Page 13 - Ethics code ISCAR

2 Foreign Policy Sanctions
Each ISCAR Member must strictly comply with all applicable economic and trade sanctions and
embargo programs under U.S. law, local laws, United Nations resolutions, and any other applicable
laws and regulations. This means that no ISCAR Member may engage in any transactions, directly or
indirectly, that involve Cuba, Iran, North Korea, Syria, Venezuela or the Crimea Region of Ukraine, or
any country or region subject to restrictions under applicable local or other laws. For further guidance
on foreign policy sanctions, please refer to the BRK PBPP.

Transactions with Russia. As a result of broad U.S. economic sanctions programs targeting Russia,
no U.S. origin commodities, software, or technology/technical data (collectively referred to as
“items”) subject to U.S. export control laws and regulations (“collectively referred to as “U.S. items”)
shall be exported, reexported, sold, or supplied to customers located in Russia, whether directly or
indirectly (including through distributors, sales agents, or other third-party intermediaries or Business
Associates wherever located). If you believe a transaction with Russia may involve U.S. items, then
ISCAR Compliance Officer must be immediately notified and the transaction shall not proceed
without his/her prior approval.

ISCAR Warehouse

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