1. Company: The Coral Oil Company Limited

2. Affiliate: means in relation to the Company any entity controlled, directly or indirectly, by the Company, any entity that controls, directly or indirectly, the Company or any entity directly or indirectly under common control with the Company. For this purpose, “control” of any entity or person means ownership of a majority of the voting power of the entity or person.

3. High Risk Counterparty: Counterparty (Supplier, Bank, Customer) that may constitute a particular risk to the reputation of the company and who should normally be treated as high risk and be subject to enhanced due diligence measures (refer to Due Diligence and Customer Acceptance Policy which should be read in conjunction with the said policy).
4. Sanctions Authorities: includes without limitation the United States of America, the United Nations, the European Union, the United Kingdom, the United Arab Emirates or the respective governmental institutions and agencies of any of the foregoing, including, the Office of Foreign Asset Control of the US Department of the Treasury (“OFAC”), the United States Departments of State and Commerce and the UK Office of Financial Sanctions Implementation (“OFSI”) and “Sanctions Authority” means each of them.

a. OFAC: Office in the US Department of Treasury that manages and enacts economic and trade sanctions based on US foreign policy and national security objectives against specific foreign nations and regimes, terrorists, global drug smugglers, individuals involved in the proliferation of Weapons of Mass Destruction (WMD), as well as other threats to US national security, foreign policy, or economic interests.

b. Specially Designated Nationals (SDN): The United States imposes prohibitions on interactions with particular people, businesses, and entities and restricts assets which may include people, businesses, or other entities that are owned, controlled, or working on behalf of a nation that has been sanctioned. They can also be people, organizations, or businesses that have been designated by OFAC programs that are not country-specific, such as terrorists and drug traffickers. These Specially Designated Nationals are listed by OFAC.

c. Subject to Financial Sanctions (EU): For parties facing sanctions, the European Union continues to impose asset freezes and investment restrictions. They may include people, businesses, or other entities that are owned, controlled, or working on behalf of a sanctioned nation. They can also be people, organizations, or businesses that have been designated under current EU policies that are not country-specific, such as terrorists and drug traffickers. A list of entities under EU financial sanctions is kept up to date by the EU’s External Action Service.

5. Sanctions: Instruments of a diplomatic or economic character that aim to influence actions or practices such transgressions of human rights, international law, or practices that disregard the rule of law or democratic values. Governments, non-state organizations, and/or people may all be the targets of sanctions or other restrictive actions (such as terrorist groups and terrorists). Arms embargoes, other specific or general trade restrictions (such as import and export bans), finance constraints, entrance limitations (such as visa and travel bans), or other measures, if necessary, may be included.

6. Sanctions Lists: means the Sectoral Sanctions Identifications and Foreign Sanctions Evaders lists maintained by US OFAC for “Specially Designated Nationals and Blocked Persons,” the Consolidated List of Financial Sanctions Targets (Asset Freeze Targets and the Investments Ban Lists) maintained by UK OFSI, or any similar lists maintained by, or public announcement of Sanctions designation made by, any of the Sanctions Authorities, each as amended, supplemented, or replaced from time to time.

7. Person connected with a sanctioned country: The following are considered as persons connected with a sanctioned country:

• The government/state of the sanctioned country or any public authority thereof
  Any natural person in, or ordinarily residing in, the sanctioned country
• Any legal person, entity or body having its registered office in the sanctioned country
• Any legal person, entity or body, inside or outside the sanctioned country, owned or controlled, directly or indirectly, by one or more of the above mentioned persons or bodies
• Any natural or legal person, entity or body acting on behalf of or dealing/trading with any sanctioned person or in any sanctioned activity.

8. US Jurisdiction: U.S. sanctions laws are applicable to U.S. citizens acting within the country, regardless of where they are located. U.S. individuals would include employees of U.S. personnel, even if they were working abroad for a non-U.S. corporation, international branches of U.S. banks, and other U.S.-incorporated entities. Additionally, property under U.S. jurisdiction, such as that in the custody of a U.S. person, physically located in the United States, or in some circumstances, subject to U.S. export controls, is susceptible to sanctions administered by OFAC.

The Sanctions Policy is a cornerstone in terms of the Compliance Charter of the company. In terms of responsibilities of implementation and abidance, the roles of the following parties are highlighted below:

Board of Directors:

• Ratify and approve the contents of the Policy as well as any review
• Ensure that the company is equipped with the adequate skills to ensure implementation of the Policy and its requirements
• Ensure strict abidance by management and all concerned staff with the Policy prerogatives
• Ensure all staff is adequately and regularly trained on sanctions abidance

Finance Manager:

• Ensure to abide by the requirements of the policy where all processed financial transactions comply with laws governing economic and trade sanctions, by following approved processes and controls

Compliance Department:

• Ensure Sanctions Policy is regularly updated and at least reviewed semi-annually
• Ensure monitoring of all transactions with any counterparty where said transactions should be in strict compliance with all sanctions regulations
• Determine and approve controls to be followed in specific regions or types of transactions
• Provide guidance on specific situations on request
• Conduct periodic assessments and monitor the processes and controls in place

All Employees:

• Read and follow this Policy, understand and identify any red flags that may arise in the business and to escalate potential compliance concerns to the Compliance Team.
• Report promptly to their line managers and/or to the Compliance Department any known violation to this policy when detected.
• Protect the company’s interests and reputation above commercial gain

No tolerance in breaching any of the applicable sanctions regimes or this Policy. An employee violating this policy will face disciplinary action, which may include employment termination.