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Sanctions Compliance Addendum

1. OFAC Compliance Program

XenoStep maintains a sanctions compliance program designed around five core elements.

1. Management commitment to sanctions compliance and escalation of potential issues.
2. Risk assessment based on Supplier location, ownership, products, customers, transaction patterns, and payment activity.
3. Internal controls for screening, review, approval, escalation, suspension, and recordkeeping.
4. Testing and auditing of sanctions controls and related procedures.
5. Training for personnel involved in onboarding, payments, risk review, customer support, and operations.

2. Prohibited Persons and Jurisdictions

The Supplier must not be owned or controlled by, act for, sell to, or provide products for any person or entity on the OFAC Specially Designated Nationals and Blocked Persons List or other applicable sanctions list.

The Supplier must not conduct activity through XenoStep involving prohibited jurisdictions, including Cuba, Iran, North Korea, Syria, or Russia-occupied territories, unless XenoStep gives written approval after confirming the activity is legally permitted.

3. Screening Procedures

XenoStep may screen the Supplier, its representatives, directors, officers, UBOs, products, and relevant customer or transaction information at onboarding, annually, upon ownership change, upon material information change, and whenever XenoStep determines screening is needed.

The Supplier must provide information requested for sanctions screening and must not withhold ownership, control, address, nationality, or transaction information.

4. Hit Procedures

If XenoStep identifies a sanctions hit or potential hit, XenoStep may immediately suspend onboarding, product availability, payouts, support actions, or transactions involving the Supplier. XenoStep may investigate the match, request additional information, reject activity, block activity, terminate the relationship, or report to regulators if required.

The Supplier must cooperate with any investigation and must not attempt to route activity around sanctions controls.

5. Supplier Obligations

The Supplier must provide accurate and complete information, promptly notify XenoStep of changes in ownership, control, location, representatives, products, or sanctions status, and cooperate with XenoStep's screening and investigation requests.

The Supplier must comply with all applicable sanctions and export control laws connected to its products, customers, and operations.

6. Controlling Language

This Addendum is prepared in English. A Korean translation may be provided for reference convenience only. If there is any conflict or inconsistency between the English version and any translation, the English version controls in all respects.