Anti-Terrorism & Trade Sanctions Policy
Purpose
IsoGentiX is committed to full compliance with applicable counter-terrorism financing obligations and trade sanctions regimes. This policy applies to all directors, employees, contractors, and third parties acting on behalf of IsoGentiX.
Applicable legal frameworks
IsoGentiX's operations are subject to sanctions administered by multiple authorities, including the UK Office of Financial Sanctions Implementation (OFSI), the EU, and the United Nations Security Council. All transactions and business relationships must be screened against applicable sanctions lists before engagement.
Prohibited activities
- Making funds or economic resources available, directly or indirectly, to designated persons or entities on any applicable sanctions list
- Entering into business relationships with sanctioned parties without applicable licences or exemptions
- Facilitating the movement of funds that may support terrorism or sanctions evasion
- Structuring transactions to avoid sanctions screening obligations
Screening requirements
Before entering into any commercial relationship — whether with a licensee, investor, data partner, supplier, or agent — IsoGentiX will conduct sanctions screening against UK OFSI, EU consolidated lists, and UN sanctions lists. Screening must be repeated whenever there is a material change in the counterparty's ownership or control.
Any match against a sanctions list must be immediately escalated to a director before any transaction proceeds. No transaction will proceed where there is a reasonable suspicion of a sanctions breach without obtaining appropriate legal advice and, where required, a licence from OFSI or equivalent authority.
Terrorist financing
IsoGentiX will not knowingly receive funds from, or make funds available to, any person or entity associated with terrorist activity. Any suspicion of terrorist financing in connection with IsoGentiX's business must be reported immediately to a director and, where legally required, to the National Crime Agency (UK) via a Suspicious Activity Report.
Training and responsibility
All personnel with responsibilities for entering into commercial relationships or processing payments receive training on sanctions compliance obligations. The Chief Operating Officer has primary responsibility for maintaining this policy and ensuring screening procedures are current.
Reporting
Concerns about potential violations of this policy should be raised immediately with a director or via the Grievance Policy process. No retaliation will be taken against any person reporting a concern in good faith.