VPBank's Statement on Sanctions and Export Control Compliance Related to Russia

In recent years, due to the conflict between Russia and Ukraine, the United States (U.S.) and the European Union (EU) have continuously updated and adjusted their sanctions, embargoes, and export control policies (collectively referred to as "sanctions policies") imposed on Russia, making them increasingly stringent.

Specifically, the scope of U.S. sanctions policies against Russia has expanded to include non-U.S. individuals and entities. If non-U.S. individuals or entities conduct transactions or business activities that violate U.S. sanctions against Russia, they could face severe financial, legal, and reputational risks. These risks include:

• Financial Impact: Funds may be frozen, preventing the receipt or recovery of business payments, and significant fines may be imposed.

• Economic Penalties: Other economic sanctions may be applied, including being placed on sanctions lists, leading to exclusion from international business markets and loss of access to critical resources and technology.

• Reputational Damage: Damage to an individual's or entity's reputation in the market, resulting in lost business opportunities and profits.

Therefore, to minimize these risks for its customers, VPBank strongly recommends that customers proactively establish and maintain comprehensive and synchronized internal solutions, including but not limited to:

• Policy Establishment and Updates: Setting up sanctions compliance policies and risk appetites related to Russia and regularly updating them to reflect any changes in sanctions policies.

• Due Diligence and Screening: Developing mechanisms to screen relevant parties in transactions and business partners against sanctions lists. Conducting thorough risk assessments and due diligence on business partners and transactions before execution to ensure no business is conducted with sanctioned individuals/entities or in violation of sanctions policies against Russia.

• Resource Allocation and Training: Allocating appropriate compliance resources, and communicating, training, and raising employee awareness to ensure employees are fully aware of compliance requirements.

As a financial institution with extensive international business operations and partnerships, VPBank is committed to ensuring compliance with applicable sanctions regulations—including those against Russia—and guaranteeing that transactions conducted through VPBank are safe, efficient, and free from legal, financial, and reputational risks for its customers.

VPBank will NOT engage in any transactions/activities or provide any products/services to customers if VPBank has reason to suspect or determine that such transactions/activities/product/service provisions are:

• Directly or indirectly related to, or serving the interests of, individuals/entities on Russia-related sanctions lists, and/or individuals/entities directly or indirectly owned 50% or more by, or controlled by, individuals/entities on Russia-related sanctions lists, especially those operating or having operated in the technology, defense, construction, aerospace, or manufacturing sectors (collectively referred to as "the specific sectors").

• In violation of or supporting the violation of sanctions policies related to Russia applicable to the transaction (including but not limited to violations concerning end-users, transaction purposes, or goods transacted, especially transactions/services related to Russia's military-industrial complex, including the sale, supply, or transfer, directly or indirectly, to Russia of "specified items" goods).

• Supporting attempts to circumvent sanctions/export controls against Russia by concealing information about relevant parties in a transaction, disguising the true purpose of a transaction, etc.

• Potentially exposing VPBank to non-compliance risks with sanctions/export control policies imposed on Russia by nations/international organizations.

Furthermore, VPBank may implement measures including refusing to establish/terminate relationships, refusing to maintain accounts, or refusing to provide products/services to customers if VPBank determines that maintaining such relationships or providing such products/services could pose a sanctions compliance risk to VPBank.

These measures by VPBank may be adjusted periodically to ensure ongoing compliance with evolving sanctions and embargo policies imposed on Russia.

VPBank requests its customers' cooperation and commitment to:

• (i) Fulfill the commitments and obligations stated in the Terms and Conditions of Transactions that VPBank has communicated to customers.

• (ii) Cooperate by providing full and accurate information related to the customer/customer's business activities and/or transactions/products/services that the customer wishes to use, as requested by VPBank, for the purpose of complying with the aforementioned sanctions policy imposed on Russia.

Please refer to the "Specified Items" list HERE.

VPBank sincerely appreciates your cooperation.