SANCTIONS POLICY

INTRODUCTION AND COMMITMENT

URIGHTCOMPANY FINANCE LIMITED (the "Company") is committed to conducting its business in compliance with applicable economic and trade sanctions laws and regulations and to maintaining a secure and responsible financial environment.

The Company applies a risk-based and proportionate approach to sanctions compliance and does not knowingly engage in or support transactions involving sanctioned individuals, entities, or jurisdictions.

Controls are applied proportionately, taking into account customer profile, transaction characteristics, and geographic exposure.

The Company is registered as a Money Services Business (MSB) with FINTRAC and operates in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and applicable Canadian sanctions legislation, including:

• The Special Economic Measures Act (SEMA)
• The United Nations Act
• The Justice for Victims of Corrupt Foreign Officials Act (Magnitsky Law)

These measures are designed to protect both the Company and its customers from exposure to financial crime and regulatory risk.

SCOPE OF APPLICATION

This Policy applies across the Company's operations and covers:

• Customers (individual and corporate)
• Ultimate Beneficial Owners (UBOs) and authorized representatives
• Transactions, including foreign exchange, money transfers, and virtual currency activity
• Relevant counterparties and partners, where involved in transaction flows, to which the Company may apply sanctions controls.

Sanctions controls are applied prior to onboarding and on an ongoing basis, taking into account the nature of the relationship and associated risks.

SANCTIONS SCREENING APPROACH

The Company applies a layered approach to sanctions screening supported by internal controls and technology.

Customer Screening

Customers are screened prior to onboarding and periodically thereafter. Screening includes individuals, legal entities, UBOs (typically at a 25% threshold), and relevant representatives.

Transaction Screening

Sanctions controls are applied to transactions on a risk-based basis, including review of originators and beneficiaries where relevant.

Virtual Currency Controls (where applicable)

For virtual currency activity, the Company applies additional checks, including risk-based analysis of wallet addresses and transaction flows, where appropriate.

SANCTIONS LISTS USED

The Company utilizes a combination of domestic and international data sources, including:

• Canadian sanctions lists (SEMA and United Nations Act)
• United Nations Security Council sanctions lists
• U.S. OFAC lists (applied on a risk-based basis, particularly for USD exposure)
• Politically Exposed Persons (PEP) and related risk indicators

The Company may also consider publicly available information, such as adverse media, where relevant to risk assessment.

PROHIBITED JURISDICTIONS

The Company applies a risk-based approach to geographic exposure and may restrict or decline relationships involving jurisdictions subject to:

• Applicable sanctions regimes
• Significant AML/CFT deficiencies
• Elevated financial crime or sanctions evasion risk

Controls may include enhanced due diligence, limitations on services, or refusal to onboard or process transactions, depending on the level of risk identified.

PROHIBITED ACTIVITIES

The Company does not permit the use of its services for activities that involve or may facilitate sanctions breaches, including:

• Transactions involving sanctioned individuals or entities
• Activity intended to conceal or circumvent sanctions controls
• Use of third parties or structures to obscure the identity of relevant parties
• Transactions lacking a clear lawful or economic purpose

Additional scrutiny may be applied where higher-risk indicators are identified.

The Company remains alert to potential attempts to circumvent sanctions controls and may apply additional review where such risks are identified.

ACTIONS ON CONFIRMED MATCH

Where a sanctions match is confirmed:

• The Company will not establish or continue the business relationship
• Relevant transactions will not be processed
• Appropriate restrictions may be applied to accounts or funds, where required by law
• Reporting obligations to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and other competent authorities will be fulfilled, where applicable.

CONFIDENTIALITY AND NON-DISCLOSURE

The Company maintains confidentiality in relation to sanctions-related matters and complies with applicable legal restrictions on disclosure.

The Company does not inform customers or third parties of:

• The existence of a sanctions-related review
• Any reporting made to competent authorities

GOVERNANCE AND CONTROLS

The Company maintains internal controls designed to support the implementation of this Policy, including:

• Oversight by a designated Compliance function
• Risk-based monitoring and review processes
• Internal escalation procedures for higher-risk cases

Employees are expected to adhere to applicable compliance requirements and escalate concerns in accordance with internal procedures.

DATA HANDLING

The Company maintains records relevant to sanctions compliance in accordance with applicable legal requirements and ensures that such information is handled securely and accessed only by authorized personnel.

POLICY REVIEW

This Policy is reviewed periodically and updated as necessary to reflect changes in regulatory requirements and the Company's risk profile.

CONTACT INFORMATION

For questions related to this Policy or the Company's sanctions compliance practices, please contact:

• Email: [email protected]
• Address: 1 - 4903 54 STREET, LLOYDMINSTER, SASKATCHEWAN, CANADA, S9V 0N6
• FINTRAC MSB Registration No.: C100000462