Sanction Policy

1. Purpose and Objectives

As an international group, Bizzdesign (i.e. Bizzdesign Group Holding B.V. and its fully owned subsidiaries) is involved in business activities on a worldwide scale and is therefore subject to various regulations that impose restrictions on imports and exports.

The likelihood of Bizzdesign being contacted, directly or indirectly, by a natural or legal person subject to an international sanction or located in a prohibited or restricted country is significant.

The impact of a breach of any of these regulations could be very significant and, therefore, must be considered as a Black risk for the group (see section 6).

To mitigate this risk, Bizzdesign has set up an action plan that applies to its entire ecosystem (each subsidiary, each employee, each partner, each supplier, each customer, etc.).

This action plan is based on the reports and ratings provided by the non-governmental organization, the Transparency International, and the various regulations issued by governments, the European Union and the United Nations.

The most common sanctions are:

Arms and Related Material Embargo: An arms embargo aims to prevent weapons and military equipment from leaving or entering a targeted country;
Financial prohibitions: Financial prohibitions prohibit targeted persons from engaging in financial transactions with, or on behalf of, designated persons. These prohibitions may cover trade in goods, technology or services;
Travel or visa bans on designated individuals;
Freezing of assets (funds and economic resources): An asset freeze is designed to prevent certain individuals, entities, or terrorist groups from gaining access to property or other assets they may hold overseas;
Economic sanctions include import/export bans, investment bans, prohibitions on the provision of certain services, embargoes on certain goods that could be used for internal repression, and controls on the export of certain sensitive goods and technology.

As a result, in many cases, Bizzdesign will not be able to provide services to, or conduct business with, persons, entities or countries subject to sanctions.

2. Policy Requirements

To ensure compliance with this policy, Bizzdesign has set up specific procedures that must be followed by all Bizzdesign employees in all business activities regardless of the country or territory.

Section 6 Glossary provides the definition of what prohibited and restricted countries are.

Appendix 1 provides the list of the Prohibited and Restricted Countries. This list is maintained by the Legal Department of Bizzdesign (“the Legal department”) and is updated whenever there are changes to sanctions regimes.

Bizzdesign is and will be highly vigilant with respect to doing business with partners or
customers in these countries.

3. Scope and Exceptions

This policy is mandatory and applies to all employees, affiliates and contractors of Bizzdesign without exception.

Any request to do business with a restricted country must be submitted to the Legal Department for review. It should include the following information

Name of the prospective customer or partner, its shareholders/owners and officers;
Estimated value of the transaction;
Type of agreement (License, SaaS, Services, etc.);
Details of the products/services.

4. Roles and Responsabilities

It is the responsibility of all Bizzdesign employees and partners making a business proposal to determine whether the prospective partner or customer is located in a country listed in Appendix 1.

It is the responsibility of Bizzdesign partners to determine whether their end customer is located in a country defined by Bizzdesign as prohibited or restricted. However, these partners may seek advice from the Legal Department if necessary.

It is the responsibility of the Legal Department to involve the Chief Financial Officer of Bizzdesign where necessary. The Legal Department performs any necessary checks, including through the use of LEXIS NEXIS.

It is the responsibility of the Chief Financial Officer to thoroughly review all requests and make a final decision based on reasonable grounds.

5. Consequence for Non-compliance

Failure to comply with this Policy and sanction's regulations could result in liability for Bizzdesign, its officers and any individuals involved, as well as huge reputational damages to Bizzdesign. Any business in a prohibited /restricted country put Bizzdesign Group at risk, such risk qualified as a Black risk.

Accordingly, any employee or partners who fails to comply with this policy will be subject to disciplinary action such as dismissal or an immediate termination of the partner agreement only subject to a written notice.

6. Glossary

Term	Definition
Sanctions	Sanctions are restrictions on activity with targeted countries, governments, entities, individuals and industries (‘targets’) that are imposed by entities such as the United Nations (UN), the European Union (EU), the US Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC). OFAC defines economic sanctions as measures imposed against foreign jurisdictions, regimes, as well as individuals and entities involved in harmful activities, such as terrorism, international narcotics trafficking, the proliferation of weapons of mass destruction, and other malicious actors.
Prohibited Countries	Countries where Bizzdesign refuses to operate business. Therefore, any activity with an individual or a company located in such country is strictly prohibited.
Restricted Countries	Countries which have a low score on CPI and are therefore perceived as a country with a high level of risk of corruption. Therefore, any business within this country has to be previously assessed by the Bizzdesign Legal Department.
Corruption Perception Index	The Corruption Perceptions Index (CPI) is published annually by Transparency International since 1995. It ranks countries "by their perceived levels of public sector corruption, as determined by expert assessments and opinion surveys." The CPI generally defines corruption as "the misuse of public power for private benefit".
Black risk	A black risk is a risk of total or at least partial shutdown of a company’s activity in a given country.

7. Contacts

For questions regarding this policy, please contact the Legal Department at
compliance@bizzdesign.com

Appendix 1 – List of Prohibited and Restricted Countries

Type	Countries
Prohibited Countries	Belarus, Burkina Faso, Cuba, Haiti, Iran, Myanmar, Niger, North Korea, Russia, Somalia, Sudan, South Sudan, Syria, Venezuela, Yemen, and the following Ukraine territories: Crimea, Donetsk, Luhansk, Sevastopol, Zaporizhzhia.
Restricted Countries	Afghanistan, Azerbaijan, Bangladesh, Burundi, Cambodia, Cameroon, Center Africa Republic, Chad, China, Comoros, Congo, Democratic Republic of the Congo, Eritrea, Equatorial Guinea, Guatemala, Guinea-Bissau, Honduras, Iraq, Kyrgyzstan, Lebanon, Libya, Liberia, Madagascar, Mali, Mauritania, Mozambique, Nicaragua, Nigeria, Pakistan, Palestine, Paraguay, Tajikistan, Turkmenistan, Uganda, Zimbabwe.