Extract to table

Upon becoming effective, the Enhanced Program shall supersede and replace all prior sanctions and export controls compliance policies, procedures, and guidance documents across all Dunmore Group entities

Formal adoption is anticipated on or about October 1, 2023, at which time the Enhanced Program shall become binding on all Covered Entities and Covered Persons as defined herein

For entities in which Dunmore holds less than a fifty percent (50%) equity interest, Dunmore shall use commercially reasonable efforts to cause such entities to adopt sanctions and export controls compliance programs materially consistent with this Policy

All such third parties must be informed of, and must agree in writing to comply with, the sanctions and export controls compliance requirements set forth in this Policy as a condition of their engagement

The Board shall receive quarterly written reports from the Chief Compliance Officer on the status, effectiveness, and material developments of the compliance program

Board approval shall be required for any material exception to, or waiver of, any provision of this Policy