GLOBAL MOUNTAIN GROUP LLC

Last Updated: April 2026

Global Mountain Group LLC (“Company”, “GMG”, “we”, “us”, or “our”) operates under a compliance-first, eligibility-based, and risk-aware framework.

This Policy explains the principles governing screening, acceptance, continuation, limitation, suspension, and termination of engagements, business relationships, and service requests involving the Company.

1. Compliance-First Principle

All Company activities are subject to applicable laws, regulations, and internal compliance standards, including where relevant:

• United States federal and state law
• international sanctions and export control requirements
• trade, logistics, technology, and cross-border restrictions
• data protection, privacy, and record-handling requirements
• licensing, authorization, and professional obligations

No commercial opportunity or operational objective overrides compliance, legality, or risk acceptability.

2. Eligibility Is Conditional

Eligibility to engage with the Company is not automatic, permanent, or unconditional.

Eligibility may be assessed:

• before an engagement begins
• during an ongoing engagement
• whenever material circumstances change

A prior acceptance, payment, or signed agreement does not remove the Company’s right to reassess eligibility.

3. Screening and Due Diligence

Before and during an engagement, the Company may conduct screening and due diligence, including where relevant:

• identity and authority verification
• counterparty legitimacy review
• end-user and end-use review
• jurisdictional assessment
• sanctions and regulatory screening
• reputational, legal, compliance, and operational risk review

The Company may request additional information, documents, or clarifications at any time.

4. Accuracy of Information

Any person or entity dealing with the Company is responsible for ensuring that information provided is:

• accurate
• complete
• current where relevant
• not misleading by action or omission

False statements, concealed facts, or material omissions may be treated as a compliance breach.

5. Reassessment During Engagement

The Company may reassess an engagement if it discovers or reasonably believes that:

• previously supplied information was inaccurate or incomplete
• material facts were withheld
• circumstances have changed significantly
• new compliance, legal, or reputational concerns have emerged
• continuing the relationship may create unacceptable risk

6. Right to Limit, Suspend, or Terminate

Where appropriate, the Company may, at its sole discretion:

• decline a new request
• pause or suspend an engagement
• limit scope, access, or deliverables
• require additional checks or conditions
• terminate an engagement

Such actions may be taken where legally permitted without advance notice and without detailed disclosure of internal findings.

7. Reputational and Strategic Risk

The Company may refuse, suspend, or terminate an engagement if continued association may:

• harm the Company’s reputation
• damage trust with partners, providers, banks, or regulators
• create disproportionate legal, regulatory, or public risk
• conflict with internal standards or risk tolerance

Reputational risk may be a sufficient standalone basis for disengagement.

8. Authorized Delivery and External Constraints

Some services, activities, or supply matters may only be possible through qualified partners, external providers, or legally authorized channels.

If lawful, compliant, or practical delivery becomes impossible, restricted, or excessively risky, the Company may decline or discontinue the matter.

9. No Obligation to Disclose Internal Assessments

The Company is not required to disclose:

• internal risk evaluations
• screening logic or criteria
• sources or methods
• internal compliance reasoning
• detailed grounds for refusal or termination beyond what is legally required

10. No Waiver

Failure to enforce any provision of this Policy on one occasion does not constitute a waiver of any right or future enforcement.

11. Policy Updates

This Policy may be updated from time to time. The “Last Updated” date reflects the current version.

12. Governing Law

Unless mandatory law requires otherwise, this Policy is governed by the laws of the State of Wyoming, United States of America.

13. Contact

For compliance-related inquiries, where appropriate, please contact: