Sanctions Compliance Policy

This Sanctions Compliance Policy (the "Policy") explains how the Premium Auto Bid platform identifies, assesses and manages the risk that its services could be used by, or for the benefit of, persons, entities, vessels, aircraft, organisations, governments or jurisdictions that are the target of economic or trade sanctions. It sets out our screening practices, the restrictions that may apply to you, and the steps we take when a sanctions concern arises.

Premium Auto Bid is the trading brand of Premium Logistics SHPK, a limited liability company (shoqëri me përgjegjësi të kufizuar) registered in the Republic of Albania, NUIS/NIPT M53004202C, recorded with the National Business Center (Qendra Kombëtare e Biznesit, QKB). Our registered office is at Rruga "Dubai", Lagjia nr. 2, cadastral zone 2066, property no. 89/38, 4-storey building, 2nd floor, Entrance 1, Kamëz, Tirana, Albania. In this Policy, "Premium Auto Bid", "we", "us" and "our" mean Premium Logistics SHPK.

This Policy is effective from 4 June 2026 and was last updated on 4 June 2026. It applies to all visitors, registered users, customers, applicants, suppliers, agents, intermediaries and other counterparties (each a "you" or a "counterparty") who use, or seek to use, the platform or who transact with us in connection with vehicle sourcing, bidding, payment handling, transport, customs or import support.

Premium Auto Bid is an independent vehicle sourcing, bidding and import-support platform serving customers in Albania, Kosovo, North Macedonia and Montenegro. We help customers discover Copart auction vehicles and, after identity verification and deposit approval, place their bids on Copart in real time through the Copart API, and we coordinate purchase, transport, customs and import support. This Policy must be read together with our Member Terms, our Anti-Money Laundering Policy, our Know-Your-Customer (KYC) Policy, our Anti-Corruption Policy and our Privacy Policy.

Premium Auto Bid places customer bids on Copart in real time through the Copart API once a customer has completed identity verification, accepted the Member Terms and has an approved deposit. Premium Auto Bid is independent and is not owned by, operated by, endorsed by, or officially affiliated with Copart, Inc. Copart and the Copart logo are trademarks of Copart, Inc. The specific sample vehicles shown on the platform are clearly-labelled demonstration samples only; they do not represent real Copart lots and are not biddable.

Premium Auto Bid is committed to conducting its business lawfully and to not knowingly providing services, funds, goods, technology or economic resources to, for, or on behalf of any individual, entity or country that is the target of applicable sanctions. We will not facilitate any transaction that we know, or have reasonable grounds to suspect, would breach sanctions laws binding on us or that would expose us, our banking partners, our prospective auction-source relationships or our customers to sanctions exposure.

We maintain this commitment because we operate in an international supply chain that connects an Albanian operating entity, customers across the Western Balkans, United States vehicle auctions, cross-border payment channels and international transport and customs providers. A single non-compliant transaction in such a chain can carry serious legal, financial and reputational consequences. Accordingly, our default posture is conservative: where a sanctions concern cannot be resolved with confidence, we will not proceed.

• We do not knowingly accept as a customer, supplier, agent or counterparty any person or entity that is sanctioned.
• We do not knowingly source, bid on, purchase, pay for, transport, import or release any vehicle where doing so would breach sanctions.
• We do not knowingly process, receive or send funds to or from a sanctioned person, entity, bank or jurisdiction.
• We screen, escalate, document and, where appropriate, report sanctions concerns rather than ignore them.
• We cooperate with competent authorities and with our banking and prospective auction-source partners on sanctions matters.

Because of where we are established and the markets and supply chain in which we operate, we take account of several overlapping sanctions frameworks. Where these frameworks differ, we apply the most restrictive applicable requirement that is relevant to a given customer, counterparty, vehicle, payment or transport route.

United Nations (UN)

Sanctions adopted by the United Nations Security Council under Chapter VII of the UN Charter, including asset freezes, arms embargoes and targeted measures against listed individuals, entities and jurisdictions, as implemented through binding resolutions.

European Union (EU)

Restrictive measures adopted by the European Union, including EU consolidated listings, sectoral measures and country-specific regimes. As an Albanian undertaking operating in a region closely aligned with the EU and frequently transacting in EUR and through EU-linked banking and logistics channels, we treat EU restrictive measures as directly relevant to our risk assessment.

United States (US / OFAC)

Sanctions administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons List (the "SDN List"), sectoral and program-based sanctions, and secondary-sanctions risk. Because our supply chain involves United States vehicle auctions and may involve US-dollar payment flows, US sanctions are of particular significance to our operations.

Albanian and other applicable measures

Sanctions and restrictive measures given effect under the law of the Republic of Albania, and any other sanctions regimes that are relevant to a specific transaction, counterparty, vehicle, financial institution or transport route involved in our services.

Sanctions lists and programs change frequently and without notice. A person, entity, country or activity that is permitted today may become restricted tomorrow. This Policy describes the categories of measures we take into account; it is not, and cannot be, a complete or current list of every sanctions designation. Nothing in this Policy is legal advice to you about your own sanctions obligations.

Sanctions screening is embedded in our customer lifecycle and works alongside our KYC and AML controls. Identity verification (KYC) and acceptance of the Member Terms are required before any bidding, and screening forms part of that gateway. We screen at onboarding and again at key decision points, and we re-screen on an ongoing basis because designations change over time.

Who we screen

• Customers and applicants, including the named individual and, where the customer is a company, its directors, authorised representatives and beneficial owners.
• Persons connected to a transaction, such as anyone funding a deposit or balance, anyone nominated to receive a vehicle, and any agent or intermediary acting for a customer.
• Suppliers, transport providers, customs agents, payment counterparties and other business partners, to the extent relevant to a transaction.
• Banks and other financial institutions involved in inbound or outbound payments connected to our services.

What we screen against

• Applicable UN, EU, US/OFAC and other relevant consolidated sanctions and designation lists.
• Jurisdiction-level restrictions, including comprehensively sanctioned or embargoed countries and territories.
• Indicators that a counterparty may be owned or controlled by, or acting on behalf of, a sanctioned person or entity.

When we screen

1. At registration and during identity verification (KYC), before any bid is placed.
2. Before a deposit is approved and before any bid is submitted to Copart on the customer's behalf.
3. Before funds are confirmed, before a purchase is completed, and before transport, customs or import support is arranged.
4. On an ongoing basis for active customers and open transactions, including re-screening following changes to sanctions lists or to the information we hold.

Where screening produces a potential match or another sanctions concern, the matter is escalated for review before the relevant step proceeds. We may pause activity on an account or transaction while a concern is being assessed. Screening supports, but does not replace, our overall verification of KYC, deposit status and Member Terms before any bid is placed on Copart.

Sanctions compliance can require us to interrupt or stop activity at short notice. Where we identify, or reasonably suspect, a sanctions concern, or where we are required to do so by applicable law, by a competent authority, or by a banking or prospective auction-source partner, we may take any of the following actions without prior notice and without liability to you, to the maximum extent permitted by applicable law.

• Delay or suspend onboarding, identity verification, deposit approval, bid requests, purchases, payments, transport, customs or import support while we assess the concern.
• Refuse to enter into, continue or complete a transaction or relationship.
• Decline to accept, hold, or return funds, or freeze, block or refrain from moving funds, where required or appropriate.
• Restrict, suspend or close an account and decline to provide further services.
• Withhold a vehicle, document or release pending resolution of a sanctions concern.
• Request additional information or documentation as a condition of proceeding.

Where applicable sanctions law requires funds or property to be frozen or blocked, we will comply with that requirement. In such cases we may be legally prohibited from returning funds, completing a transaction, or even explaining the specific reason for an action. Any handling, holding or return of funds is always subject to our independent operator verification of inbound payments and to applicable law.

All deposits and balances are denominated in USD ($750 standard, or 10% of value for vehicles over $7,500) and are separate from the final purchase payment. Inbound payments are operator-confirmed (bank transfer in USD or EUR, or cash in ALL at the Tirana office); customers upload proof and the operator verifies it independently. We do not use third-party card processors for this flow. Sanctions screening of payers, beneficiaries and the financial institutions involved forms part of that verification, and a payment may be delayed or rejected on sanctions grounds.

Our sanctions controls depend on knowing who we are dealing with and who ultimately benefits from a transaction. Providing false, misleading or incomplete identity information, using another person's identity, acting as an undisclosed front for someone else, or concealing the true beneficial owner or controller of an account or transaction undermines those controls and is strictly prohibited.

If we determine, or reasonably suspect, that a customer or counterparty has provided false identity information or has concealed beneficial ownership or control, we may take action that includes, without limitation, the following.

• Immediate suspension or closure of the account and termination of services.
• Cancellation or reversal of pending bid requests, purchases or arrangements.
• Refusal to release a vehicle or to process related funds, subject to applicable law.
• Retention of relevant records as required by law.
• Internal escalation and, where required or appropriate, reporting to competent authorities.

Where our suspicions concern money laundering or terrorist financing, we may be legally required to make a report to the General Directorate for the Prevention of Money Laundering (the Albanian Financial Intelligence Unit) under Albanian Law no. 9917 dated 19.05.2008 "On the Prevention of Money Laundering and Financing of Terrorism" (as amended), having regard to FATF recommendations. In the circumstances set out in that law, we may be prohibited from notifying you that such a report has been or may be made.

Our services are intended for customers located in our served markets: Albania, Kosovo, North Macedonia and Montenegro. We do not market our services to, and we do not knowingly provide services to customers ordinarily resident or located in, comprehensively sanctioned or embargoed countries or territories, or to persons acting for the benefit of such jurisdictions.

• We may decline to onboard, or may restrict or terminate, any customer connected to a jurisdiction subject to comprehensive sanctions or embargo.
• We may refuse any transaction, payment, transport or import arrangement that would route value to, through, or for the benefit of a restricted jurisdiction.
• We may require evidence of a customer's location, residence or place of establishment, and of the origin and destination of funds and vehicles.
• We may apply additional checks where a transaction has connections to a higher-risk jurisdiction, even if that jurisdiction is not comprehensively sanctioned.

Operating within a served market does not by itself entitle any person to services. Eligibility always remains subject to identity verification, deposit approval, acceptance of the Member Terms, and the screening and risk controls described in this Policy. We may update the list of served markets and the geographic restrictions we apply at any time.

We maintain internal procedures so that sanctions concerns are identified, escalated and dealt with consistently. Personnel who become aware of a possible sanctions issue, including a possible list match, an attempt to disguise identity or ownership, or a transaction with a restricted-jurisdiction nexus, are required to escalate it promptly and not to take steps that could prejudice a lawful response.

1. Identify the concern through screening, operator review, partner notification or other information.
2. Pause the relevant step where appropriate, so that no action is taken that could breach sanctions.
3. Escalate to the person responsible for compliance for assessment and a decision on whether to proceed, refuse, freeze, report or seek further information.
4. Document the concern, the assessment and the decision, and retain the relevant records.
5. Where required, freeze or block funds or property and make any report required by applicable law to the competent authority.
6. Cooperate with competent authorities and, as appropriate, with banking and prospective auction-source partners.

Our sanctions controls form part of a broader compliance framework that includes anti-money-laundering and counter-terrorist-financing measures, KYC, and anti-corruption controls informed by the Albanian Criminal Code provisions on corruption and, for international dealings, by principles drawn from the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. We review this Policy periodically and adjust our controls as our business, our supply chain and the applicable regimes evolve.

Suspected breaches of this Policy, including by personnel or partners, can be raised with us using the contact details below. We do not tolerate retaliation against a person who raises a genuine concern in good faith.

By using the platform and by transacting with us, you make the following representations and undertakings, on a continuing basis, in addition to any obligations in our Member Terms.

• You are not a person targeted by applicable sanctions, and you are not owned or controlled by, or acting on behalf of, any such person.
• You are not ordinarily resident or located in, and you are not acting for the benefit of, a comprehensively sanctioned or embargoed jurisdiction.
• The information you provide about your identity, residence, beneficial ownership and the source and destination of funds and vehicles is true, accurate and complete, and you will keep it up to date.
• You will not use our services to evade, or to attempt to evade, any sanctions or other applicable legal restriction.
• You will provide additional information or documentation we reasonably request to meet our sanctions, KYC or AML obligations.

If any of these representations becomes untrue, or if your circumstances change in a way relevant to sanctions, you must tell us promptly. We rely on these representations, and a breach of them may result in delay, refusal, freezing, account closure and reporting as described in this Policy.

We apply reasonable, risk-based measures to avoid knowingly dealing with sanctioned persons, entities or jurisdictions. We do not, however, guarantee that our screening will detect every sanctions concern, that sanctions lists and tools are complete or error-free, or that any particular transaction will proceed, complete or be permitted. Sanctions compliance is an ongoing, judgement-based process, and our decisions are necessarily conservative.

Vehicles are sold as-is by third-party auction sources. Premium Auto Bid does not guarantee condition, title, mileage, damage, history, availability, auction outcome, or shipping or customs timelines. Sanctions controls may independently delay, refuse or stop a transaction, and the application of those controls is never a guarantee that an unrelated outcome (such as a successful purchase, a particular price, or a delivery date) will be achieved.

Nothing in this Policy creates rights for you beyond those in our Member Terms and applicable law, and nothing in it requires us to act in a way that would itself breach sanctions. To the maximum extent permitted by applicable law, we are not liable for losses arising from action taken in good faith to comply with sanctions, including delay, refusal, freezing, blocking or account closure.

This Policy and any non-contractual obligations arising out of or in connection with it are governed by the law of the Republic of Albania. The competent courts of Tirana have jurisdiction over any dispute arising out of or in connection with this Policy, without prejudice to any mandatory rules of applicable law and to our obligations under applicable sanctions regimes.

We may update this Policy from time to time to reflect changes in applicable law, sanctions regimes, our services, our supply chain or our internal controls. When we make changes, we will update the "last updated" date above and publish the revised Policy on premlogistics.com. Where a change is significant, we will take reasonable steps to bring it to the attention of affected customers.

Your continued use of the platform or continued dealings with us after a revised Policy takes effect constitute acceptance of the updated Policy. If you do not agree with a change, you should stop using the platform and contact us. We recommend that you review this Policy periodically.

Questions, disclosures or requests relating to this Sanctions Compliance Policy should be directed to our compliance function, which is responsible for sanctions matters.

• Compliance (sanctions, AML and reporting): compliance@premlogistics.com
• Legal: legal@premlogistics.com
• Data protection / DPO: privacy@premlogistics.com
• General and customer support: info@premlogistics.com and support@premlogistics.com
• Operating entity: Premium Logistics SHPK (trading as Premium Auto Bid), NUIS/NIPT M53004202C
• Registered office: Rruga "Dubai", Lagjia nr. 2, cadastral zone 2066, property no. 89/38, 4-storey building, 2nd floor, Entrance 1, Kamëz, Tirana, Albania
• Website: premlogistics.com