1. Commitment
Ory will comply with applicable economic sanctions, export controls, import laws, customs requirements, antiboycott rules, and related trade restrictions.
2. Scope
This Policy applies to Ory personnel and controlled operations and informs requirements for brokers, freight forwarders, customs agents, suppliers, customers, financial institutions, and other counterparties.
3. Core Controls
- Screen counterparties, beneficial owners, vessels, banks, destinations, and other relevant parties against applicable restricted-party lists.
- Determine origin, destination, end user, end use, routing, ownership, classification, licensing, and documentation requirements before controlled activity.
- Do not evade restrictions through transshipment, intermediaries, altered documents, split transactions, or indirect dealings.
- Escalate military, intelligence, nuclear, missile, surveillance, dual-use, sanctioned-country, embargoed, or diversion concerns.
- Protect controlled technical data and technology from unauthorized access, including deemed exports and cross-border cloud access where applicable.
- Maintain accurate customs valuation, tariff classification, origin, license, and shipping records.
- Conduct risk-based due diligence and include appropriate contract clauses.
4. Red Flags and Holds
Personnel must promptly escalate unexplained end users, unusual routing, inconsistent documents, cash or third-party payment requests, opaque ownership, refusal to provide end-use information, sanctioned geography, altered marks, or requests to remove compliance language. Ory may temporarily hold a shipment, payment, disclosure, or contract when reasonably necessary to review and resolve a potential compliance concern.
5. Licensing and Government Authorizations
Only authorized personnel may apply for, interpret, or rely on a license or authorization. Conditions must be communicated, monitored, and retained.
6. Records, Training, Reporting
Records must be retained for the period required by applicable law and Ory’s record-retention procedures. Ory will use risk-based screening tools and escalation processes appropriate to the transaction. Executive Management will designate responsible personnel and provide role-appropriate training. Report suspected violations immediately to the Chief Compliance Officer at info@oryminerals.com. Retaliation for good-faith reporting or cooperation is prohibited.