Sanctions Policy

Secure Capital Group Ltd ("the Company") is fully committed to compliance with all applicable sanctions laws, regulations, and restrictive measures. The Company maintains a zero-tolerance approach to any dealings that would constitute a violation of sanctions obligations.

This Sanctions Policy sets out the Company's framework and procedures for ensuring that its operations, transactions, and business relationships comply with all applicable sanctions regimes.

The Company adheres to the following sanctions regimes:

• United Arab Emirates: sanctions and restrictive measures issued by the UAE authorities, including those implemented under UAE Federal Decree-Law No. 20 of 2018
• United Nations: sanctions and restrictive measures imposed by the United Nations Security Council (UNSC)
• United States: sanctions administered by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury
• European Union: restrictive measures adopted by the Council of the European Union
• United Kingdom: sanctions administered by the Office of Financial Sanctions Implementation (OFSI) under HM Treasury

The Company does not engage in any business, transactions, or dealings, directly or indirectly, with or involving the following prohibited territories:

• Iran (Islamic Republic of Iran)
• North Korea (Democratic People's Republic of Korea)
• Cuba (Republic of Cuba)
• Crimea (Autonomous Republic of Crimea and the City of Sevastopol)
• Kherson Oblast (Ukraine — occupied territories)
• Zaporizhzhia Oblast (Ukraine — occupied territories)
• Donetsk Oblast (so-called "Donetsk People's Republic")
• Luhansk Oblast (so-called "Luhansk People's Republic")

The Company conducts comprehensive sanctions screening of all counterparties, service providers, and business associates prior to establishing any business relationship and on an ongoing basis. Screening procedures include:

• Pre-onboarding screening: all counterparties are screened against all applicable sanctions lists before any business relationship is established or any transaction is executed
• Transaction screening: all transactions are screened for potential sanctions exposure, including the identities of the parties involved, the jurisdictions concerned, and the nature of the transaction
• Periodic re-screening: all existing counterparties are re-screened against updated sanctions lists on a regular basis to identify any changes in sanctions status

The Company monitors and screens against the following sanctions lists, among others:

• OFAC Specially Designated Nationals and Blocked Persons List (SDN List)
• European Union Consolidated List of persons, groups, and entities subject to EU financial sanctions
• United Nations Security Council Consolidated List
• United Kingdom Sanctions List (OFSI Consolidated List of Financial Sanctions Targets)
• UAE Local Terrorist List and other sanctions lists issued by UAE authorities

The Company strictly prohibits the following activities:

• Engaging in any transaction, business relationship, or dealing, directly or indirectly, with any person, entity, or country that is subject to sanctions under any of the regimes listed in this policy
• Facilitating, assisting, or knowingly permitting any transaction or activity that would result in a sanctions violation
• Engaging in any evasive or deceptive practices designed to circumvent or avoid the application of sanctions

Where the Company identifies a potential or actual sanctions match, or suspects that a transaction or business relationship may involve a sanctioned person, entity, or jurisdiction, the matter is immediately escalated to the Money Laundering Reporting Officer (MLRO).

The MLRO is responsible for evaluating the match, determining the appropriate course of action, and filing reports with the UAE Financial Intelligence Unit (FIU) and any other relevant authorities as required by applicable law.

The Company maintains continuous monitoring procedures to ensure ongoing compliance with applicable sanctions regimes. These include:

• Automated re-screening of all counterparties whenever sanctions lists are updated
• Monitoring of sanctions-related developments, including new designations, delistings, and changes to sanctions programmes
• Periodic review and testing of the effectiveness of the Company's sanctions screening tools and procedures

All Company personnel are responsible for:

• Understanding and complying with this Sanctions Policy and all applicable sanctions laws and regulations
• Reporting any suspected sanctions violations or concerns immediately to the MLRO
• Participating in sanctions-related training programmes as required by the Company

Violations of sanctions laws can result in severe consequences, including:

• Criminal penalties, including imprisonment and substantial fines for individuals
• Civil penalties and monetary fines for the Company
• Reputational damage, regulatory sanctions, and potential loss of the Company's license

This Sanctions Policy is reviewed at least annually by the MLRO and senior management to ensure that it remains current, effective, and aligned with the latest sanctions developments and regulatory requirements.

The policy may also be updated on an ad hoc basis in response to changes in sanctions laws, new designations, or emerging risks.

For any questions or concerns relating to this Sanctions Policy, please contact the Money Laundering Reporting Officer (MLRO) at contact@securecapitalgroup.ltd.