Due diligence policy for counterparties

SEABERRY TECHNOLOGIES DOO BEOGRAD (hereinafter referred to as SEABERRY TECHNOLOGIES DOO) conducts business transparently and in accordance with ethical standards. SEABERRY TECHNOLOGIES DOO operates in strict accordance with policies, rules, procedures and regulations, including those in the areas of corruption, bribery, money laundering, terrorist financing and trade restrictions. SEABERRY TECHNOLOGIES DOO has zero tolerance for any form of unethical or illegal behavior.

This Policy applies to all SEABERRY TECHNOLOGIES DOO employees in relation to any business relationships or contracts with contractors.

SEABERRY TECHNOLOGIES DOO expects that all employees working at any level of the organization, as well as all third parties, including those acting on behalf and/or on behalf of SEABERRY TECHNOLOGIES DOO, including customers, partners, suppliers, consultants, agency employees, contractors and others, comply with the requirements of this Policy.

This Policy provides guidelines and sets forth certain requirements for SEABERRY TECHNOLOGIES DOO employees to ensure that proper due diligence is carried out on SEABERRY TECHNOLOGIES DOO counterparties.

The requirements of the policy also apply to SEABERRY TECHNOLOGIES DOO's counterparties, since their behavior may have serious consequences for SEABERRY TECHNOLOGIES DOO from both a reputational and legal point of view. In this regard, conducting appropriate risk-based due diligence on counterparties is a critical part of ensuring SEABERRY TECHNOLOGIES DOO's economic security and maintaining a high level of business reputation.

The provisions of this Policy apply to interaction with counterparties based on the conclusion of a written agreement, but, if necessary, can be applied to other situations.

At SEABERRY TECHNOLOGIES DOO we adhere to the principles of honesty and openness, such as:
• The principle of legality of obtaining, processing and storing the necessary information about the counterparty. Actions to verify the counterparty do not contradict the law. Therefore, SEABERRY TECHNOLOGIES DOO uses only open sources of information and official services that do not raise doubts from the point of view of legality.
• The principle of complete verification of the counterparty. SEABERRY TECHNOLOGIES DOO does not approach verification of counterparties formally. SEABERRY TECHNOLOGIES DOO collects and analyzes as much data as possible so that the decision on cooperation is as informed as possible.
• The principle of relevance of information about the counterparty. SEABERRY TECHNOLOGIES DOO constantly updates information about its business partners to ensure long-term relationships are maintained.
• The principle of risk differentiation. Depending on the type, complexity, amount, regularity and timing of the transaction, as well as the identification of the counterparty and its form of ownership, SEABERRY TECHNOLOGIES DOO divides the due diligence criteria. The approaches, timing and resources required to carry out verification of counterparties vary.
• The principle of equal rights of inspection participants. In the event that a minimum set of data cannot be collected from open sources to conduct a comprehensive assessment, it is necessary to request the missing documents from the counterparty.
• The principle of reasonable timing of verification of the counterparty. The verification of the counterparty is carried out in SEABERRY TECHNOLOGIES DOO in a timely manner. The duration of the inspection is indicated in internal documents.

Reliability of a counterparty is a complex concept that includes such criteria as financial condition, solvency, judicial practice, law-abidingness, affiliation, productivity, customer focus, etc.
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Due diligence is a set of measures that must be carried out for a comprehensive analysis of the financial, economic and business activities of the counterparty, allowing one to draw a conclusion about its reliability.
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Counterparty is any person interacting with SEABERRY TECHNOLOGIES DOO or acting on behalf and/or on behalf of SEABERRY TECHNOLOGIES DOO, including customers, clients, contractors, suppliers, consultants, advisors, distributors, agents, commercial and other intermediaries.
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Due diligence is a process carried out to assess the risks of interaction with an actual or potential counterparty by collecting, analyzing, managing and monitoring information.
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Unethical behavior is behavior when an SEABERRY TECHNOLOGIES DOO employee or a representative of a counterparty, in the process of interaction or decision-making, neglects moral and ethical standards, social responsibility, violates legislation, including in the field of corruption and commercial bribery, uses unacceptable tools of pressure and coercion, uses manipulation, and operates at an unreasonable level of risk that could cause harm.
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Employee - any employee employed by SEABERRY TECHNOLOGIES DOO on a permanent or temporary basis.

The purpose of this Policy is to ensure the economic security of SEABERRY TECHNOLOGIES DOO when checking counterparties, by identifying, identifying and minimizing risks associated with reliability, as well as confirming that the counterparty in its activities is guided by generally accepted ethical standards of business and adheres to the principles of intolerance to any manifestations of corruption.

SEABERRY TECHNOLOGIES DOO, in order to achieve the goals of this policy, considers the implementation of such tasks as:
• Collection and assessment of information about business partners.
• Maintaining a register of counterparties.
• Collection of due diligence documents.
• Checking counterparties for reliability.
• Ensuring proper storage of financial documents.

To fulfill the objectives of this policy, the due diligence procedure for counterparties is divided into stages. The implementation of each stage can be assigned to employees of different divisions of SEABERRY TECHNOLOGIES DOO.
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Stage 1: Understanding counterparties
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Understanding SEABERRY TECHNOLOGIES DOO's counterparties is the key to eliminating or minimizing legal and commercial risks. SEABERRY TECHNOLOGIES DOO strives to do business with counterparties whose activities are clear and transparent.

To understand who SEABERRY TECHNOLOGIES DOO's counterparties are and the level of risk they pose, it is necessary to perform appropriate due diligence before entering into any business relationship.

Based on the principles of reasonableness, legality, relevance, differentiation and completeness of due diligence information, SEABERRY TECHNOLOGIES DOO provides:
1. Obtaining key information about the counterparty:
- name of the organization, details and registration data, registration address;
- charter of the organization, copy of the registration certificate;
- extract from the unified state register of legal entities;
- website data, instant messengers, search engines;
- information about the founders/owners/ultimate beneficial owners, executive body or directors;
- list of persons authorized to sign documents on behalf of the company and powers of attorney confirming these rights;
- financial statements and audit reports;
- other payment details or delivery addresses;
- bank and payment details;
- confirmation of the completeness, relevance and reliability of the information;
- contact details of the counterparty’s employees;
2. Verification of information received from the counterparty using open, reliable and independent sources.
3. Assessing the nature and history of the counterparty’s activities.
4. Study of information about the interaction of the counterparty with state executive and judicial authorities.
5. Record information on steps taken to perform due diligence and due diligence on the counterparty.
6. Ensuring that all information is stored in a form and manner that guarantees accuracy, integrity and completeness.
7. Organization of updating, updating and revision of information and information about the counterparty.

Stage 2: Checking for Trade Restrictions
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SEABERRY TECHNOLOGIES DOO checks all potential counterparties for trade restrictions imposed by the Governments of the United Kingdom, the United States of America and the European Union. The verification is carried out using open sources and government information systems.
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In the event that a potential counterparty is subject to trade restrictions, enhanced due diligence must be carried out to determine the advisability of further interaction before entering into or continuing a relationship.
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SEABERRY TECHNOLOGIES DOO follows the legislation of the Republic of Serbia and does not interact with organizations that call for the introduction of restrictive measures against the Republic of Serbia, citizens of the Republic of Serbia or Serbian legal entities.

Stage 3: Determine the need for enhanced due diligence
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To determine whether enhanced due diligence is required, SEABERRY TECHNOLOGIES DOO evaluates the overall level of risk posed by a potential counterparty.
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The risk associated with a potential counterparty should be assessed according to the following criteria:
Red flags: suspicious or unusual information, actions or intentions of the counterparty that raise concerns related to corruption or commercial bribery, terrorist financing.
Geography: the location of the counterparty or place of performance of contractual obligations in a region/country where there is a perceived increased risk in terms of corruption or commercial bribery.
Services: the services that the counterparty will provide, or requests to provide, have an increased risk of corruption or commercial bribery.
Goods: products, equipment and other products, the production or import of which indicates an illegal origin associated with corruption or commercial bribery, terrorist financing.
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Enhanced due diligence may be required in other cases based on the characteristics of a particular transaction.
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Red flags
If there is anything unusual, suspicious or otherwise about a counterparty that may raise concerns about corruption or commercial bribery, this should be considered a red flag.
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Red flags include, but are not limited to:
- any behavior that is unethical or illegal;
- unusually high proposed payment for goods or services provided;
- requests for payments that are unusual or opaque;
- requests for commissions or agency fees;
- requests for payments to third parties not participating in transactions;
- any information, including anonymous information, indicating problems related to corruption or commercial bribery;
- unclear or confusing ownership structure;
- lack of an office or work address;
- registration of an organization at the addresses of mass registration of legal entities;
- participation of government officials in the management or decision-making of the relevant transaction;
- offers from the counterparty to make payments (not required by law), give gifts, provide entertainment or hospitality;
- any information about planning the execution of the contract by additionally involved third parties (subcontractors);
- proposals from the counterparty not to enter into legally binding or written agreements;
- any information regarding the counterparty about the forces and means involved to fulfill contractual obligations;
- proposals from the counterparty to conduct financial settlements in cash or other untraceable funds;
- refusal of the counterparty to include in contracts or other legal provisions an anti-corruption clause and other requirements related to corruption or commercial bribery;
- proposals to make payments from any preferential tax zones or offshore jurisdictions that are considered high risk from the point of view of money laundering or terrorist financing;
- any information if the counterparty relies heavily on contacts rather than on professional experience;
- any information about an obvious lack of qualifications or resources required to provide the services;

If one or more red flags are identified regarding a counterparty, the Ethics and Compliance Committee, another SEABERRY TECHNOLOGIES DOO division, or a responsible person determined by the CEO may take the risk of further interaction. Conditional and unconditional criteria for the reliability of counterparties are given in the relevant instructions.
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Geography
SEABERRY TECHNOLOGIES DOO reviews all requests and analyzes any information to determine whether enhanced due diligence is required due to the location of the counterparty or the location of contractual obligations.
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Services
The type of services that a counterparty provides to SEABERRY TECHNOLOGIES DOO affects the level of risk that may be associated with such counterparty. A business partner who is an agent or representative will require enhanced due diligence.
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Goods
SEABERRY TECHNOLOGIES DOO strives and welcomes the commitment of counterparties to use in their activities certified equipment, licensed software, as well as goods whose legal import into the Republic of Serbia has been confirmed. A business partner who is a distributor or supplier will require enhanced due diligence.
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Stage 4: Conduct enhanced due diligence (if required)
Where enhanced due diligence is required, it will typically include the following steps, depending on the circumstances and depending on the nature and extent of the risks identified:
- requesting additional information from a potential counterparty to clarify specific information of concern;
- request for a complete corporate profile and history if the potential counterparty is a legal entity or individual entrepreneur;
- request for a complete employment history, resume, professional recommendations, if the potential counterparty is an individual or self-employed citizen;
- search for information about court proceedings and criminal records of officials;
- requesting recommendations and business references from trusted business partners or other similarly located sources;
- personal visit to the facilities of a potential counterparty (office, production, etc.);
- interviews with representatives of a potential counterparty.
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SEABERRY TECHNOLOGIES DOO may also engage external specialists and consultants to provide assistance or conduct enhanced due diligence. The Ethics and Compliance Committee can arrange this where necessary.
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The Ethics and Compliance Committee determines what should be done and organizes specific controls to mitigate, prevent or correct any risks.
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Stage 5: Formalization of relationships
Relations with the counterparty must be formalized by concluding a written agreement (contract), which, among other things:
- clearly defines goods or services, payment procedure;
- provides that payments are made only from a bank account opened in his country;
- includes appropriate contractual protections.
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Stage 6: Continuous Monitoring
SEABERRY TECHNOLOGIES DOO continuously monitors and, if necessary, re-evaluates the relationship in any circumstance where a new red flag is discovered or it becomes aware of incorrect or incomplete information received regarding a counterparty. The frequency and nature of periodic inspections should take into account the overall level of risk.
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A comprehensive audit of the counterparty is carried out in the event of a significant change in the contractual relationship or its extension, but at least once every six months.

Any employee who becomes aware of a violation of this Policy or any other event or circumstance that results in an actual or suspected violation of applicable laws regarding corruption, bribery, money laundering, terrorist financing and trade restrictions of any counterparty shall escalate the matter in accordance with the Whistleblowing Policy.
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Any questions about this Policy may be directed to the Ethics and Compliance Committee by email at compliance@seaberrytech.com.

In the event of a violation of this Policy, SEABERRY TECHNOLOGIES DOO will initiate an internal compliance audit and, if necessary, involve law enforcement and other competent authorities.
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All SEABERRY TECHNOLOGIES DOO employees are responsible for compliance with this Policy and any other documents aimed at its implementation. Failure to comply with the requirements of this Policy is grounds for disciplinary and other sanctions.