SANCTIONS POLICY OF METTMANN PUBLIC COMPANY LIMITED

   1.  WHICH SANCTIONS LAWS APPLY

The Company is incorporated and existing under the Laws of the Republic of Cyprus and has a duty to implement:

• Sanctions adopted by the relevant Security Council Resolution pursuant to Article 41 of Chapter VII of the Charter of the United Nations and Statue of the International Court of Justice, which have direct and immediate application in the Republic of Cyprus, in accordance with the Law 58(I) of 2016 which provides for the Implementation of the Provisions of the Resolutions or Decisions of the United Nations Security Council (Sanctions) and the Decisions and Regulations of the Council of the European Union (Restrictive Measures). In addition, the EU, and consequently the Republic of Cyprus, implement UN sanctions by incorporating them into EU law, through the adoption of relevant Decisions and Regulations within the framework of the Common Foreign and Security Policy.

• Restrictive measures adopted by the Council of the European Union, through the issuance of relevant Decisions (under Article 29 of the Treaty on European Union (Maastricht Treaty)) and Regulations (under Article 215 of the Treaty on the Functioning of the European Union (Treaty of Rome)), within the framework of the Common Foreign and Security Policy, which supersede national law. They are binding legal acts in their entirety for EU Member States and their citizens, requiring direct and immediate application to the integral legal order of EU Member States.

• Any other European legislation or legally binding international instrument related to sanctions.

• Cypriot Law 58(I)/2016 that provides for the Implementation of the Provisions of the United Nations Security Council Resolutions or Decisions (Sanctions) and the European Union Council’s Decisions and Regulations (Restrictive Measures) and Combating of Terrorism and Victims’ Protection Law N. 75(I)/2019 which deals with a number of issues, including the definition of terrorism felonies and the responsibilities of legal persons.  

For the purposes of this Policy collectively referred as “Sanctions Laws”.

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  2.  SANCTIONS COMPLIENCE STATEMENT​

It is the Company’s Policy to comply with all Sanctions Laws in our operations worldwide. To this end, the Company will comply with all economic and trade sanctions applicable to our business activities.

The Company will not conduct business with, or involving any, sanctioned countries, territories, entities individuals or goods and services and will not participate in transactions that would expose the Company to risk of violation of Sanctions Laws.

 

  3.  WHO IS SUBJECT TO THIS POLICY?

This Policy applies to everyone working for the Company worldwide including its overseas entities and its subsidiary companies (“Mettmann Group”) as well as its employees at all levels, directors, officers, interns, agents, external consultants

 

  4. WHAT DO WE MEAN BY SANCTIONS?

Sanctions are penalties or regulatory restrictions applicable to dealings with certain countries/territories, governments, groups, businesses, political groups, natural persons, legal entities, bodies and other legal arrangements (i.e., trusts, funds), terrorist organizations, aircraft or vessels. The nature and extent of these restrictions may vary. Measures, such as arms embargoes and other trade transactions (import/export restrictions), financial restrictions (asset freezes), as well as restrictions on admission (visa or travel bans) are some of the measures most commonly used, depending on the case.

Governments and international bodies use sanctions as a diplomatic tool which act as a lever of pressure, seeking to bring about a change and/or limit activities or policies, such as violations of international law, human rights or policies that do not respect the rule of law or democratic principles, development of weapons of mass destruction or drug trafficking.

In general, Sanctions Laws:

• Prohibit dealing with individuals or entities listed on applicable assets freeze lists, such as the UN list of specially designated nationals and blocked persons, the EU consolidated list of financial sanctions targets, or any list maintained by any relevant authority.

• Prohibit dealing with entities owned or controlled by entities on the lists referred to above.

• Prohibit or restrict dealing with certain countries or territories.

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  5.   WHAT ARE THE RISKS?

Violations of Sanctions Laws may lead to serious civil and/or criminal penalties against companies and individuals, including significant monetary penalties, imprisonment, asset seizures, extradition, blacklisting, revocation of licenses and disqualification of directors.

Additionally, violations of Sanctions Laws can lead to damaging political consequences, including irrecoverable reputation damage and harm to commercial relationships, restrictions in the way the Company does business and extensive time and cost in conducting or defending against various investigations.

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  6.   MEASURES WE TAKE TO ENSURE COMPLIANCE

Mettmann Group must, as a minimum, meet the requirements of this Policy. In any country where the requirements of applicable law(s), directives or practices establish a higher standard, Mettmann Group must meet those standards.

Minimum implementation procedures:

• Screen all counterparties we do business with, understand exactly who we are in business with to avoid association with persons or organizations responsible for actions that are illegal;  

• Screen all jurisdictions we do business with to ensure compliance with sanctions on restricted countries

• Monitor sanctions regimes on an ongoing basis and make sure we do not circumvent, evade or facilitate a breach of Sanctions Laws. The Legal Department is up-to-date with all relevant Sanctions Laws. If you have any questions about our Sanctions Policy you can email aml@mettman.biz. 

• Report any suspicious activities of third parties, to the Board of Directors, which may raise sanctions concerns. Examples of Red Flags to be reported include: lack of information as to the identity of the end-client involved parties and/or the reluctance of a party to provide such information, any suspicion or evidence to suggest the possible involvement of a restricted territory or restricted party. 

 

  7.   MONITORING

The AML Officer along with the Legal Department of the Company shall monitor and evaluate, on an on-going basis, the implementation of this Policy and overall compliance with Sanctions Laws.

The Accounting Department ensures that financial transactions/operations are in line with economic and trade sanctions regulations, by following approved processes and controls.

All Employees shall conduct due diligence checks before any action and refrain from any actions prior to receiving advice and/or instructions from the Legal Department.

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  8.   UPDATES, REVIEW AND OWNERSHIP OF THIS POLICY

The Legal Department on ongoing basis provides updates and guidance on Sanctions Laws to the Company’s employees.  

This Policy will be periodically reviewed and updated by the Company to ensure compliance with new or revised laws and regulations. The latest version of the Policy will be immediately made available on the Company’s website at www.mettmann.biz.

For timely, valid and immediate updates on current EU measures and UN sanctions, you can consult the following sites:

For EU Restrictive Measures

• EU Sanctions Map

• Consolidated List of Sanctions

• European Commission

• Council of the European Union

For UN Sanctions

• General Information

Consolidated List of Sanctions