Sanctions Compliance Policy
I. Introduction
Artizen is dedicated to upholding economic and trade sanctions laws ("Sanctions") in every jurisdiction in which it operates. This commitment is foundational to our mission to fund breakthroughs in human creativity, ensuring we mitigate and manage the risks associated with primary and secondary Sanctions violations effectively.
II. Policy Applicability
This Sanctions Compliance Policy ("Policy") is applicable to all directors, officers, contractors, employees of Artizen, its subsidiaries, and controlled entities ("Artizen" or "the Company"), affiliates providing management services, and any individual or entity acting on behalf of Artizen (collectively referred to as "Covered Persons").
This Policy supplements Artizen's other codes of conduct, policies, and procedures. In instances of conflict or inconsistency between this Policy and other documents, this Policy will take precedence, unless specified otherwise in contractual agreements.
III. Overview of Sanctions and Prohibited Conduct
Sanctions are enacted by governments and international bodies to promote foreign policy and security objectives. Artizen prohibits business with entities or countries targeted by Sanctions, including transactions involving the sale of ART tokens and cultural Artifacts.
IV. Compliance Measures
Artizen will ensure compliance with U.S., U.K., U.N., and E.U. Sanctions laws, alongside those of other relevant jurisdictions. This involves:
Screening and Due Diligence: Screening transactions and parties against Sanctions lists and undertaking due diligence, especially in high-risk contexts.
Contractual Requirements: Including Sanctions compliance clauses in contracts with third parties, requiring them to adhere to relevant Sanctions laws and this Policy.
Risk Management: Refraining from transactions that pose a reputational risk or violate export laws, regardless of legality.
V. Obligations of Covered Persons
Covered Persons are required to:
Comply with this Policy and conduct due diligence on prospective transactions.
Avoid actions that circumvent Sanctions obligations.
Understand and comply with Sanctions laws applicable due to citizenship, residency, or presence in certain jurisdictions.
VI. Consequences of Non-Compliance
Violations may result in significant legal, reputational, and financial consequences for Artizen and individual Covered Persons. Artizen adopts a zero-tolerance policy towards intentional violations, leading to disciplinary actions or termination.
VII. Reporting of Violations
Covered Persons must report potential violations to the legal department. Retaliation against individuals reporting violations in good faith is strictly prohibited.
VIII. Policy Review and Confirmation
Artizen will periodically review and update this Policy to ensure compliance with evolving Sanctions laws and operational needs. All Covered Persons are expected to adhere to the procedures outlined in this Policy to ensure its effective implementation.
For inquiries or concerns related to this Policy, please contact the legal department at [email protected].