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A-FLOWMining Supply Solutions

30 N Gould St #69113, Sheridan, WY 82801, United States

10 Miles, Chibombo, Lusaka Province, Zambia

+1 307-204-0466 · info@aflowsolutions.com

DRAFT · Draft for legal review — not yet approved for use.

Public policies · Zambia edition

Sanctions & Trade Compliance Policy

How A-flow screens counterparties and avoids dealings with sanctioned persons, goods, and territories.

Commitment

A-flow Mining Supply Solutions, of 10 Miles, Chibombo, Lusaka Province, Zambia complies with applicable international sanctions, including U.S. sanctions administered by the Office of Foreign Assets Control (OFAC) and with the trade laws of every country in which it operates.

Screening

  • Every client, supplier, carrier, and agent is screened against applicable sanctions lists before engagement and periodically afterwards.
  • Beneficial owners holding 25% or more are identified and screened.
  • Vessels, terminals, and origins of imported product are checked where relevant.

Prohibited dealings

A-flow does not deal directly or indirectly with sanctioned persons or entities, or with territories subject to comprehensive sanctions, and does not help any party to evade sanctions.

Red flags and escalation

Unusual routing, reluctance to share ownership information, requests to pay third parties, or inconsistent documents are escalated to compliance@aflowsolutions.com and must be resolved before a transaction proceeds.

Records

Screening results and supporting documents are kept for at least five years.

A-flow Mining Supply Solutions · Controlled document · Version 0.1Reliable Fuel → Uninterrupted Power