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Sanction Policy

SANCTIONS POLICY

Last updated: April 18, 2023

Contents

1 Introduction

2 Policy Scope and Applicability

3 Compliance with Sanction Laws and Regulations

4 Vendor Responsibilities

5 Enforcement and Remedial Actions

6 Policy Updates

 

1           Introduction

KulturCart is committed to upholding the highest standards of ethical conduct, ensuring the integrity of our platform, and promoting a safe and secure environment for our users. As a leading multicultural e-commerce platform, we recognize our responsibility to adhere to national and international trade regulations, including the implementation and enforcement of sanctions imposed by relevant authorities.

This Sanctions Policy outlines KulturCart’s commitment to complying with applicable sanction laws, regulations, and guidelines. It also provides information on our internal processes and the responsibilities of our vendors to prevent and address potential sanction violations.

2           Policy Scope and Applicability

This Sanctions Policy applies to all vendors, partners, employees, and contractors affiliated with KulturCart. All parties are expected to comply with the policy and any related procedures and guidelines established by KulturCart.

3           Compliance with Sanction Laws and Regulations

KulturCart Marketplace is committed to fully complying with all applicable sanction laws, regulations, and guidelines imposed by governments, international organizations, or regulatory bodies. This includes but is not limited to, sanctions imposed by the European Union and the United Nations.

Our compliance efforts encompass the following key areas:

  1. Restricted Parties: KulturCart Marketplace diligently screens all vendors, partners, employees, and contractors against applicable sanctions lists to ensure that we do not engage in business with sanctioned individuals or entities.
  2. Restricted Products and Services: We prohibit the sale or provision of any products or services that are subject to trade controls or sanctions, including, but not limited to, items of military or dual-use nature, and products originating from or destined for sanctioned countries.
  3. Restricted Transactions: KulturCart Marketplace prohibits transactions with individuals, entities, or countries subject to sanctions, as well as any transactions that may involve the evasion or circumvention of sanctions.

4           Vendor Responsibilities

Vendors on KulturCart Marketplace are responsible for ensuring that their business activities align with our Sanctions Policy and all applicable sanctions laws, regulations, and guidelines. This includes: 

  1. Conducting due diligence to ensure that their products and services do not violate any sanction laws or regulations.
  2. Verifying the origin and destination of their products to ensure compliance with trade controls and sanctions.
  3. Reporting any suspicious activities, potential sanction violations, or concerns about their own or other vendors' compliance with this policy to the KulturCart platform.

5           Enforcement and Remedial Actions

KulturCart is committed to taking prompt and appropriate action in response to any potential or actual violation of our Sanctions Policy or applicable sanctions laws, regulations, and guidelines. Such actions may include, but are not limited to:

  1. Investigating any reported or suspected violations and cooperating with relevant authorities, as necessary. 
  2. Suspending or terminating a vendor's account or access to KulturCart services if we determine that they have violated our Sanctions Policy or applicable sanctions laws, regulations, or guidelines.
  3. Implementing additional controls or measures to prevent future violations and ensure continued compliance with applicable sanctions laws, regulations, and guidelines.

6           Policy Updates

KulturCart reserves the right to update or modify this Sanctions Policy at any time to reflect changes in applicable sanctions laws, regulations, or guidelines, or to enhance our internal processes and controls. We will notify vendors of significant changes to our Sanctions Policy by posting an updated version on our platform or via email communication. Vendors are responsible for regularly reviewing our Sanctions Policy to stay informed about their obligations and any changes that may affect their compliance.

By partnering with KulturCart, vendors acknowledge their understanding of and commitment to complying with our Sanctions Policy and all applicable sanctions laws, regulations, and guidelines. Together, we can ensure the continued integrity, safety, and success of our marketplace.