Muculo Retail
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Sanctions and Trade Controls Policy

Version 1.0 · November 2026

Statement

Muculo Retail buys, sells and moves goods across many markets. It therefore does not carry out operations that breach applicable sanctions or export controls, or that aim to circumvent them, directly or through third parties.

Regimes we respect

We comply with the sanctions of the United Nations Security Council, the European Union, Angola (Law No. 1/12 of 12 January, as amended by Law No. 4/25 of 24 April) and Portugal. We also take into account those of the United Kingdom and the United States (OFAC), even where they do not bind us directly, because banks, insurers, shipowners and carriers apply them and may refuse the operation. We also apply export controls on dual-use items, such as Regulation (EU) 2021/821, and restrictions on arms and military equipment.

What we check before accepting an operation

  • Persons and entities: client, supplier, beneficial owner, intermediaries, bank and final consignee, screened against sanctions lists.
  • Countries and routes: origin, destination, transit, ports and transhipments, including territories under embargo or sectoral restrictions.
  • Transport: carrier, shipowner and vessel (IMO number), where applicable, and consistency of transport documents with the route.
  • Goods: tariff classification, end use and end user, and whether an export or import licence or authorisation is required.
  • Payment: source and destination of funds, bank and currency, in line with our Anti-Money Laundering Policy.

Know your client and your supplier

Before the first operation we identify and verify the counterparty and its beneficial owners, its activity and the source of funds. The depth of the checks depends on risk: country, sector, type of goods, corporate structure and value. High-risk counterparties require approval from the compliance officer and enhanced monitoring. Checks are repeated periodically and whenever sanctions lists or circumstances change.

Red flags

We suspend the operation and escalate when we find, for example:

  • payment by a third party unrelated to the operation, or to an account in a country different from the counterparty's;
  • a vague or inconsistent description of the goods, or altered or inconsistent documents;
  • a route or transhipment with no commercial justification, or a request to change the destination after shipment;
  • a vessel with a history of switching off its AIS signal, or frequent changes of flag or owner;
  • a company with no real presence, newly formed or with an opaque structure;
  • a price far above or below the market, or reluctance to provide information.

Decision, refusal and escalation

Whoever identifies a red flag suspends the operation and informs the compliance officer. Only the compliance officer may authorise it to continue, in writing and with reasons. We refuse or cancel any operation that cannot be completed with legal certainty, and we record the decision. We do not tell a counterparty that it is under review on suspicion, where the law forbids it. Where the law requires, we report to the competent authorities.

Contracts

Our contracts include clauses on compliance with sanctions and export controls, the right to suspend or cancel the operation, without penalty to us, where there is a risk of breach, and the counterparty's duty to inform us of relevant changes.

Records, training and review

We keep the checks, decisions and supporting documents for the applicable legal periods. People working in purchasing, sales, operations and payments receive training on this policy. The policy is reviewed at least once a year and whenever relevant new sanctions arise.

Questions and reports

Anyone with doubts must consult the compliance officer before proceeding. Suspected breaches can be reported confidentially through the Whistleblowing Channel. This policy complements the Code of Ethics and Conduct and the Anti-Corruption Policy.