Latest update: 23-12-2024

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 prioritize compliance in all business interactions.

Purpose
Sova Trading B.V. upholds strict adherence to international trade laws, including economic and trade sanctions issued by the United Nations, the United States, the European Union, and other relevant authorities. This policy defines our responsibilities and procedures to ensure our activities do not contravene sanctions laws or support prohibited activities. It applies to all employees, suppliers, and clients involved in international trade.

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. Additionally, our products and services may not be used in activities related to the development, production, handling, or use of nuclear, chemical, or biological weapons, nor in activities that support terrorism or violate human rights.

Due Diligence and Screening
We implement robust screening procedures for customers, partners, and transactions against relevant sanctions and restricted party lists to ensure compliance with regulations. Our products and technologies are classified to identify whether they are subject to export controls and to determine if specific licenses are required.

Compliance Responsibilities
Senior management at Sova Trading B.V. is responsible for ensuring compliance with sanctions regulations and providing the resources necessary to support these efforts.

Reporting and Monitoring
We actively monitor for potential violations of sanctions laws or internal policies. Regular audits and reviews are conducted to assess the effectiveness of our trade compliance program and to identify areas for improvement. This policy is communicated to all relevant stakeholders and is periodically updated to reflect changes in applicable laws and regulations.