Bramble Cay Ltd.

Bramble Cay Oy

This statement describes the company’s basic approach to sanctions compliance and trade-related due diligence in connection with its normal business activities.

The company seeks to ensure that it does not engage, directly or indirectly, in transactions with sanctioned persons, entities, or countries, or in transactions that would violate applicable sanctions or be seen as an attempt to circumvent them.

As the company is small, these checks are carried out by management as part of the normal review of counterparties, payments, and business transactions. In practice, this means that the company:

1. Checks the counterparty, the country in which it operates, and its payment details before starting cooperation or making payments.
2. Reviews whether the transaction fits the company’s normal business activity and whether it has a clear commercial rationale.
3. Where needed, reviews available information about the supplier or customer from open sources, including the company’s official website, LinkedIn, Facebook, Instagram, and general Google search results and mentions.
4. Where relevant, also considers the intended use of the goods and the identity of the end recipient.
5. Does not work through non-transparent arrangements involving unclear intermediaries or third-party payments without a clear reason.
6. Keeps invoices, shipping documents, order records, and payment documents.
7. If a transaction or payment raises concerns, reviews it further and, if necessary, declines to proceed.

The company does not knowingly do business with sanctioned persons or entities, with companies or persons located in sanctioned jurisdictions, and it does not trade with countries that are subject to sanctions restrictions.

The company also keeps normal business records in order to support transparency and compliance in its commercial activity.