Trade Compliance Policy

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DOC NO. 20031102/ OFFICIAL/ DATED:11 MARCH 2020

Trade Compliance Policy Statement

SinFooTech Pte Ltd is committed to being in compliance with all relevant trade laws that are applicable to its business and business operations. Through this policy, the company acknowledges that any failure to meet trade compliance requirements can have serious consequences for the company, such as reputational damages, monetary penalties, and suspension/revocation of the company’s export/import/manufacture privileges. The company is hence committed to the implementation, maintenance and continued review of its trade compliance policy in all of its business processes.

Trade-related activities carried out at SinFooTech Pte Ltd must adhere to the points stated below:

1. Export Compliance
• All exports are to be accurately declared as applicable under the Customs/trade laws of Singapore
• Shipping documentation shall accurately describe item(s) being shipped as well as the applicable export classification

2. Import Compliance
• All imports are to be accurately described as applicable under the Customs/trade laws of Singapore
• All Customs entries shall accurately state all required information, including the importer of record’s name and address, importer number, quantity, value, classification, duty preference eligibility, and country of origin for the imported items

3. Manufacture Compliance
• All dutiable products manufactured by the company shall be manufactured, packaged and distributed in strict compliance with all relevant applicable laws under the Customs/trade laws of Singapore

4. Sanctions Compliance
The company shall not participate in transactions in which the destination, end-use, or enduser is subject to a sanctions program, including, but not limited to, those programs maintained by United States’ Office of Foreign Assets Control

5. Anti-Boycott Compliance
• Any requests received by anyone to support a trade boycott of any country are to be reported to the Board of Directors of the company in accordance with the Reporting and Investigation policy; and
• The Board of Directors shall assess whether any such requests to participate in a boycott could violate applicable anti-boycott regulations or otherwise could negatively impact the company
• The company shall not participate in any trade boycott without the prior written approval of the Board of Directors

6. Compliance Responsibility
All employees are responsible for supporting the principles contained in this policy

The Trade Policy Statement has been reviewed and approved by SinFooTech Pte Ltd’s
Directors, and will be reviewed and revised where necessary, from time to time.

Version 2 (11 March 2020)

Endorsed by:



11 MARCH 2020