Objectives

To comply with the economic and trade sanctions laws and regulations of the United Nations (UN), European Union (EU), United States of America (US), as well as all applicable sanctions laws and regulations (including import and export control regulations) in the jurisdictions which we operate.

Measures

1. This policy sets out the minimum standards in which Kerry Logistics Network must comply with to meet the above obligations. This includes:
   1. Screening customers and transactions against global sanctions lists;
   2. Prohibiting or restricting business activities or transactions or commencing customer relationships that we believe may violate the applicable sanction laws, whether directly or indirectly; or involve individuals, entities or vessels listed on an official sanctions list; and
   3. Blocking or rejecting business activities or transactions where we are obligated to do so under the applicable sanctions laws and regulations.
2. On a risk-based approach, we will screen customers and transactions against global sanctions lists (including but not limited to UN, EU and US sanction lists). Given the volume of transactions and the fact that the scope of sanctions is highly sophisticated and constantly changing, the screening process will be carried out through IT systems with the assistance of the compliance solutions offered by reputable third-party service provider(s) which provide updated database containing global sanctions lists and other risks data and filtering services. Screening will be performed automatically in our system from time to time upon account opening, creation and execution of transactions and/or other circumstances that we deem appropriate according to our policy.
3. We will prohibit or restrict business activities or transactions or commencing customer relationships that we believe may violate the applicable sanction laws, whether directly or indirectly; or involve individuals, entities or vessels listed on an official sanctions list.
4. We do not tolerate any breach of this policy that could jeopardise the soundness and integrity of our Group. Any suspicious transactions should be reported to the designated manager of the local office, and if applicable, regional and global management office. Where necessary, we will also report breaches of sanction laws to relevant regulatory authorities.
5. The effectiveness of this policy will be monitored regularly. Procedures and practices will be reviewed and further practical guidelines may be issued with a view to ensure compliance with sanction laws and regulations.