COMPLIANCE & RESPONSIBLE TRADE
Effective Date: September 4, 2026
Compliance & Responsible Trade
NeyMar Global ImEx Inc. is committed to conducting international commodity trading and supply activities responsibly and in accordance with applicable laws, regulations, sanctions, export controls, and other legal requirements relevant to our transactions.
Our approach is based on careful counterparty review, transaction diligence, appropriate documentation, and responsible commercial practices.
U.S. Sanctions and Trade Restrictions
NeyMar does not knowingly participate in transactions prohibited by applicable U.S. sanctions or other applicable trade restrictions.
Transactions may be reviewed based on the parties involved, ownership and control, country or territory, product, origin, destination, end use, payment structure, and other relevant factors.
Where appropriate, transactions may be declined, suspended, or subjected to additional review.
Counterparty Due Diligence
NeyMar may conduct appropriate due diligence on prospective counterparties and transaction participants.
Depending on the circumstances, this may include review of:
- Corporate identity
- Ownership and control
- Beneficial ownership
- Business activities
- Relevant licenses and registrations
- Commercial references
- Transaction participants
- Product and supply documentation
- End-user and end-use information
- Destination and delivery information
KYC and AML
NeyMar supports appropriate Know Your Customer (KYC) and Anti-Money Laundering (AML) practices applicable to its business activities.
We seek to understand the identity and legitimate commercial purpose of counterparties and transactions and may request documentation reasonably necessary for due diligence.
Sanctions and Screening
Relevant parties and transactions may be screened against applicable sanctions, restrictedparty, and other government or regulatory lists.
Where a potential compliance concern or red flag is identified, the transaction may be placed on hold pending appropriate review.
Export Controls
Where applicable to a transaction, NeyMar seeks to evaluate export-control requirements, including applicable U.S. export controls, licensing requirements, product classifications, destinations, end users, and end uses.
NeyMar does not represent that every transaction is subject to the same regulatory requirements; compliance requirements are evaluated according to the facts and circumstances of each transaction.
Product and Documentation Review
Depending on the transaction, NeyMar may request or review documentation relating to:
- Product identity and specifications
- Origin
- Quantity
- Quality
- Inspection
- Ownership or supply authority
- Export authorization
- Transportation and delivery
- End destination
- Other transaction-specific requirements
Anti-Bribery and Ethical Conduct
NeyMar is committed to conducting business with integrity and does not knowingly tolerate bribery, corruption, fraudulent documentation, or improper payments in connection with its business activities.
Business decisions should be based on legitimate commercial considerations and conducted in accordance with applicable law.
Responsible Transaction Review
A transaction may require additional review when circumstances raise concerns involving sanctions, restricted parties, unusual payment structures, unclear ownership, inconsistent documentation, suspicious transaction patterns, unclear product origin, diversion risk, or other compliance concerns.
NeyMar reserves the right to decline or discontinue a transaction when appropriate compliance requirements cannot be satisfactorily addressed.
Documentation and Records
NeyMar seeks to maintain appropriate business and transaction records consistent with applicable legal, regulatory, contractual, and operational requirements.
Commitment to Continuous Improvement
NeyMar recognizes that international trade regulations and compliance risks can change.
Accordingly, our compliance practices may be reviewed and updated as appropriate to our business activities and applicable requirements
Important Notice
This Compliance & Responsible Trade statement describes NeyMar’s general approach to responsible international commerce. It does not constitute a legal certification, government approval, guarantee of compliance for any particular transaction, or representation that every transaction will be permissible.
Specific transactions remain subject to applicable laws, regulations, sanctions, export controls, contractual requirements, and transaction-specific due diligence.