Compliance — sanctions, KYC, AML

Draft. This text is a working draft pending counsel review. The petrochemical business unit's exposure to sanctions-relevant origins requires explicit legal sign-off before publication.

1. Statement

SATco Group operates within the international sanctions and export-control regimes that apply to its activities. We monitor and apply the following sanction lists:

• United Nations Security Council Consolidated List
• European Union Restrictive Measures
• United States OFAC Specially Designated Nationals (SDN)
• United Kingdom OFSI Consolidated List
• Applicable national sanction lists in the jurisdictions of our operating entities (China, Hong Kong SAR, Bahrain, Portugal)

2. Counterparty due diligence (KYC)

Every counterparty — buyer, seller, intermediary, agent — is subject to know-your-counterparty (KYC) due diligence before any transaction is concluded. KYC includes:

• Identity verification (corporate registry, beneficial-ownership lookup, sanctions-list screening)
• Industry and activity check
• Country and end-use review
• Re-screening at defined intervals and on each new transaction

Counterparties unable or unwilling to satisfy our KYC requirements are not transacted with.

3. Anti-money-laundering (AML)

Our AML controls follow the FATF recommendations and are applied across all SATco Group entities. Controls include:

• Documented source-of-funds verification on transactions above defined thresholds
• Suspicious-transaction reporting via the channels mandated in each operating jurisdiction
• Annual AML training for staff with counterparty-facing roles
• Periodic external audit of AML controls

4. Petrochemical-specific posture

The petrochemical business unit holds direct supply relationships with refineries in multiple jurisdictions, including some that are subject to ongoing international restrictions. For each transaction we:

• Verify the cargo's origin against current sanctions
• Verify the destination port and ultimate end-use against current restrictions
• Confirm payment-channel compliance with the relevant national bank's correspondence requirements

Where any element of a transaction would breach an applicable sanction, the transaction is not proceeded with — irrespective of commercial impact.

5. Reporting concerns

If you believe a SATco Group transaction may involve a breach of applicable sanctions, KYC, or AML obligations, please contact our compliance team at arturbastos@satcogrp.com. We treat all reports confidentially and investigate.

6. No legal advice

This statement is informational. It does not constitute legal advice and does not modify any contractual obligation under a separate agreement.