Sanctions Policy

Objective:
Zero Emissions World (ZEW) is committed to ensuring full compliance with sanctions regulations to prevent engaging with individuals, organizations, or entities subject to international sanctions. This policy outlines ZEW’s procedures for screening customers and transactions, freezing funds and assets, and reporting any potential violations.

Legal Framework:
ZEW complies with relevant national and international sanctions regulations, including but not limited to:

Portuguese Legislation: Law No. 83/2017, of August 18^th and Law No. 97/2017, of August 23^rd.

Definitions:

Money Laundering (ML): (i) the conducts provided for and punished by article 368-A of the Penal Code; (ii) the acquisition, possession, or use of goods, with knowledge at the time of their receipt, that they originate from a criminal activity or participation in such an activity; and (iii) the participation in any of the acts referred to in the preceding subparagraphs, the association to commit said act, the attempt and complicity in its commission, as well as facilitating its execution or advising someone to commit it.
Financing of Terrorism (FT): the conducts provided for and punished by article 5-A of Law No. 52/2003, of August 22, with subsequent amendments.
United Nations Sanctions: United Nations Security Council Resolutions on individuals, assets and entities related to money laundering or terrorism financing practices.
European Union Sanctions: European Union resolutions on individuals, assets and entities related to money laundering or terrorism financing practices
High-risk third countries: countries or jurisdictions outside the European Union identified by the European Commission as having national regimes for combating money laundering and terrorist financing that have strategic deficiencies posing a significant threat to the financial system of the European Union, and which are listed by the Financial Action Task Force (FATF) and the Policy Coordination Committee for the Prevention and Combating of Money Laundering and Terrorist Financing.

Combined Framework

This Policy should be read in conjunction with ZEW's Anti-Money Laundering (AML) Policy.

Procedures:

Sanctions Screening

Before entering any business relationship or partnership, as well as, before accepting or delivering funds, ZEW will screen all counterparties, including donors, NGOs, and any recipients of funds, against the relevant sanctions' lists, such as:

European Union Sanctions Lists, including the Consolidated Lists of Persons, Groups, and Entities Subject to Sanctions;
United Nations approved Sanctions Lists; and
Other relevant national and international sanctions lists, as applicable, namely the ones approved by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury and HM Treasury of the United Kingdom, including, respectively, the Specially Designated Nationals and Blocked Persons List of the Office of Foreign Assets Control of the U.S. Department of the Treasury as well as the List of Persons, Entities, and Ships Designated or Specified by the Regulation in force in the United Kingdom.

ZEW’s screening is conducted through research in information made publicly available, namely in the press, information available on the Internet and through duly certified specialized software tools which ZEW has implemented for this purpose.

ZEW will regularly update its sanctions screening process to reflect any changes or additions made to sanctions lists approved by the European Union, the United Nations or other relevant bodies.

In the event that any person, group, legal entity or relevant asset is or becomes included in the aforementioned lists, ZEW will adopt the appropriate actions for the scrupulous compliance with the restrictive measure or sanction, refraining from accepting, authorizing, and/or executing any operation or transaction that may jeopardize the compliance with the mentioned measure or sanction.

In this event, ZEW may refrain from initiating or continuing any business relationship or partnership with said person/group/legal entity.

All transactions, including donations and fund transfers, will be screened at the time of execution and during subsequent transactions to detect any potential links to sanctioned individuals, assets or entities.

In the event that any transaction is found to be related to individuals, assets or entities included in the aforementioned sanctions lists, ZEW will adopt the appropriate actions for the scrupulous compliance with the restrictive measure or sanction, refraining from accepting, authorizing, and/or executing any operation that may jeopardize the compliance with the mentioned measure or sanction.

In this event, ZEW may refrain from processing the transaction.

ZEW may also block or refuse to process any donations that are connected to sanctioned parties, assets or jurisdictions.

Both the identification of the individual, asset or entity in any of the relevant sanctions’ lists, and the decision to adopt certain measures to ensure full compliance with the applicable restrictive measures or sanctions, including the decision to terminate the business relationship/partnership or to refuse to carry out the transaction, are documented in writing.

Persons or entities established in high-risk third countries

If ZEW’s risk-based analysis of a given counterpart, including donors, NGOs, and any recipients of funds, reveals that the person or entity in question is established in a High-risk third country, ZEW will apply the appropriate Enhanced Due Diligence (EDD) procedures.

Upon conclusion of its risk-based analysis, and depending on the specific Money Laundering and Financing of Terrorism risk identified, ZEW’s management decides to:

Accept the business relationship/partnership/transaction;
Reject the business relationship/partnership/transaction; or
Accept the business relationship/partnership/transaction subject to the implementation of monitoring and control measures that, based on the risk of the operation, are deemed necessary or appropriate.

This decision is made in writing and must be duly grounded.

Reporting Violations

ZEW actively cooperates with the competent authorities, both national and European, to ensure full compliance with the restrictive measures and sanctions approved by the European Union and the United Nations as well as in the investigation of any potential violations.

ZEW communicates to the competent national authorities any information it becomes aware that may facilitate the compliance with restrictive measures.

Whenever ZEW executes a restrictive measure or sanction, ZEW immediately informs the competent authorities.

If ZEW detects any potential violation or the attempt of violation of any restrictive measures or sanctions, ZEW immediately informs the competent authorities.

ZEW keeps record of all communications to the authorities made under the law and this Policy.

All communications and contacts made with the competent authorities under the law, applicable regulations, and the provisions of this Policy are covered by a duty of non-disclosure that applies to their existence, content, and any possible or known consequences, which all ZEW team members, including employees, who, for any reason, become aware of these facts must uphold.

Record Conservation

The documents, information and other referenced elements whose retention is required by this Policy must be kept for a period of 7 years.

The retention of the documents, information, and other referenced elements is done on a durable computerized form that ensures conditions for their proper preservation and easy retrieval, as well as immediate access to them whenever requested by the competent authorities.

Awareness

All members of the ZEW team are informed and made aware of this Policy.

ZEW also that all team members are aware of the importance of preventing any kind of non-compliance or violation of national and international sanctions and restrictive measures, ensuring that all team members are well-informed about their roles in preventing prohibited transactions.

The organization promotes a "zero tolerance" culture for Money laundering and Terrorist financing practices and takes proactive measures to identify emerging risks.

Review this Policy

This policy will be reviewed annually and updated as needed to reflect any changes in sanctions and restrictive measures regulations, operational risks, or internal policies.

The review will ensure that ZEW remains compliant with all national and international laws and best practices related to sanctions and restrictive.

Commitment:

Zero Emissions World is committed to maintaining the highest standards of integrity, transparency, and compliance with international sanctions regulations. By adhering to this policy, ZEW ensures that all donations and partnerships are free from involvement with sanctioned individuals, assets or entities, furthering the mission of combating Money Laundering and the Financing of Terrorism while maintaining public trust and legal compliance.