Policies & Compliance

Sanctions and Trade Compliance Policy

Apex Grove Distribution Ltd ("Apex Grove") trades internationally in bulk commodities such as sugar, fuels such as LPG and gasoil, and bitumen. We are committed to complying with all applicable sanctions, export control and customs laws. Apex Grove is part of the Earthe group, and we apply United Nations, United Kingdom, European Union and United States sanctions regimes as a matter of policy, in addition to Kenyan law, including the Proceeds of Crime and Anti-Money Laundering Act 2009.

Scope

This policy applies to all staff, agents and intermediaries, and to every transaction, including purchases, sales, shipping, storage, financing and payments.

Prohibited Dealings

  • Dealing directly or indirectly with persons or entities designated on UN, UK (OFSI), EU or US (OFAC) sanctions lists, or entities owned or controlled by them.
  • Buying, selling, transporting or financing product of sanctioned origin. We do not deal in Iranian-origin product, or product originating from any other country or region subject to comprehensive or sectoral sanctions affecting the goods concerned.
  • Trading Russian-origin oil products other than in full compliance with applicable price caps and restrictions; in practice, Apex Grove does not accept such product.
  • Using sanctioned vessels, or vessels engaged in deceptive shipping practices such as AIS switch-off or unexplained ship-to-ship transfers.
  • Any attempt to disguise origin, ownership or destination, or to evade sanctions.

Know Your Counterparty

Before entering into any transaction we:

  • verify the counterparty's identity, registration and beneficial ownership;
  • screen the counterparty, beneficial owners, banks, vessels and other parties against UN, UK, EU and US lists;
  • obtain and review documentation on origin, such as certificates of origin, bills of lading and loading port records;
  • assess red flags, including unusual routing, pricing far from market, reluctance to provide information, or payments through unrelated third parties.

Screening is repeated before each shipment and when lists change.

Contracts

Our contracts include sanctions warranties, origin representations and termination rights for breach.

Escalation and Records

Any potential match or red flag must be escalated to senior leadership and the transaction suspended until resolved. We keep due diligence and screening records for at least seven years.

Training and Reporting

Staff involved in trading receive sanctions guidance. Concerns must be reported to connect@apexgrove.ke. Breaches may result in disciplinary action, termination of relationships and reporting to authorities.

Review

This policy is reviewed at least annually and whenever significant sanctions changes occur.

Last reviewed: November 2026

Signed:
Gruffald Salter, CEO
Apex Grove Distribution Ltd

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