Sanctions & Export Controls

1. Policy Statement

GENURES Technologies OÜ is committed to full compliance with applicable sanctions regimes and export-control laws in connection with all technology trading, brokerage, distribution and procurement activities.

GENURES does not engage in, facilitate or support transactions that violate applicable sanctions or export-control regulations. All transactions are subject to pre-transaction screening and compliance review.

2. Applicable Regulatory Framework

All transactions facilitated by GENURES are subject to applicable:

• —European Union sanctions regulations and restrictive measures
• —Estonian national law and implementing legislation
• —United Nations Security Council sanctions
• —Applicable export-control laws of the country of origin of the technology
• —Applicable U.S. export-control rules (EAR, ITAR) where U.S.-origin technology is involved
• —Destination-country import and export restrictions
• —End-user and end-use restrictions applicable to advanced computing technology
• —Applicable dual-use goods regulations

3. Advanced Computing Technology

GENURES recognises that advanced computing technology — including GPU, FPGA, HPC and related infrastructure — may be subject to specific export-control classifications and destination restrictions.

GENURES conducts pre-transaction screening of:

• —Technology classification and export-control classification number (ECCN) where applicable
• —Destination country and applicable restrictions
• —End-user identity and intended end-use
• —Re-export and re-transfer restrictions

GENURES does not guarantee that any particular technology can be exported to any particular destination. Counterparties are responsible for independently verifying applicable export-control requirements.

4. Sanctions Screening

GENURES screens counterparties, transactions and jurisdictions against applicable sanctions lists including but not limited to:

• —EU Consolidated Sanctions List
• —UN Security Council Consolidated List
• —OFAC Specially Designated Nationals (SDN) List
• —UK Financial Sanctions List
• —Other applicable national and international sanctions lists

GENURES reserves the right to decline any transaction involving a sanctioned party, sanctioned jurisdiction or transaction that raises sanctions-compliance concerns.

5. Counterparty Obligations

Counterparties engaging with GENURES represent and warrant that:

• —They are not subject to applicable sanctions
• —The transaction does not violate applicable export-control laws
• —The intended end-use of the technology is lawful
• —They will not re-export or re-transfer technology in violation of applicable restrictions
• —They will provide accurate and complete information required for compliance screening

6. Contact

Sanctions and export-control compliance inquiries may be directed to: [email protected]