Sanctions Compliance Statement

Our Commitment

Nex Global LLC, trading as Nex Systems (Nex), provides sanctions, politically exposed persons and financial-crime screening technology. We hold ourselves to the same standards we help our customers meet.

Nex is committed to complying with all economic and trade sanctions and export control laws that apply to it, and to making sure that its services are never used by, for the benefit of, or on behalf of sanctioned persons, or to evade sanctions.

This Sanctions Compliance Statement (the Statement) explains the framework Nex follows, the controls it applies to its own business, and what Nex requires of its customers, partners and referrers. It is incorporated by reference into the Nex Systems Terms of Service (the Terms), and the obligations of customers in it form part of the Terms. It should be read with the Acceptable Use Policy and the Anti-Bribery and Corruption Policy.

Nex's senior management is responsible for this Statement and for making sure that Nex has the resources, controls and culture needed to comply with sanctions in practice.

1. Sanctions Framework We Follow

1.1 US sanctions. As a United States company, Nex complies with the sanctions laws and regulations administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC) and the US Department of State, including the Specially Designated Nationals and Blocked Persons List (SDN List) and the rule that entities owned 50% or more, directly or indirectly, by one or more blocked persons are themselves blocked.

1.2 Other regimes. As a matter of policy, and wherever they apply to Nex's activities, Nex also complies with:

• (a) sanctions adopted by the United Nations Security Council;
• (b) restrictive measures adopted by the European Union;
• (c) financial sanctions and trade sanctions of the United Kingdom; and
• (d) the sanctions laws of any other country that apply to a particular customer, partner or transaction.

1.3 Strictest rule. Where regimes differ, Nex applies the stricter requirement, unless doing so would itself breach applicable law.

1.4 Changes. Sanctions change frequently. Nex monitors official publications and updates its controls when sanctions programmes change.

2. Restricted Jurisdictions and Persons

2.1 Comprehensively sanctioned jurisdictions. Nex does not provide services to, or do business with any person located, organised or ordinarily resident in, any country or region subject to comprehensive US sanctions. At present these include Cuba, Iran, North Korea, and the Crimea, so-called Donetsk People's Republic and so-called Luhansk People's Republic regions of Ukraine. This list may change, and Nex applies the list in force at the time.

2.2 Sanctioned persons. Nex does not provide services to, contract with, or make or receive payments from:

• (a) any person on the SDN List or on any other sanctions list maintained by OFAC, the UN, the EU or the UK;
• (b) any entity owned 50% or more, directly or indirectly, or controlled by such persons; or
• (c) any person acting for or on behalf of such persons.

2.3 Higher-risk jurisdictions. For countries subject to targeted or sectoral sanctions, or identified as high risk by the Financial Action Task Force, Nex applies enhanced due diligence and may decline business at its discretion.

2.4 Sanctions screening services. Nothing in this section prevents a customer in a permitted jurisdiction from using Nex services to screen names that appear on sanctions lists. Screening sanctioned persons is the purpose of the services; providing services to them is prohibited.

3. How We Screen Our Own Customers and Partners

3.1 Onboarding. Before entering into a paid subscription, a Government and NPO Program agreement, an Authorised Partner agreement or a Referral Program enrolment, Nex:

• (a) verifies the legal identity of the organisation, and of individual referrers through valid means;
• (b) identifies beneficial owners and controlling persons where appropriate to the risk;
• (c) screens the organisation, its beneficial owners, directors and authorised signatories against applicable sanctions lists; and
• (d) checks the jurisdiction of incorporation, operation and billing.

3.2 Ongoing screening. Nex re-screens its customers, partners and referrers when sanctions lists change and at regular intervals, and reviews any potential match before deciding on action.

3.3 Technical controls. Nex uses reasonable technical measures, such as IP address and location checks at sign-up and log-in, to prevent access from comprehensively sanctioned jurisdictions. Customers must not try to bypass these measures, for example by using a VPN or proxy.

3.4 Payments. Nex accepts payments only from, and makes payments only to, accounts held by the contracting party at regulated financial institutions. Nex does not accept cash or cryptocurrency. Payments are checked for sanctions risk before they are made.

3.5 Free tools. Free online tools on nex.systems are offered openly and as-is. Nex may restrict access to them from comprehensively sanctioned jurisdictions.

4. Customer Obligations and Prohibited Use

4.1 Representations. By ordering or using the services, each customer represents, and repeats on each day of the subscription, that:

• (a) neither it nor any of its owners, directors, officers or, to its knowledge, employees or users is a sanctioned person or is located, organised or resident in a comprehensively sanctioned jurisdiction; and
• (b) it is not owned 50% or more, or controlled, by a sanctioned person.

4.2 Prohibited use. Customers must not, and must ensure that their users do not:

• (a) permit any sanctioned person, or any person located in a comprehensively sanctioned jurisdiction, to access or benefit from the services;
• (b) use the services, or results from them, to help any person evade or avoid sanctions, including by testing which names are or are not flagged in order to structure transactions;
• (c) resell, sublicense or provide the services or their outputs to any third party in breach of sanctions; or
• (d) use the services in connection with any transaction or activity prohibited by sanctions.

4.3 Notification. A customer must notify Nex at legal@nex.systems immediately if it becomes aware that any representation in section 4.1 is no longer true or that a breach of section 4.2 has occurred.

4.4 Consequences. Under Terms 7.7, if Nex reasonably believes that a customer is in breach of this section, or that continuing the services would expose Nex to sanctions risk, Nex may suspend or terminate the services immediately, without notice, liability or refund, and may freeze, block or report as required by law. Fees for the remainder of the term become immediately payable to the extent the law permits.

5. Export Controls

5.1 Software and technology. Nex services, software, Documentation and technology may be subject to US export control laws, including the Export Administration Regulations, and to the export laws of other countries.

5.2 Customer obligations. Customers must not export, re-export or transfer any Nex software, technology or Documentation, or allow access to the services, in breach of those laws, including to any prohibited end user, end use or destination.

5.3 Classification. Information about the export classification of Nex software is available on request at legal@nex.systems.

6. Our Tools Versus Your Obligations

6.1 Supportive technology. Nex provides screening technology. It collects sanctions data through its own systems from official publishing authorities, collects PEP data from open sources, and filters adverse media with AI-assisted tools. These tools support, but do not replace, a customer's own sanctions compliance programme.

6.2 Customer remains responsible. Each customer remains solely responsible for:

• (a) its own compliance with the sanctions and anti-money-laundering laws that apply to it;
• (b) configuring the services, including match thresholds, lists and fuzzy-matching settings, to suit its own risk assessment;
• (c) reviewing, investigating and deciding on every potential match, including confirming results against the official publication where needed;
• (d) blocking, rejecting or reporting transactions and persons as the law requires; and
• (e) any report to a regulator, financial intelligence unit or other authority. Nex never files reports for customers.

6.3 No guarantee. Nex does not guarantee that the services will identify every sanctioned person, that lists will be complete or current at any moment, or that results, including AI-assisted results, are 100% accurate. Update targets for data sources are set out in the Service Level and Support Policy and are targets only.

6.4 No legal advice. Nothing in this Statement or in the services is legal advice. Customers should seek their own legal advice on their sanctions obligations.

7. Governance, Reporting and Contact

7.1 Programme. Nex's sanctions compliance programme follows the elements set out in OFAC's Framework for Compliance Commitments: management commitment, risk assessment, internal controls, testing and audit, and training.

7.2 Responsibility. Senior management has overall responsibility for sanctions compliance. The Compliance Officer oversees day-to-day controls, reviews potential matches about Nex's own customers and partners, and decides on escalation.

7.3 Training. Nex Personnel involved in sales, onboarding, partnerships and finance receive sanctions training when they join and at least once a year.

7.4 Blocking and reporting. Where the law requires, Nex will block or reject property or transactions and report them to the competent authority within the required time.

7.5 Record-keeping. Nex keeps records of its own sanctions screening and decisions for at least five (5) years, or longer if the law requires.

7.6 Review. This Statement is reviewed at least annually and whenever there is a significant change in sanctions programmes or in Nex's business. Nex may update it by publishing a revised version at nex.systems/legal.

7.7 Raising a concern. Anyone with a concern that Nex services may be used in breach of sanctions should contact compliance@nex.systems. Concerns may be raised anonymously and will be handled under the non-retaliation protections in the Anti-Bribery and Corruption Policy.

7.8 Contact. Sanctions questions and due-diligence questionnaires: compliance@nex.systems. Contractual notices: legal@nex.systems. Nex Global LLC, trading as Nex Systems, Wyoming, United States.