Trade Sanctions & Export Controls Policy

Why This Matters

International trade sanctions and export controls exist to promote global security, prevent human rights abuses, and maintain international peace. Violations carry severe consequences including criminal penalties, substantial fines, reputational damage, and loss of our license to operate. More fundamentally, compliance reflects our commitment to operating ethically within the global rules-based system and refusing to support regimes or activities causing harm.

What We're Committed To

1. Full legal compliance - We comply with all applicable sanctions and export control laws including Canadian sanctions (Global Affairs Canada), US sanctions (OFAC), UN Security Council sanctions, and other jurisdictional requirements
2. Pre-engagement screening - All suppliers, contractors, business partners, and counterparties are screened against current sanctions lists before we engage with them
3. Geographic vigilance - We conduct enhanced due diligence for any business involving sanctioned countries, territories, or regions subject to comprehensive or targeted sanctions
4. No circumvention - We do not engage in activities designed to evade or circumvent sanctions, whether directly or through intermediaries, and we do not tolerate evasion by others
5. Ongoing monitoring - We maintain awareness of sanctions list updates and changes to ensure continued compliance with evolving requirements
6. Immediate reporting - Any identified or suspected sanctions violations or risks are escalated to leadership and legal counsel without delay

How We Work

Use professional judgment when assessing sanctions risks in business relationships. Verify the identity and location of counterparties. Question any arrangements appearing designed to obscure ultimate parties or destinations. Monitor for changes in sanctions status of existing relationships. If you're unsure whether a transaction raises sanctions concerns, pause and escalate. Your expertise guides risk assessment - our standards define what's prohibited.

When to Escalate

Contact CEO or IT immediately if:

• A potential business partner appears on sanctions lists or operates in sanctioned jurisdictions
• You become aware of existing relationships with sanctions exposure
• Any party requests arrangements appearing designed to circumvent sanctions
• You receive inquiries from regulatory authorities regarding sanctions compliance
• You're uncertain whether a proposed transaction complies with sanctions requirements