COTT Electronics Sp. z o.o. International Sanctions Compliance Policy

1. Policy Overview

COTT Electronics Sp. z o.o. (hereafter referred to as "the Company"), a limited liability company registered in Poland under KRS: 0001019972, NIP: 5252944045, REGON: 524484765, with its registered office at Mikołaja Kopernika 30 / 11A, 00-336 Warszawa, Polska, is committed to operating its global business activities within the framework of international law, EU regulations, and Polish law.

This policy delineates the Company's structured approach to ensuring comprehensive compliance with sanctions regimes imposed by the European Union, Poland, the United States, the United Kingdom, and other relevant jurisdictions, while ensuring all decisions are made in compliance with Polish law. We adhere strictly to all applicable sanctions, demonstrating our unwavering commitment to uphold ethical business practices and legal compliance across all jurisdictions in which we operate.

1.1 Legal Framework. This policy is based on and complies with:

• EU sanctions regulations and decisions, including Council Regulations and Common Foreign and Security Policy (CFSP) decisions
• Polish sanctions laws and regulations, including the Act on Special Solutions for Counteracting Support for Aggression against Ukraine (Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę) and other relevant Polish legislation
• UN Security Council sanctions resolutions
• US sanctions administered by the Office of Foreign Assets Control (OFAC)
• UK sanctions administered by the Office of Financial Sanctions Implementation (OFSI)
• Sanctions imposed by other EU member states, where applicable under Polish law

2. Scope and Application

2.1 Universal Applicability. This policy is universally applicable to all employees, directors, officers, affiliates, subsidiaries, contractors, agents, and third-party representatives of COTT Electronics Sp. z o.o., regardless of their location or role within the organization.

2.2 Business Activities Covered. This policy encompasses all business dealings, including but not limited to:

• Procurement and supply chain activities
• Sales, distribution, and service provision
• Financial transactions, including payments and transfers
• Technology transfers and licensing agreements
• Partnerships, joint ventures, and strategic alliances
• Any other form of commercial engagement, particularly in the hospitality sector where we provide IPTV services

2.3 Geographic Scope. This policy applies to all business activities conducted by the Company, whether within Poland, the EU, or internationally, ensuring compliance with all applicable sanctions regimes.

3. Sanctions Lists and Sources

The Company monitors and complies with sanctions lists from multiple jurisdictions, while ensuring all decisions are made in compliance with Polish law:

3.1 European Union Sanctions. We comply with all EU sanctions, including:

• EU Consolidated List of Sanctions (maintained by the European External Action Service - EEAS)
• EU Sanctions Map (www.sanctionsmap.eu)
• Council Regulations implementing UN Security Council resolutions
• EU autonomous sanctions regimes

3.2 Polish Sanctions. We comply with all Polish sanctions, including:

• Sanctions implemented under the Act on Special Solutions for Counteracting Support for Aggression against Ukraine (Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę)
• Polish Ministry of Interior and Administration sanctions lists (www.gov.pl/web/mswia/sankcje)
• Polish National Bank (NBP) sanctions lists and restrictions
• Other Polish sanctions regulations and restrictions

3.3 United States Sanctions. We monitor and consider US sanctions, including:

• Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List
• OFAC Sectoral Sanctions Identifications (SSI) List
• OFAC Consolidated Sanctions List (ofac.treasury.gov)
• US sanctions programs and country-specific sanctions

3.4 United Kingdom Sanctions. We monitor and consider UK sanctions, including:

• UK Sanctions List maintained by the Office of Financial Sanctions Implementation (OFSI)
• OFSI Consolidated List of Financial Sanctions Targets (www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases)
• UK autonomous sanctions regimes

3.5 Other EU Member State Sanctions. We monitor sanctions imposed by other EU member states, where applicable and in compliance with Polish law, including:

• National sanctions lists of EU member states
• Country-specific restrictions imposed by EU member states

3.6 UN Security Council Sanctions. We comply with all UN Security Council sanctions resolutions, which are implemented in EU and Polish law.

3.7 Decision-Making Process. When sanctions from different jurisdictions conflict or when determining which sanctions to apply, we make decisions in compliance with Polish law, prioritizing:

1. Polish sanctions laws and regulations (mandatory compliance)
2. EU sanctions regulations (mandatory for EU member states)
3. UN Security Council sanctions (implemented through EU and Polish law)
4. US, UK, and other jurisdictions' sanctions (considered on a case-by-case basis, ensuring compliance with Polish law and EU regulations)

4. Sanctions Compliance Requirements

The Company acknowledges the complexity of international sanctions laws, which are subject to change based on geopolitical developments and legislative amendments. As such, COTT Electronics Sp. z o.o. pledges to:

4.1 Adherence to Sanctions Lists. Comply with all sanctions lists published by the European Union, Poland, and relevant international bodies (e.g., UN Security Council), as well as monitor US, UK, and other EU member state sanctions lists, ensuring no business dealings contravene the restrictions placed on individuals, entities, or regions. This includes:

• Regular screening of all business partners, customers, suppliers, and third parties against applicable sanctions lists
• Verification that no transactions involve sanctioned individuals, entities, or countries
• Compliance with sectoral sanctions and restrictions on specific industries or activities
• Adherence to asset freeze measures and financial restrictions

4.2 Prohibited Activities. Strictly prohibit any transactions, direct or indirect, that may breach applicable sanctions, ensuring no part of our business operations supports sanctioned activities or contributes to the violation of sanctions laws. This includes compliance with:

• Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine, as amended
• Polish Act on Special Solutions for Counteracting Support for Aggression against Ukraine (Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę)
• Other EU and Polish sanctions regulations applicable to our business activities
• US and UK sanctions, where compliance is required under Polish law or where we determine it is necessary to avoid legal or reputational risks

4.3 Prohibited Transactions. We prohibit transactions with:

• Individuals, entities, or organizations listed on EU, Polish, US, UK, or UN sanctions lists
• Countries or regions subject to comprehensive sanctions
• Entities owned or controlled by sanctioned parties
• Transactions that would circumvent or evade sanctions
• Activities that would violate sectoral sanctions or specific restrictions

5. Due Diligence and Screening Procedures

COTT Electronics Sp. z o.o. commits to rigorous due diligence processes to identify and mitigate risks associated with sanctions compliance:

5.1 Screening Requirements. We conduct comprehensive screening of:

• All new and existing business partners, suppliers, customers, and third parties
• Beneficial owners and ultimate beneficial owners of business partners
• Shipment destinations and origins
• Financial institutions and payment processors
• Any other parties involved in our business transactions

5.2 Screening Sources. Screening is conducted against:

• EU Consolidated List of Sanctions
• Polish sanctions lists and restrictions
• US OFAC sanctions lists (SDN, SSI, and other lists)
• UK OFSI sanctions lists
• UN Security Council sanctions lists
• Other relevant sanctions lists, as determined in compliance with Polish law

5.3 Screening Frequency. Screening is conducted:

• Before entering into any new business relationship
• On a regular basis for existing business partners (at least annually, or more frequently as required)
• When sanctions lists are updated or new sanctions are imposed
• Before processing any significant transaction

5.4 Continuous Monitoring. We continuously monitor transactions for potential sanctions violations, employing advanced compliance software and methodologies where applicable, to detect and prevent breaches. This includes:

• Real-time transaction monitoring
• Automated sanctions screening tools
• Regular review of business relationships
• Monitoring of sanctions list updates and regulatory changes

5.5 Escalation Procedures. Any potential sanctions breach or match is immediately escalated to the Company's dedicated compliance officer or legal department for further investigation and resolution, ensuring compliance with EU and Polish reporting obligations, including:

• Internal investigation and assessment
• Documentation of findings and decisions
• Reporting to relevant authorities, if required by law
• Implementation of remedial measures

6. Employee Training and Awareness

Understanding the critical role of our employees in maintaining sanctions compliance, the Company will:

• Regular Training: Provide regular, mandatory training sessions on sanctions laws and regulations, tailored to the specific roles and responsibilities within the Company, covering EU, Polish, US, UK, and international sanctions frameworks, in compliance with Polish training requirements and EU best practices.
• Compliance Culture: Cultivate a culture of compliance and ethical conduct, encouraging employees to report any suspected breaches of sanctions without fear of retaliation, in line with Polish whistleblower protections (Ustawa o ochronie sygnalistów, implementing EU Directive 2019/1937).
• Policy Awareness: Ensure all employees are aware of this policy and understand their obligations under it, including the requirement to screen business partners and report potential violations.
• Updates and Communications: Provide regular updates on sanctions developments and changes to sanctions lists, ensuring employees stay informed about relevant sanctions regimes.

7. Reporting and Violation Management

7.1 Reporting Obligations. In the event of a suspected violation of this policy or applicable sanctions laws, employees are required to report their concerns immediately through established reporting channels. The Company guarantees a thorough investigation of all reports and will take appropriate corrective actions.

7.2 Investigation Process. All reports of potential sanctions violations are subject to:

• Immediate assessment and preliminary investigation
• Comprehensive review of the facts and circumstances
• Consultation with legal and compliance experts
• Determination of appropriate remedial actions

7.3 Corrective Actions. Appropriate corrective actions may include:

• Immediate cessation of prohibited activities
• Termination of relationships with sanctioned parties
• Disciplinary measures for employees involved in violations
• Adjustments to business practices to prevent future breaches
• Enhanced screening and monitoring procedures
• Legal action or reporting to authorities, such as the Polish Internal Security Agency (ABW), the Polish Financial Intelligence Unit (GIIF), or EU bodies, if required by law

7.4 Regulatory Reporting. We comply with all mandatory reporting obligations under Polish and EU law, including:

• Reporting to the Polish Financial Intelligence Unit (GIIF) in cases of suspected money laundering or terrorist financing, in accordance with the Polish Anti-Money Laundering Act (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu)
• Reporting to the Polish Internal Security Agency (ABW) or other relevant authorities, as required by law
• Compliance with EU reporting requirements and cooperation with EU authorities

8. Sanctioned Countries and Regions

As of the most recent updates, countries and regions subject to sanctions by Poland (in alignment with EU sanctions) include, but are not limited to:

• Afghanistan
• Belarus
• Central African Republic
• Democratic People's Republic of Korea (North Korea)
• Democratic Republic of the Congo
• Iran
• Iraq
• Lebanon
• Libya
• Mali
• Myanmar
• Russia (comprehensive sanctions in response to aggression against Ukraine)
• Somalia
• South Sudan
• Sudan
• Syria
• Venezuela
• Yemen
• Abkhazia and South Ossetia (regions of Georgia)
• Crimea and Sevastopol (regions of Ukraine)

8.1 Dynamic Nature of Sanctions. Sanctions are dynamic and may change in response to geopolitical developments. The above list is not exhaustive and is subject to change. We monitor sanctions updates regularly and adjust our compliance procedures accordingly.

8.2 Official Resources. For the most current and comprehensive list of sanctioned countries, entities, and individuals, please refer directly to the official resources provided by:

• EU: EU Sanctions Map and the European External Action Service (EEAS)
• Poland: Polish Ministry of Interior and Administration and the Polish National Bank (NBP)
• United States: US Office of Foreign Assets Control (OFAC)
• United Kingdom: UK Office of Financial Sanctions Implementation (OFSI)
• UN: UN Security Council sanctions committees

9. Compliance with Polish Law

9.1 Primary Compliance. All decisions regarding sanctions compliance are made in compliance with Polish law, which is the primary legal framework governing our operations as a Polish company. This includes:

• Compliance with Polish sanctions laws and regulations, which are mandatory
• Compliance with EU sanctions regulations, which are directly applicable in Poland
• Consideration of US, UK, and other jurisdictions' sanctions, where compliance is required under Polish law or where we determine it is necessary to avoid legal or reputational risks

9.2 Legal Basis. Our sanctions compliance is based on:

• Polish Act on Special Solutions for Counteracting Support for Aggression against Ukraine (Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę)
• Polish Anti-Money Laundering Act (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu)
• Polish Penal Code (Kodeks karny), including provisions on violations of sanctions
• EU sanctions regulations, which are directly applicable in Poland
• Other relevant Polish and EU laws and regulations

9.3 Decision-Making Authority. Decisions regarding sanctions compliance, including which sanctions lists to apply and how to handle potential conflicts between different jurisdictions' sanctions, are made by our compliance officer and legal department, in consultation with external legal counsel when necessary, ensuring all decisions comply with Polish law.

10. Review and Amendments

10.1 Regular Review. This policy will be reviewed at least annually to ensure its relevance and effectiveness, with revisions made in response to changes in sanctions laws, regulatory guidance, or the Company's operational landscape.

10.2 Updates and Communications. Updates to this policy will be communicated promptly to all relevant stakeholders, in compliance with EU transparency requirements and Polish corporate governance standards. All employees will be notified of significant changes and provided with updated training as necessary.

10.3 Continuous Improvement. We are committed to continuously improving our sanctions compliance procedures, incorporating lessons learned, best practices, and feedback from regulatory authorities and industry peers.

11. Conclusion

COTT Electronics Sp. z o.o.'s International Sanctions Compliance Policy underscores our resolve to conduct business responsibly, ethically, and in full compliance with all applicable sanctions laws, including those of the EU, Poland, the United States, the United Kingdom, and other relevant jurisdictions, while ensuring all decisions are made in compliance with Polish law.

Through steadfast adherence to this policy, we aim to protect our operations from legal risks, maintain our reputation, and contribute to global peace and security efforts. We are committed to maintaining the highest standards of sanctions compliance and will continue to invest in our compliance infrastructure, training, and procedures.

12. Contact Us

For inquiries about this Sanctions Compliance Policy, please contact us at:

Regulatory Authorities:
For reporting sanctions violations or seeking guidance, you may also contact: