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IMC

INT’L METALWORKING CO.
Transactions with Venezuela. Due to ongoing and increasing concerns of the U.S. government regarding
political and social developments in Venezuela, the U.S. Department of the Treasury’s Office of Foreign Assets
Control (“OFAC”) and other federal agencies have developed and implemented sanction programs relative to
a variety of specific industries, government agencies and individuals, and specifically identified individuals and
entities. The various sanction programs, when considered in their breadth and complexity, make this a de
facto embargo on Venezuela. As a consequence, IMC has a policy of not doing business with or in Venezuela,
or with individuals or entities that constitute the government of Venezuela. To ensure compliance with the
foregoing laws and sanction programs, no IMC Member may engage in any transaction or conduct of the type
described above that is known to involve Venezuela, directly or indirectly, without prior consultation with IMC
Compliance Officer.

Transactions with Certain Blocked Individuals, Entities and Groups. The United States and other countries in
which IMC conducts business maintain various restricted/denied parties lists, which may prohibit or restrict
IMC Members from engaging in transactions with listed parties and entities owned or controlled by them.
These lists may be issued, updated and/or revoked (sometimes, as often as several times a week) and
published regardless of whether online or in print. The largest and most restrictive U.S. list is the Specially
Designated Nationals and Blocked Persons (“SDN”) List administered by OFAC. Any prospective transactions
or dealings with a party identified on the SDN or any other list administered by OFAC (including parties that
are constructively blocked as a result of OFAC’s 50-Percent Rule), whether directly or indirectly, must be
immediately reported to IMC Compliance Officer and shall not proceed without his/her prior approval.

For all IMC Members, under no circumstances shall U.S. persons, U.S. origin items, or the U.S. Dollar be
involved, whether directly or indirectly, in any transaction or dealing with an individual, entity, aircraft, or vessel
subject to U.S. economic sanctions (including SDNs and SSIs). For these purposes, the term U.S. person
includes any U.S. citizen, U.S. permanent resident alien (green card holder), any person physically present in
the U.S. regardless of immigration status, any entity, bank, or other financial institution organized under the laws
of the U.S. (including their foreign branches), or any person otherwise subject to U.S. jurisdiction (e.g., persons
using the instrumentalities of U.S. interstate commerce, such as internet or other communications services).

Before entering into any transaction, IMC Members should conduct applicable screening of parties, due-
diligence measures and appropriate investigation before engaging with a third party (including vendors and
customers and other Business Associates), to make sure that such parties are not sanctioned or affiliated
with anyone or any entity who is sanctioned.

Furthermore, no IMC Member, may facilitate any transaction with any sanctioned country or region, or take
any action that will cause or may result in a U.S. Person being involved in facilitation of any such transaction.
“Facilitation” includes any unlicensed action by a U.S. Person that assists or supports trading activity with a
sanctions target, by any person. For example, referral of a business opportunity with a sanctioned jurisdiction
by a U.S. Person to a non-U.S. Person, or requesting input from a U.S. Person regarding a transaction that
involves sanctioned parties may be considered prohibited facilitation under the applicable OFAC sanctions
program. Economic and trade sanctions are very broad in nature, especially U.S. programs, under which
prohibitions or other sanctions risks can be extended extraterritorially to the conduct of foreign persons, where
sanctions targets are involved in a transaction.

IMC Members should consult the IMC Compliance team where a concern is raised regarding sanctions, or if
there are any questions or clarifications regarding their compliance with foreign policy sanctions obligations.

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