SANCTIONS POLICY

In this document, the following terms have the meanings set out below:

  • “Recipients”: All individuals acting in the name and on behalf of the Euricom Group. This includes: Employees, the Administrative Body, Supervisory Bodies, Suppliers, Consultants, Professionals, Contractors, Clients, Companies controlled by Euricom S.p.A., etc.

  • “Euricom S.p.A.” or “Parent Company”: The company controlling the Euricom Group.

  • “FSE”: Foreign Sanctions Evaders list. Published by OFAC, it contains foreign individuals and entities that have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran under Executive Order 13608.
    (https://ofac.treasury.gov/media/5926/download?inline)

  • “Group” or “Euricom Group”: The corporate group headed by Euricom S.p.A.

  • “EU Sanctions Map”: A map of sanction measures adopted by the European Union. EU sanctions against countries, individuals, or entities are issued under the EU’s common foreign and security policy to bring about changes in the policy or activities of a targeted country, part of a country, government, entity, and/or individuals, with the ultimate aim of promoting peace, democracy, the rule of law, human rights, and international law.

  • “External Supplier”: An external organization that provides services to a company. These services can include consulting and other specialized services. Under this Policy, the External Supplier supports Group entities in checking and monitoring whether a Third Party is listed on updated sanctions lists.

  • “OFAC”: The Office of Foreign Assets Control of the U.S. Department of the Treasury. It administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats.

  • “UN”: United Nations. An international organization founded in 1945 to promote peace and international security through a system of collective security.

  • “Sanctions”: Restrictive measures, restrictions, or prohibitions imposed by public international law following violations of laws. These may target individuals, entities, groups, regimes, and countries, and may include economic and diplomatic sanctions, travel bans, arms embargoes, asset or fund freezes, etc. They are imposed in response to actions such as human rights violations, terrorism, nuclear proliferation, annexation of foreign territories, deliberate destabilization of a sovereign country, cyberattacks, and use of chemical weapons. The goal is to restore peace, territorial security, and the rule of law.

  • “SDN”: Specially Designated Nationals list. A list published by OFAC of individuals, entities, and groups, as well as blocked ships and aircraft.

  • “SSI”: Sectoral Sanctions Identifications list. Published by OFAC, it identifies persons operating in sectors of the Russian economy designated under Executive Order 13662.
    (https://ofac.treasury.gov/media/5961/download?inline)
    The directives specify prohibitions relating to dealings with listed persons.

  • “Third Parties” or “The Party”: Natural or legal persons, other than Employees, with whom the Company has business relations. This includes Suppliers (excluding farmers residing in the EU), Consultants, Professionals, Intermediaries, Contractors, Business Partners, Clients, etc.

PREAMBLE

In today’s international regulatory framework for the prevention and combating of terrorism, illegal trafficking, proliferation of weapons of mass destruction, and their financing, there are laws that limit or, in some cases, prohibit transactions or other relationships involving certain countries, territories, and individuals.

The Euricom Group pays particular attention to international sanctions laws, which include economic and diplomatic sanctions, arms embargoes, travel bans, and the freezing of assets or funds.

Given the nature of its business, the Group may be exposed to sanctions or other restrictive measures imposed by various governmental authorities. Failure to manage the risk of violating such measures may lead to sanctions and penalties for the Group and/or its personnel, harm to the company’s brand reputation, and potential criminal proceedings.

For these reasons, the Euricom Group has adopted this Policy to discourage and prevent violations of laws, regulations, embargoes, or other restrictive measures on sanctions applicable in the markets where Group companies operate.

Each Group company undertakes to verify and monitor whether any Third Party with whom it has business relations appears on updated sanctions lists described in this Policy at the time of signing new contracts, renewing existing contracts, or during periodic monitoring of regular business partners.

To manage its exposure to sanctions risk and ensure compliance with sanctions laws, the Euricom Group applies the controls described in the section Control Systems.

SCOPE OF APPLICATION

This Policy applies to all individuals acting in the name and on behalf of the Euricom Group, including Employees, Members of Administrative Bodies, Members of Supervisory Bodies, Suppliers, Consultants, Professionals, Contractors, and companies controlled by Euricom S.p.A.
These individuals are referred to collectively as Recipients.

REGULATORY FRAMEWORK

The Euricom Group is committed to complying with sanctions laws imposed by national and international governments and organizations applicable to its business activities.
Each Group company must stay up to date with the applicable laws and regulations, which are constantly evolving, possibly with the support of external providers.

The Group undertakes to comply with:

1. United States Sanctions Laws

Administered by the Office of Foreign Assets Control (OFAC), U.S. sanctions impose restrictions and prohibitions on transactions or relationships involving certain countries, entities, and individuals. Generally, OFAC restrictions apply to:

  • U.S. companies (and certain affiliates)

  • U.S. citizens and permanent residents, regardless of location

  • Anyone in the United States

There are primary sanctions and secondary sanctions:

  • Primary sanctions apply to U.S. persons, entities organized under U.S. law, and anyone located in the U.S., including U.S. branches of foreign entities. They apply directly because the legal entity or the goods have a U.S. jurisdictional link.

  • Secondary sanctions may be imposed on non-U.S. companies engaging in certain commercial activities with countries targeted by U.S. sanctions, to reinforce the effect of primary sanctions. These have an extraterritorial scope — unlike EU sanctions, which apply only to EU entities and citizens.
    They apply to any company anywhere if:

    1. Transactions are made in U.S. dollars, and/or

    2. They have a link with the United States.

Violating secondary sanctions may result in designation as an SDN.

OFAC Lists

Key lists include:

  1. SDN List – Persons or entities designated as threats to U.S. national security or foreign policy objectives (terrorism, human rights violations, weapons of mass destruction, etc.). U.S. persons may not deal with SDNs or their controlling entities (50% rule).

  2. FSE List – Foreign Sanctions Evaders list (violations related to Iran or Syria).

  3. SSI List – Sectoral Sanctions Identifications list (Russian economy sectors).

2. European Union Sanctions

EU sanctions apply:

  • Within EU territory

  • On board aircraft or ships under an EU Member State’s jurisdiction

  • To EU citizens anywhere

  • To entities incorporated under EU Member State law

  • To companies operating wholly or partly in the EU

They include asset freezes, travel bans, financial restrictions, goods and service restrictions, and other specific measures.
The EU also implements UN sanctions and may adopt stricter measures.

3. United Nations Sanctions

UN sanctions (imposed by the Security Council) may include economic and trade measures, arms embargoes, travel bans, and asset freezes, aimed at maintaining peace, protecting human rights, and preventing terrorism.

4. United Kingdom Sanctions

Implemented under the Sanctions and Anti-Money Laundering Act 2018, these measures align with UN obligations and UK foreign policy and security goals. They apply to all UK persons and entities, wherever located.
Types include trade sanctions, financial sanctions, transport sanctions, and immigration restrictions.

CONTROL SYSTEMS

To ensure compliance, the Group applies:

  • Sanctions screening procedures for Third Parties

  • Contractual clauses confirming compliance with sanctions laws

  • Whistleblowing channels for reporting suspected violations

  • Training programs for employees on sanctions compliance

Third Parties must:

  • Not appear on the SDN list

  • Be excluded from tenders if listed as SDNs

DISSEMINATION AND TRAINING

The Policy is published on the Euricom S.p.A. website and shared across all Group companies.
Training and communication activities are provided to employees to ensure knowledge of the Policy and applicable regulations.

REPORTING

Violations or suspected violations must be reported through the whistleblowing channel provided by each Group company or the Parent Company at:
https://euricom.it/IT/WHISTLEBLOWING/

Reports will be kept confidential and whistleblowers will be protected from retaliation.

DISCIPLINARY SYSTEM

Compliance with this Policy is contractually required.

  • Employees: Disciplinary measures up to dismissal

  • Third Parties: Contract termination and possible damages claims

  • Directors/Supervisors: Suspension or removal from office

APPROVAL AND UPDATES

Approved by the Administrative Body of Euricom S.p.A. and adopted by all Group companies.
Updates due to changes in national or international sanctions laws must be approved by the Administrative Body.