Trade Sanctions Policy

Policy and Procedures for Compliance with International Trade Laws

It is the policy of Ben Line Agencies, its subsidiaries, and affiliates (together, "BLA" or the "Company") that the Company and its directors, officers and employees must comply fully with all applicable laws, including laws of the United Nations, United States, the Member States of the European Union, and other countries governing international trade transactions and activities. In light of global compliance best practices, while not legally required, BLA comports itself as a U.S. Person for economic sanctions compliance purposes. It is the responsibility of each BLA director, officer and employee to become familiar with and follow this Policy and Procedures for Compliance with International Trade Laws (hereinafter, "Policy" or "Procedures").

It is the responsibility of every director, officer, and employee of the Company (together, "Company personnel" or "BLA personnel") to ensure compliance with this Policy. It is the responsibility of the Compliance Director to ensure that this Policy is made known to all Company personnel, that appropriate training occurs with respect to this Policy, and that all questions or issues raised with respect to this Policy and compliance with its requirements are fully addressed.

Responsibility for compliance with the requirements of this Policy rests with the management of the Company. All Company personnel with business management responsibility, from the Managing Director down to subordinate members of Company management, shall be responsible for assuring the compliance with the requirements of this Policy by Employees and Business Partners for whom they have supervisory responsibility. Any gaps in understanding the requirements of these policies should be brought to the attention of the Compliance Director so that these gaps may be addressed through formal or informal training.

The Board of Directors periodically shall assess the manner in which Company senior management is discharging such responsibility, and Company senior management periodically shall assess the manner in which subordinate members of Company management similarly are discharging such responsibility.

Any questions concerning these laws, or the Policy should be directed in the first instance to the Compliance Director, or, alternatively, to the Managing Director:

Matthew Soloman

Compliance Director

Mobile   +60 3 7932 7066

matthew.soloman@benline.com.my

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Kristian Vandermeer

Group Managing Director

Direct   +65 6420 9070

kristian.vandermeer@benlineagencies.com

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1.    Economic Sanctions Laws

The United Nations, United States, the Member States of the European Union and other countries have adopted economic sanctions laws that restrict activities and transactions with, in or involving certain specified countries, individuals, companies and organisations subject to sanctions programs. This includes the nationals of specified countries, and other designated entities (including vessels) and individuals. The restrictions on the sale and/or shipment of products, as well as related activities, often apply regardless of the type of products being sold or shipped, or the location from which the sale or shipment originates.

1.1 Screening Parties to Transactions

Before agreeing to provide any products or services to a particular customer, BLA personnel first must conduct and document screening efforts confirming that none of the parties involved - including the customer and, if known and applicable, the customer's customer - is on or covered by any of the lists on the linked Internet websites provided below.
A consolidated screening list is maintained by the U.S. government and is accessible here: https://www.export.gov/csl-search.

Please note that these lists are revised and updated periodically. Therefore, it is essential to consult the lists at the time of the proposed transaction. Records regarding screening efforts should be retained for five years.

If any transaction party is on or covered by one of these lists, the transaction cannot be pursued further. The rejection of the enquiry must be immediately logged with the Compliance Director.

1.2 Comprehensive Sanctions Programs

As of the date of these Procedures, transactions, and activities with, in, or involving the following countries (and the associated "Comprehensive Sanctions Programs") - including with.entities located in these Countries or with nationals of these Countries - are subject to significant economic sanctions programs maintained and administered by one or more governments:

Cuba, Iran, North Korea, Syria

No trade in any form to/from these countries, and no business with any individual or company connected to these countries, including those knowingly trading, is permitted. If there is any link, stated or implied, the transaction must be rejected and logged with the Compliance Director.

Transactions and activities with, in or involving countries, individuals, companies or organisations subject to Comprehensive Sanctions Programs -- including with entities located in these Countries or nationals of Sanctioned programs wherever located -- whether directly or indirectly, are not permitted without advance written clearance from the Compliance Director. As a general matter, written clearance will not be provided for prohibited transactions and activities with, in or involving these Countries.

Due to variations in sanctions programs, consultation with the Compliance Director is encouraged.

The Company's Trade Sanctions Country Guidelines contains summaries of economic sanctions programs that may apply to activities of the Company, including sanctions applicable to the Countries noted above.

1.3 High-Risk Sanctions Programs

As of the date of these Procedures, transactions, and activities with, in, or involving the following High-Risk countries - including with entities & individuals, require extensive due diligence to be undertaken.

Russia & the Crimea region of Ukraine and Venezuela

The Company's Trade Sanctions Country Guidelines contains summaries of sanctions programs that may apply to activities of the Company, including sanctions applicable to the Countries noted above.

1.4 Specially Designated Nationals

The U.S. Government prohibits transactions involving certain individuals and entities deemed to be affiliated with, or supportive of, the subjects of Sanctions programs, or otherwise deemed to have engaged in illicit activities. This list includes terrorists and narcotics traffickers as well as shipping companies and their agents. The current list of Specially Designated Nationals includes thousands of individuals and entities; it can be accessed on the Internet at http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/defauIt.aspx (a search faciIity allowing searching by names is also available at http://sdnsearch.ofac.treas.gov. "Specially Designated Nationals" include not only individuals and entities identified on the list, but also any entity in which such persons directly or indirectly own an aggregate ownership interest of 50% or more.

Transactions with or involving Specially Designated Nationals, whether directly or indirectly, must be rejected and logged with the Compliance Director.

2.    Export Control Laws and Anti-Boycott Laws

2.1 Export Control Laws

Complementing the economic sanctions laws, the United States, the Member States of the European Union, and many other countries have adopted export control laws that regulate the export and re-export of goods, software, and technology to specified destinations and end-users for specified purposes and applications. These laws apply to intra-company transfers as well as to dealings with third parties. Export control laws may prohibit a particular export or re-export of goods, software or technology.

Similar to economic sanctions lists, the United States and other countries maintain various export controls lists (e.g., Entity List, Denied Persons List, Unverified Persons, etc.) with varying restrictions.

Please refer to the screening requirements discussed in Section 1.1 above, ensure that no parties to our transactions are included on any such lists, and retain records of screening efforts. The Compliance Director should be consulted if there are any questions./p>

2.2 Anti-Boycott Laws

U.S. export control laws and associated regulations contain provisions generally prohibiting U.S. persons and certain of their non-U.S. affiliates from cooperating in third country boycotts that the United States does not support, such as the Arab League boycott of lsrael.
As of 23 July 2021, the list of countries that the U.S. Government believes require or may require participation in, or cooperation with, an international boycott includes: Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, and Yemen. The list is published quarterly by the U.S. Department of Treasury and can be accessed on the Internet at https://www.federalregister.gov under "List of Countries Requiring Cooperation with an International Boycott".

Under certain circumstances even the receipt of a request to cooperate in a boycott must be reported to the U.S. Government.
Similarly, the Internal Revenue Code requires that U.S. persons, including U.S. corporations, submit annually to the U.S. Internal Revenue Service a report detailing (1) their operations in or related to boycotting countries and (2) their receipt of boycott requests and any agreements to comply with such boycott requests. U.S. tax laws impose certain boycott-related reporting requirements on U.S. corporations as well.

The anti-boycott prohibitions and the reporting requirements are broad and complex. Accordingly, it is imperative that BLA personnel who receive boycott-related requests contact the Compliance Director prior to responding in any way to such requests and seek guidance on whether and how to respond.

Any questions concerning these laws or BLA's policy or procedures should be directed to the Compliance Director.

Matthew Soloman

Compliance Director

Mobile   +60 3 7932 7066

matthew.soloman@benline.com.my

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