First Esfand Financial Intermediary Institution

Sanctions Policy Statement of the Website

This Sanctions Policy Statement (“Sanctions Policy”) outlines the sanctions practices for Cbonds website (“Web-site”).

Website is committed to complying with the sanctions laws and regulations of the UAE, European Union, Hong Kong, the United Kingdom, the United Nations, and the United States, as well as other applicable sanctions laws and regulations in the jurisdictions in which company operates, subject to the primacy of local laws and regulations, including:

• Screening customers/clients against the sanctions lists issued by the UAE, United Nations, the European Union, the United Kingdom, the United States and Hong Kong. As of January 2020, these countries and territories include: Iran, Israel, North Korea, Syria, North Sudan.

• Screening locally against other sanctions lists that apply to operations in a particular jurisdiction.

• Prohibiting business activity, including prohibitions on commencing or continuing customer relationships or providing products or services or facilitating transactions that Company believes may violate applicable sanctions laws or Sanctions Policy. This includes prohibitions on business activity with individuals or entities named on a sanctions list or activity, directly or indirectly, involving countries or territories subject to comprehensive sanctions.

• Restricting certain business activity involving, directly or indirectly, countries or persons subject to more selective or targeted sanctions programmes. These sanctions apply restrictions on some types of products or services or target certain industry sectors or governments.

• Investigating all customer/client alerts or transactions that are stopped in banks' screening systems and full cooperation and collaboration with banks on all such cases

• Blocking or rejecting transactions where Company is required to do so under applicable sanctions laws or regulations or Sanctions Policy.

• Reporting breaches of sanctions laws to the relevant regulatory authority. This can include any attempt by a customer to evade sanctions laws.

The Company may, in its sole discretion, also decide not to onboard clients, provide products or services or otherwise facilitate transactions if it suspects the individual or entity to be related to Sanctions list.

The present website adheres to UAE laws and policies and supports for implementation of economic sanctions.

By using our Web-site, you agree to the above provided information and use of information in accordance with this Sanctions Policy