Sanctions Compliance Policy

1. Scope

ID Shipping Agency (“the Company”) has established this Sanctions Compliance Policy as part of its overall Compliance and Risk Management Framework.

The purpose of this Policy is to define the minimum standards and procedures to identify, assess, mitigate, and manage risks related to international sanctions. The Company is committed to preventing any involvement—directly or indirectly—with sanctioned individuals, entities, vessels, cargoes, or jurisdictions.

This Policy applies to all Company activities, including but not limited to:

1. Ship agency services
2. Turkish Straits (Bosphorus & Dardanelles) transit operations
3. Shipyard and port agency services
4. Crew change, CTM, logistics, and maritime support services
5. International trade and shipping-related transactions

2. Regulatory Compliance

ID Shipping Agency complies with all applicable national and international sanctions laws and regulations in every jurisdiction in which it operates.

Sanctions screening and compliance checks are conducted in accordance with regulations and guidance issued by, including but not limited to:

1. United States – Office of Foreign Assets Control (OFAC)
2. United Nations (UN)
3. European Union (EU)
4. United Kingdom – Office of Financial Sanctions Implementation (OFSI)

In the event of any conflict between this Policy and applicable local laws or regulatory requirements, the Company will document the issue and escalate it internally and, where relevant, advise the client accordingly.

3. Objectives of the Policy

The objectives of this Sanctions Compliance Policy are to:

1. Demonstrate the Company’s commitment to full sanctions compliance
2. Establish a structured sanctions screening and monitoring framework
3. Identify and manage higher-risk clients, vessels, cargoes, and transactions
4. Prevent involvement in prohibited or restricted activities
5. Protect the Company from legal, financial, and reputational risks
6. Ensure timely reporting of potential sanctions breaches to relevant authorities
7. Maintain effective internal controls and documentation standards
8. Ensure staff awareness and continuous training on sanctions compliance

4. Sanctions Compliance Commitment

ID Shipping Agency is committed to full compliance with all applicable sanctions laws and regulations.

The Company will not establish or maintain business relationships, nor execute transactions, for or on behalf of any sanctioned individual, entity, vessel, organization, or country in violation of applicable sanctions regimes.

Minimum compliance standards include:

1. Screening clients, counterparties, vessels, and beneficial owners
2. Monitoring cargoes, routes, and shipping activities
3. Preventing the involvement of sanctioned goods or destinations
4. Investigating and resolving potential sanctions matches
5. Maintaining updated sanctions lists and screening tools
6. Managing licensing requirements where applicable
7. Reporting suspicious or prohibited activities when required
8. Maintaining accurate records and audit trails

5. Management & Authorised Person Responsibilities

Senior Management and Authorised Person(s) are fully accountable for ensuring effective sanctions compliance across all Company operations.

They are responsible for:

1. Providing sufficient resources, systems, and authority to the Sanctions Compliance function
2. Overseeing the implementation and effectiveness of sanctions controls
3. Ensuring direct reporting lines between compliance functions and senior management
4. Addressing compliance deficiencies and implementing corrective actions
5. Demonstrating zero tolerance toward sanctions violations

6. Sanctions Compliance Function Responsibilities

The Sanctions Compliance function is responsible for the development, implementation, and ongoing review of this Policy.

Key responsibilities include:

• Keeping the Policy aligned with regulatory developments
• Advising departments on sanctions-related risks
• Overseeing sanctions screening and monitoring processes
• Conducting risk assessments related to maritime and shipping operations
• Delivering regular sanctions awareness and training programs

7. Transparency and Ethical Conduct

Employees are strictly prohibited from modifying, concealing, or misrepresenting information to bypass sanctions controls.

Any request to alter or omit relevant data—such as vessel details, cargo descriptions, ownership structures, or transaction parties—must be rejected and immediately reported to the Sanctions Compliance function.

8. Sanctions Breaches and Reporting

Any failure to comply with this Policy is considered a breach.

Potential sanctions breaches are identified through:

1. Automated screening systems
2. Transaction monitoring
3. Payment rejections or alerts
4. Internal or external notifications

All potential breaches must be escalated to the Sanctions Compliance function for investigation, remediation, and reporting to authorities where required. The Company may suspend or terminate relationships where necessary.

9. Record Keeping and Retention

ID Shipping Agency maintains accurate and complete records in accordance with applicable legal and regulatory requirements, including:

1. Sanctions licenses and approvals
2. Regulatory reports
3. Screening results and alerts
4. Training records
5. Investigation and remediation documentation

10. Audit and Monitoring

Internal audits are conducted periodically to assess the effectiveness of sanctions controls.

Any identified deficiencies are promptly addressed through corrective and preventive measures to ensure ongoing compliance.

11. Policy Review and Approval

This Policy is reviewed at least annually or when regulatory changes occur.

All updates and amendments are approved by the Company’s Authorised Person(s) and Senior Management.