Control (OFAC).

Export Controls

Laws and regulations governing the export, re-export, or transfer of goods, software, technology, or services, including licensing requirements based on item classification, destination, end use, or end user, in particular the EU Dual-Use Regulation (Regulation (EU) 2021/821) and the Dutch strategic goods control framework administered by Dutch Customs.

Screening

The process of checking a counterparty, transaction, or shipment against applicable sanctions and restricted party lists prior to engagement.

CDIU

The Customs Central Import and Export Office (Centrale Dienst voor In- en Uitvoer), the Dutch authority responsible for issuing export licenses and exemptions under Dutch and EU sanctions and export control law.

4. Prohibited Activities

Sova Trading B.V. strictly prohibits the export, re-export, or transfer of goods, software, technology, or services to countries, entities, or individuals subject to comprehensive sanctions, embargoes, or restrictions imposed by relevant authorities. We do not engage in business with individuals, organizations, or entities listed on applicable sanctions or restricted party lists, including the Dutch National Terrorism List.

In addition, our products and services may not be used, directly or indirectly, in connection with:

the development, production, handling, or use of nuclear, chemical, or biological weapons, or their means of delivery;

activities that support terrorism or the financing of terrorism; or

activities that facilitate or contribute to violations of human rights.

Any employee, supplier, or client who becomes aware of a transaction that may fall within these prohibitions must immediately halt the activity and escalate it in accordance with the Reporting and Monitoring section below.

5. Due Diligence and Screening

Sova Trading B.V. implements robust screening procedures for customers, partners, and transactions against relevant sanctions and restricted party lists, including the UN Consolidated List, the EU Consolidated List, and the Dutch National Terrorism List, to ensure compliance with applicable regulations. Screening is performed before onboarding a new counterparty and before executing a transaction, and is repeated on an ongoing basis to capture updates to sanctions lists.

Where a screening result raises a potential match or other red flag, the transaction or relationship is placed on hold pending review by the compliance function, and is not progressed until the concern has been resolved.

6. Asset Freezing

Where a business relation, counterparty, or transaction is confirmed to correspond to a listed individual or entity, Sova Trading B.V. immediately freezes any funds or economic resources within its control that belong to, or are held for the benefit of, that party, and makes no funds or economic resources available to them, directly or indirectly. This freezing obligation is separate from, and applies in addition to, our refusal to enter into or continue the underlying business relationship.

7. Export Control Classification and Licensing

Our products and technologies are classified to identify whether they are subject to export controls and to determine whether specific licenses or authorizations are required prior to export, re-export, or transfer. Classification is documented and kept current, and no controlled item is shipped or transferred without the licenses or authorizations that classification determines are required.

Where a license is required, Sova Trading B.V. applies for it from the CDIU, the Dutch authority responsible for issuing export licenses and exemptions. Outbound and inbound shipments are subject to compliance checks by Dutch Customs, and Sova Trading B.V. cooperates fully with such checks.

8. Compliance Governance and Responsibilities

Senior management at Sova Trading B.V. is responsible for ensuring compliance with sanctions regulations and for providing the resources, budget, and authority necessary to support these efforts. Senior management designates a compliance owner responsible for the day-to-day administration of this policy, including maintenance of screening procedures, coordination of training, and oversight of reporting and audits.

All employees, suppliers, and clients covered by this policy are responsible for complying with its requirements within the scope of their role, and for raising concerns promptly rather than proceeding in the face of uncertainty. Employees and management should be aware that, under the Sanctions Act 1977, violations of sanctions law are economic offenses that can carry criminal liability for both the company and the individuals responsible.

9. Training and Awareness

Employees whose roles involve international trade, sales, procurement, logistics, or finance receive training on this policy and on applicable sanctions and export control requirements at onboarding and at regular intervals thereafter. Training is updated to reflect material changes in sanctions regimes, Dutch enforcement practice, or this policy.

10. Reporting and Monitoring

Sova Trading B.V. actively monitors for potential violations of sanctions laws or of this policy. Employees, suppliers, and clients are expected to report suspected violations or concerns promptly to the compliance function. Reports are handled confidentially, and no employee will face retaliation for raising a concern in good faith.

Where a screening match is confirmed and assets are frozen, Sova Trading B.V. reports this without delay to the competent Dutch authority using the applicable notification format, in addition to any internal escalation. Regular audits and reviews are conducted to assess the effectiveness of our trade compliance program and to identify areas for improvement. Findings from audits are reported to senior management, and corrective actions are tracked to completion.

11. Recordkeeping

Records relating to screening checks, classification determinations, licenses, training, audits, and reported concerns are retained for the period required by applicable law and are made available to relevant authorities upon lawful request.

12. Non-Compliance and Disciplinary Action

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment, and may result in termination of a supplier or client relationship. Suspected violations of law are reported to the relevant authorities as required, and, as noted above, may carry criminal liability under the Sanctions Act 1977 independent of any internal disciplinary outcome.

13. Policy Review and Updates

This policy is communicated to all relevant stakeholders and is periodically reviewed and updated to reflect changes in applicable laws and regulations. We are monitoring the Dutch Sanctions Modernization Bill, which is expected to introduce a dual enforcement system (administrative fines alongside criminal prosecution), a single Central Notification Centre Sanctions for reporting, and new sector supervisors, and we will update this policy and our internal procedures when that legislation takes effect. Questions about this policy, or requests for guidance on a specific transaction, should be directed to the compliance function.

This policy is reviewed periodically to reflect changes in applicable sanctions and export control law.