Trade Compliance Policy

This Policy applies to commercial activities conducted through SHOLTI, including the SHOLTI B2B Platform, Private Offers, API-enabled sales channels and other authorised commercial arrangements.

It applies, where relevant, to Buyers, suppliers, recipients, logistics providers and other parties participating in or connected with a transaction.

SHOLTI may apply additional compliance procedures where required by applicable law, the nature of the transaction, the product, the destination or the parties involved.

SHOLTI conducts its operations subject to applicable international trade requirements, including, where relevant:

• economic and financial sanctions;
• export and re-export controls;
• restrictions affecting particular products, brands, destinations or counterparties;
• customs and import/export requirements; and
• other mandatory trade restrictions applicable to a transaction.

The rules applicable to a particular transaction may depend on multiple factors and may change over time.

Accordingly, the availability of a product through SHOLTI does not mean that the product may necessarily be sold, exported, re-exported, imported or delivered to every destination or Buyer.

SHOLTI may conduct compliance checks on Buyers and other parties connected with a transaction.

Such checks may include, where appropriate, verification of:

• company or professional status;
• ownership or control information;
• authorised representatives;
• payment parties;
• consignee or recipient information;
• destination;
• transaction structure; and
• other information reasonably required for compliance purposes.

SHOLTI may use internal procedures, information supplied by counterparties and appropriate third-party sources or service providers when conducting such checks.

Successful registration or approval for B2B access does not prevent SHOLTI from carrying out additional checks in relation to a particular transaction.

Product availability may be affected by regulatory requirements, supplier restrictions, brand-related conditions, export controls, sanctions, logistics limitations or other legitimate compliance considerations.

For this reason, SHOLTI may restrict the availability of particular:

• products;
• product categories;
• brands;
• quantities;
• destinations; or
• commercial channels.

Different Buyers may therefore have access to different products or commercial opportunities.

A product being displayed on the SHOLTI B2B Platform, included in an API feed, catalogue, Private Offer or other commercial communication does not constitute confirmation that the product can be supplied for every proposed destination or transaction.

Where reasonably required, SHOLTI may request information concerning the intended recipient, final destination or intended use of goods.

The Buyer must provide accurate, complete and non-misleading information concerning the transaction and must not knowingly conceal or misrepresent:

• the identity of the Buyer;
• the identity of the consignee or recipient;
• the destination of the goods;
• the intended use of the goods; or
• any other material information relevant to applicable trade restrictions.

The Buyer must not use SHOLTI transactions to circumvent applicable sanctions, export controls, customs requirements or other mandatory trade restrictions.

SHOLTI may request documents or information reasonably necessary to evaluate or complete a transaction.

Depending on the circumstances, this may include:

• corporate registration information;
• tax or business identification information;
• information concerning ownership or authorised representatives;
• invoices or supporting commercial documentation;
• consignee or recipient details;
• shipping or transport information;
• import or customs information;
• end-use or final-destination information; and
• other information reasonably required for compliance purposes.

The Buyer must cooperate with reasonable compliance requests and ensure that information supplied to SHOLTI is accurate and current.

Failure to provide requested information may prevent SHOLTI from processing or completing a transaction.

Payment methods, including digital asset payment options where available, may be subject to additional legal, regulatory, AML/KYC, sanctions, jurisdictional and payment-provider requirements. SHOLTI may restrict or decline a payment method where necessary for Compliance purposes.

SHOLTI reserves the right, to the extent permitted by applicable law and the applicable contractual arrangements, to refuse, suspend, hold or cancel a transaction where:

• the transaction may violate applicable law or trade restrictions;
• required compliance checks cannot be satisfactorily completed;
• requested information or documentation is not provided;
• information supplied appears inaccurate, incomplete or inconsistent;
• a relevant party, destination, product or transaction presents an unacceptable compliance risk;
• a supplier or other relevant commercial party imposes a lawful restriction affecting the transaction; or
• proceeding with the transaction could expose SHOLTI or parties involved in its fulfilment to legal or regulatory risk.

SHOLTI may also delay processing while necessary compliance checks are being completed.

Nothing in this Policy requires SHOLTI to complete a transaction where doing so would be unlawful.

Buyers are responsible for ensuring that their activities comply with the laws and regulations applicable to them, the transaction and the destination of the goods.

Unless expressly agreed otherwise, the Buyer or its designated recipient is responsible for destination-country requirements relating to importation, customs clearance, duties, taxes, licences, permits and other local regulatory obligations.

The Buyer must provide SHOLTI with accurate, complete and non-misleading information concerning the Buyer, consignee, recipient, destination and, where requested, intended end use of the goods.

SHOLTI is entitled to assess and process a transaction on the basis of the information and documentation provided by the Buyer, subject to any additional verification that SHOLTI considers necessary or that may be required by applicable law.

The Buyer must promptly inform SHOLTI if any material information concerning the transaction changes before completion of the transaction.

SHOLTI's compliance procedures do not replace or reduce the Buyer's own compliance obligations.

Once goods have been supplied in accordance with the agreed transaction to the Buyer or to the consignee, carrier, freight forwarder or other recipient designated by the Buyer, the Buyer is responsible for any subsequent sale, resale, transfer, shipment, redirection, re-export or other disposition of the goods undertaken by or on behalf of the Buyer.

The Buyer must ensure that any subsequent movement or transaction complies with all applicable sanctions, export-control requirements, customs rules, import restrictions and other mandatory trade requirements.

The Buyer must not provide SHOLTI with false, incomplete or misleading information regarding the destination, consignee, recipient, end user or intended use of the goods. In particular, the Buyer must not identify an intermediate destination or recipient for the purpose of concealing a different intended destination, recipient or transaction structure or circumventing applicable trade restrictions.

Where, following completion of the transaction in accordance with the information provided to SHOLTI, the Buyer or another third party independently sells, transfers, redirects, ships, re-exports or otherwise moves the goods without SHOLTI's involvement, such subsequent activity is outside SHOLTI's control.

To the extent permitted by applicable law, SHOLTI shall not be responsible for any such independent subsequent sale, transfer, redirection, shipment, re-export or other disposition of the goods carried out by the Buyer or another third party without SHOLTI's involvement or contrary to information previously provided to SHOLTI.

If SHOLTI becomes aware of information indicating that a transaction or subsequent movement may involve circumvention of applicable trade restrictions, SHOLTI may refuse, suspend or cancel the relevant transaction, request additional information or documentation, restrict the relevant account, or take other measures reasonably necessary for compliance purposes.

Nothing in this section excludes any obligation or liability of SHOLTI that cannot lawfully be excluded and nothing in this Policy authorises or facilitates circumvention of applicable trade restrictions.

International transactions may involve independent warehouses, 3PL providers, freight forwarders, carriers, customs brokers and other service providers.

The involvement of such parties does not remove or reduce the compliance requirements applicable to a transaction.

SHOLTI may provide relevant transaction information to such parties where reasonably necessary for fulfilment, customs, compliance or other legitimate operational purposes, subject to applicable contractual and data-protection requirements.

A physical logistics route may differ from the contractual or commercial structure of a transaction.

Access to SHOLTI, approval of a Buyer account, presentation of a product, receipt of product data or previous completion of similar transactions does not guarantee that a future transaction will be available or approved.

Trade regulations, supplier requirements, banking restrictions, logistics conditions and other relevant circumstances may change.

Each transaction may therefore be assessed on its own circumstances.

International trade requirements can change without notice.

SHOLTI may modify its compliance procedures, request additional information, restrict particular transactions or change the availability of products, destinations or commercial channels where reasonably necessary to respond to changes in:

• applicable laws or regulations;
• sanctions or export-control measures;
• customs requirements;
• regulatory guidance;
• banking or payment restrictions;
• supplier restrictions; or
• other material compliance considerations.

Where appropriate, SHOLTI may update this Policy to reflect material changes to its compliance framework.

SHOLTI encourages Buyers, suppliers and other business partners to report suspected violations, inaccurate transaction information or other material trade-compliance concerns relating to SHOLTI transactions.

Reports and compliance-related enquiries may be submitted to:

SHOLTI OPERATIONS LLCTbilisi, GeorgiaCompany No. 405883487contact@sholtioperations.com