Economic Sanctions Compliance Policy

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UOM is committed to conducting business in accordance with all applicable laws and regulations and through adherence to the highest ethical principles and corporate best practices. One aspect of this commitment is UOM’s compliance with applicable laws and regulations governing economic sanctions against certain countries, entities, groups, individuals and designated vessels.

It has been, is, and shall continue to be the policy of UOM to fully comply with and not contravene all applicable laws and regulations, including but not limited to, U.S. and EU laws and regulations governing economic sanctions, and laws of states implementing UN mandated sanctions. The foregoing policy also requires that UOM will not engage in a transaction or activity if that transaction or activity, in UOM’s judgment, poses an unacceptable risk of UOM’s violation and/or contravention of applicable sanctions laws and regulations and/or of UOM’s Insurances and financing commitments.

Consistent with this policy and taking a sanctions risk-based approach, UOM will carefully scrutinize, screen, and take other preventive measures with respect to any and all relevant dealings and trade with or which in any way involves or may involve countries, persons (individuals and entities) and vessels against which the United States, the European Union and the United Nations maintain economic sanctions.

UOM will only conduct business in accordance with applicable sanctions, including in accordance with any waiver or an exception to otherwise applicable prohibitions.

To ensure compliance with and non-contravention of applicable laws and regulations which are governing economic sanctions, it is the corporate policy of UOM to make all UOM personnel aware of applicable sanctions prohibitions and requirements, and conduct compliance due diligence and screening to ensure that violations or contraventions of sanctions are avoided.