Sanctions Compliance Policy

Scope

The policy applies to all business relationships, customers, suppliers, and partners. NorseStorm
ApS does not engage in business with any party listed on an applicable sanctions list.

Screening Procedure

Before entering into any new business relationship, we screen names of individuals and entities
using:

• The EU Sanctions Map: www.sanctionsmap.eu

• Guidance from the Danish Ministry of Foreign Affairs.

• Screening is conducted by management as part of our onboarding checklist.

• Any red flags are reviewed, and partnerships are rejected if a match is found.

Responsibility

The Head of Sales is responsible for overseeing sanctions compliance and keeping up to date
with regulatory changes.

Records

A log of screenings will be maintained with date, entity name, result, and follow-up action (if any).

Compliance and Review

This policy is reviewed annually or upon updates to applicable sanction regimes.

Status

To date, NorseStorm ApS has not been in contact with or conducted business with any
sanctioned entities.