Sanctions Compliance Policy
MİKROTEKNİK KİMYEVİ MADDELER LABORATUVAR MALZEMELERİ VE CİHAZLARI SANAYİ TİCARET VE LİMİTED
ŞİRKETİ
Sanctions Compliance Policy
Website-Publication Version (Certified English Translation)
Approved by:
The Board of Managers of the Company
Effective date:
18.02.2026
Review:
This Policy is reviewed and updated at regular intervals.
Mikroteknik Kimyevi Maddeler Laboratuvar Malzemeleri ve Cihazları Sanayi Ticaret ve Limited
Şirketi (“Mikroteknik” or the “Company”) adopts, as a fundamental principle, the conduct of its
operations in full compliance with national and international sanctions law. This Policy is published
in order to share the Company’s commitment in this respect, and the principles by which it is
applied, with the public, its customers, suppliers, and business partners.
1 Our Commitment
Mikroteknik undertakes to comply fully with the economic sanctions and export-control regulations
of the competent authorities, including in particular the Republic of Türkiye, the United Nations
(UN), the European Union (EU), the Office of Foreign Assets Control of the U.S. Department of the
Treasury (“OFAC”), and the United Kingdom (OFSI). The Company does not knowingly become
party to any transaction that breaches sanctions.
2 Scope
This Policy covers all areas in which Mikroteknik operates, all of its employees and managers, and
all third parties acting on behalf of the Company. Procurement and purchasing, sales and customer
management, financial transactions, and training and awareness activities all fall within the scope
of this Policy.
3 Our Core Principles
•
Knowing our counterparties. We know our customers, suppliers, intermediaries, and
business partners, and we apply due-diligence processes that take account of ownership and
control structures.
•
Sanctions list screening. All counterparties are screened against the OFAC SDN List and
other national and international sanctions lists, both before and throughout any commercial
relationship.
•
Compliance with the law. We act in accordance with the national and international sanctions
legislation in force in every region in which we operate.
•
Records and transparency. We keep our commercial and financial records accurate and
complete, and ensure they can be made available to the relevant authorities where required.
•
A preventive approach. Our Policy is preventive in nature; it is designed to identify risks at an
early stage and to respond to them appropriately.
4 Prohibited Dealings
The following dealings are not permitted at our Company under any circumstances:
•
Doing business, directly or indirectly, with persons, companies, or entities on the OFAC SDN
List or on the sanctions lists of the UN, the EU, or the Republic of Türkiye.
•
Doing business with entities owned 50 percent or more by one or more sanctioned parties.
•
Establishing direct or indirect commercial relationships with comprehensively sanctioned
countries or regions.
•
Participating in any transaction or structure intended to circumvent sanctions or to obscure the
origin of goods or the identity of the parties.
5 Our Expectations of Counterparties
We expect our customers, suppliers, intermediaries, and business partners also to act in
compliance with applicable sanctions law. Mikroteknik reserves the right to screen its
counterparties, to request identity, ownership, and end-use information, and, where necessary, to
decline or terminate a commercial relationship. Sanctions-compliance provisions are included in
new contracts.
6 Compliance Governance
Our Company’s Sanctions Compliance Program has been approved by the Board of Managers. A
Compliance Officer has been appointed to oversee the Program. Our employees receive regular
sanctions-compliance training; processes are monitored and audited, and changes in legislation
are reflected in our practices. The Program is reviewed periodically, consistent with the principle of
compliance with national and international law.
7 Reporting and Contact
Questions regarding this Policy, and concerns about a possible sanctions non-compliance, may be
raised with the Company through the compliance contact address below. No person will be
subjected to adverse treatment for a report made in good faith.
Compliance contact:
compliance@mikroteknik.com.tr
This Policy forms part of Mikroteknik’s Sanctions Compliance Framework and has taken effect
upon approval by the Company’s Board of Managers. It is published in Turkish and English; in the
event of any discrepancy between the texts, the Turkish text shall prevail.