Sanctions policy

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1. General provisions

1.1. This Sanctions Policy (hereinafter referred to as the “Policy”) defines the approaches and procedures of Great Stone Limited Liability Company (hereinafter referred to as the “Company”), the owner of the OZTA IT service, to prevent the use of the OZTA service in violation of applicable sanctions restrictions.

1.2. The Company acts as an agent and organizer in the interests of Clients and does not carry out trade in goods, financial intermediation or logistics activities on its own behalf.

1.3. The policy has been developed taking into account:

• sanctions regimes of the UN, EU, USA (OFAC), UK;
• legislation of the Kyrgyz Republic;
• contractual requirements of banks, payment and other partners;
• international best practices of compliance.

1.4. The Policy applies to the use of the OZTA service by Clients, partners and contractors of the Company.

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2. Terms and definitions

2.1. Sanctions are restrictive measures introduced by authorized international and national bodies.

2.2. Sanctions lists - official lists of persons, organizations, ships, aircraft and territories subject to sanctions (including lists of the UN, EU, OFAC, UK).

2.3. Counterparty - Client, partner, supplier or other third party associated with the use of the OZTA service.

2.4. Sanctions risk is the likelihood of violating sanctions restrictions as a result of the provision of services through the OZTA service.

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3. Principles of sanctions compliance

3.1. The company adheres to a risk-based approach and the following principles:

• refusal to provide services if there is an unacceptable risk of sanctions;
• preventing the use of the service to circumvent sanctions;
• documenting key compliance decisions using the Company’s internal means;
• proportionality of checks to the nature of services.

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4. Inspections and risk assessment

4.1. The Company has the right to conduct inspections of Clients and counterparties, including:

• comparison with sanctions lists;
• analysis of the country of registration and jurisdiction;
• assessment of the nature of orders and proposed transactions;
• identifying signs of increased risk.

4.2. The scope and depth of the inspection are determined by the Company independently, taking into account:

• type of Client;
• geography;
• nature of orders;
• requirements of payment and banking partners.

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5. Restrictions and refusal to provide services

5.1. The company has the right to refuse to provide services or suspend the execution of an order if:

• The client or a person related to him is under sanctions;
• the order is related to the sanctioned territory;
• signs of circumvention of sanctions restrictions were identified;
• The client refuses to provide information necessary for risk assessment.

5.2. Such refusal does not constitute a violation of the Company’s obligations and does not entail its liability.

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6. Interaction with government agencies

6.1. The Company interacts with government authorities only in cases and in the manner expressly provided for by applicable law.

6.2. The company does not exercise independent government control and is not vested with supervisory functions.

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7. Responsibilities of Clients and Partners

7.1. Clients and partners undertake:

• do not use the OZTA service in violation of sanctions restrictions;
• provide reliable information at the request of the Company;
• immediately notify the Company of the occurrence of sanctions risks.

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8. Responsibility and restrictions

8.1. The Company is not responsible for the Client's losses caused by refusal or suspension of services under this Policy.

8.2. The company is not responsible for the actions of third parties, including suppliers, carriers and payment organizations.

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9. Relationship with other documents

9.1. This Policy is an integral part of the Company’s Public Offer and is applied in conjunction with the AML/KYC Policy, Payment Terms and Cancellation Policy posted on the OZTA service.

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10. Change of Policy

10.1. The company has the right to change this Policy by publishing a new version in the OZTA service.

10.2. Using the service after the publication of changes means agreement with the updated version of the Policy.

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11. Final provisions

11.1. Applicable law is the legislation of the Kyrgyz Republic.