1. PURPOSE

1.1. The UAB Maremedia Policy on the Implementation of International Sanctions (hereinafter – the Policy) is an internal document of the Company establishing a unified model for compliance with and control of sanctions. Through this document, the Company undertakes to:

• comply with the international obligations of the Republic of Lithuania;
• implement the Common Foreign and Security Policy of the European Union;
• ensure the enforcement of the United Nations sanctions;
• adhere to the sanctions established by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury;
• contribute to the efforts of the international community to maintain peace, stability, the rule of law, and to prevent international terrorism, human rights violations, and unlawful activities.

1.2. This Policy sets out the Company’s internal control measures, procedures, and responsibilities to ensure that, in the course of conducting vehicle sales and brokerage activities, no violations of international sanctions or national restrictive measures occur.

1.3. The Policy is mandatory for all employees of the Company, as well as for any persons who, on behalf of the Company, represent its interests or perform assigned functions.

2. DEFINITIONS AND ABBREVIATIONS

2.1. The following terms, abbreviations, and definitions are used in this Policy:

• Company – UAB “Maremedia”, company code 301915598, VAT payer code LT100004362216, address: Vytauto g. 48B, LT-68296 Marijampolė.
• International Sanctions (IS) – restrictive measures established by the European Union, the United Nations, the U.S. Office of Foreign Assets Control (OFAC), or other international organizations and states.
• Sanctioned Entity – a state, natural or legal person, organization, or group thereof, to which restrictive measures are applied.
• Screening – the verification of partners, clients, suppliers, transactions, and financial operations against sanctions lists.
• Violation – any act or omission that breaches sanctions laws or the Company’s internal regulations.

3. PRINCIPLES OF IMPLEMENTATION OF INTERNATIONAL SANCTIONS

3.1. The Company shall make every effort to ensure that its activities and the transactions it concludes do not violate any applicable international sanctions.

3.2. The Company shall not engage in, permit, or facilitate any activity that would result in a breach of sanctions or create conditions to circumvent them.

3.3. The Company shall not conduct any business with individuals or entities subject to sanctions, nor with entities controlled by such persons or companies.

3.4. The Company shall not operate in territories subject to international sanctions or engage with persons operating within such regions, if doing so would contravene applicable restrictions.

3.5. All employees are required to comply with the legislation governing sanctions and with the Company’s Policy on the Implementation of International Sanctions.

4. INTERNAL CONTROL SYSTEM

4.1. All clients, partners, and suppliers shall be screened in the following databases prior to entering into any transaction:

• EU Sanctions Map;
• OFAC Specially Designated Nationals (SDN) List;
• UN Sanctions List;
• Public lists published by the Ministry of Foreign Affairs (MFA) and the Financial Crime Investigation Service (FCIS) of the Republic of Lithuania.

4.2. The Company’s financial transactions shall be subject to additional supervision by accounting personnel to ensure that no payments are made to sanctioned entities.

4.3. The Company shall ensure that sanctions screening lists are regularly updated and that internal procedures are reviewed whenever international or national regulations are amended.

4.4. Employees responsible for sanctions screening shall be regularly informed of the latest best practices and shall participate in relevant training sessions.

4.5. In cases involving specific or complex issues, the Company shall consult with the competent authorities, including the Ministry of Foreign Affairs and the Financial Crime Investigation Service of the Republic of Lithuania.

5. DUE DILIGENCE OF BUSINESS PARTNERS

5.1. The Company shall conduct due diligence of its business partners:

• prior to entering into transactions;
• prior to amending or extending existing transactions;
• upon changes to sanctions lists;
• and in any other cases where there is a risk of non-compliance with sanctions.

5.2. When assessing partner-related risk, the Company shall take into consideration the partner’s country of registration, tax residence, the country of origin of goods, delivery routes, and other relevant factors.

5.3. If a partner or transaction presents a potential sanctions-related risk, the Company reserves the right to refuse cooperation or to terminate contractual relations.

6. IMPLEMENTING PARTIES AND THEIR RESPONSIBILITIES

• Director – responsible for the implementation of this Policy, allocation of necessary resources, decision-making regarding actions to be taken, and submission of relevant reports.
• Employees – must conduct client and partner screenings, comply with sanction control procedures, and report any identified violations or irregularities.
• Accounting Department – shall review all financial transactions and ensure that no payments are made to sanctioned entities.
• Managers – shall ensure that their respective departments adhere to the provisions of this Policy.

7. INTERNAL CONTROL MEASURES AND IMPLEMENTATIO

7.1. Obligation to Implement Controls.

All employees of UAB Maremedia, regardless of their position, are required to implement the internal control measures set out below in the field of sanctions compliance to ensure the proper application of international and national sanctions.

7.2. Identification of Entities.

The Company shall develop and apply internal procedures designed to identify entities falling within the scope of international and national sanctions and shall ensure that its activities do not breach any sanctions requirements.

7.3. Regular Updates.

The Company shall ensure that sanctions lists and internal procedures are updated without delay whenever discrepancies are identified between them and mandatory sanctions regulations or clarifications issued by competent authorities.

7.4. Periodic Partner Screening.

All business partners (clients, suppliers, intermediaries) shall be subject to periodic screening, taking into account the nature of their activities, country of registration, type of goods or services supplied, connections with high-risk jurisdictions, and any potential involvement in sanctions evasion schemes.

7.5. Employee Awareness and Resources.

The Company shall ensure that employees are familiar with internal rules and procedures, have sufficient resources, and possess access to reliable databases for performing sanctions screening.

7.6. Training.

The Company shall organize regular training sessions for its employees on the implementation of international sanctions to maintain and enhance their competence in this area

7.7. Termination of Transactions.

In cases where there is a reasonable risk that a partner may be associated with sanctioned entities or pose a threat to the Company’s reputation, a decision shall be made—following consultation with the Director or the Company’s legal counsel—to terminate the relevant transactions.

7.8. Cooperation with Authorities.

In cases involving specific or atypical matters, the Company shall cooperate and consult with competent authorities, including the Ministry of Foreign Affairs, the Financial Crime Investigation Service (FCIS), banks, and other financial institutions.

8. FINAL PROVISIONS

8.1. Policy Review. This Policy shall be reviewed at least once a year, or whenever amendments are made to the legal acts of the European Union (EU), the United Nations (UN), the U.S. Office of Foreign Assets Control (OFAC), or the Republic of Lithuania.

8.2. Responsibility for Updates. The Company’s Director shall be responsible for updating this Policy.

8.3. Application of the Policy. This Policy shall apply to the extent that it does not conflict with the laws and/or other applicable legal acts of the Republic of Lithuania.

Approved by: Director Inga Jakulevičienė