Version: 1.0
Revision: 10 March 2026
1.1. SatVu is committed to conducting its business responsibly and creating a culture in which diversity and inclusion are valued. However, in light of the sensitive market in which SatVu operates, SatVu does need to be mindful of the legal and contractual restrictions imposed on SatVu by law and by its investors and stakeholders.
2.1. This policy applies to all individuals, companies or partners (“You”) working for or on behalf of Global Satellite Vu Limited (or any group company) (“SatVu”) in any capacity, including employees, directors, other officers, contractors, consultants, advisers, agents and/or third-party representatives, wherever located.
3.1. When working with or on behalf of or in any way dealing with SatVu, You shall (and shall procure that any third party you work with including your customers, distributors, intermediaries, partners and end-users) at all times comply withall applicable sanctions and export control laws.
3.2. In addition, there are new mandatory investment obligations applicable to SatVu, which You are required to comply with (at all times), which means that You must not (whether directly or indirectly, (which may include through a group company or a third party)) in connection with Your dealings with SatVu:
3.2.1. engage in any conduct, licences, agreements, arrangements, operations, activities, transactions or dealings with, or for the benefit of, a Restricted Party. For the avoidance of doubt, this includes the sale of SatVu’s products or intellectual property in the Restricted Territory; or
3.2.2. engage in any conduct, arrangements, operations or activities in a Restricted Territory.
3.3. For the purpose of these restrictions, "Restricted Party" means a person that is resident or incorporated, or owned or controlled by (whether directly or indirectly) or acting on behalf of a person that is resident or incorporated, in a Restricted Territory; and "Restricted Territory" means the People’s Republic of China, Russia, Syria, Belarus, North Korea and Iran, each as identified in NATO’s Strategic Concept of 2022.
4.1. This requirement obviously impacts Your dealings with Your customers, distributors, intermediaries, partners and end-users, if, for example, they are receiving SatVu products or services or assisting with the provision of products or delivery of services. We therefore require you to:
4.1.1. forward this policy to all applicable third parties to ensure they understand these requirements; and
4.1.2. carry out sufficient Know Your Customer (KYC) checks at the commencement of the commercial relationship and monitor such checks on an ongoing basis, to ensure that You are compliant with this policy at all times.
5.1. You must comply with all instructions and directions issued to You in connection with this policy as well as provide copies of documentation and information as SatVu may require.
5.2. In the event of breach or suspected breach of this policy, this shall constitute a material breach of Your agreement(s) with SatVu and, without prejudice to SatVu’s additional rights and remedies under the applicable agreement(s), SatVu may terminate such agreement(s) immediately upon written notice.
5.3. Note that this policy may be amended at any time and in particular the definition of Restricted Party and/or Restricted Territory may be changed in SatVu’s absolute discretion.
5.4. SatVu does not accept any liability in respect of any losses incurred by You or any third party as a result of enforcement of and/or changes made to this policy (whether or not You have advised SatVu of the possibility of the same) and, notwithstanding any term of its agreement(s) with You or rights under applicable law, SatVu reserves its rights to recover all losses incurred by SatVu as a result of Your breach of this policy. By continuing to deal with SatVu, You agree to comply with the terms of this policy (as may be amended from time to time).
6.1. If you are unsure whether a proposed activity, relationship or interaction may fall within the scope of this policy, You must not proceed without prior approval from SatVu.
6.2. All questions, concerns, uncertainty or reports of actual or potential breaches must be reported immediately as follows:
Anthony Baker - CEO anthony@satellitevu.com
Melissa Mape - General Counsel melissa.mape@satellitevu.com
Proprietary to Global Satellite Vu Limited © 2026
