Akzo Nobel N.V.

Executive Committee

Guidelines

Sensitive Country

Source document Directive 7.10 Export Control

Content Owner AkzoNobel Legal Group – Compliance

Signed off by Date General Counsel July 3, 2017

Effective Date February 5, 2020

Purpose

The purpose of these guidelines is to regulate trade and travel with certain Sensitive Countries

Scope and definitions

These Guidelines apply to all employees and controlled affiliates of AkzoNobel. Those engaging
business partners such as distributors, agents, vendors are expected to ensure that these business
partners also comply with these guidelines in the business they do for AkzoNobel.

Table of contents

Left blank on purpose.

Guidelines

AkzoNobel is committed to doing business in a safe and sustainable way and in accordance with
export control and sanction regulations. Doing business in certain countries exposes the company to
safety risks, regulatory non-compliance and reputational harm. The Executive Committee (ExCo) has
appointed a Sensitive Country Committee (SCET) to assess countries against certain risk criteria and
take additional safeguards where required. These criteria include applicable sanctions, level of
corruption, respect for human rights, political and security risks and travel safety. The SCET consists
of the General Counsel, Director Compliance and ExCo-member responsible for one of the Business
Areas.

The SCET maintains a Sensitive Country List providing an overview of countries in relation to which
AkzoNobel has banned trade and travel or requires an internal approval. If you are involved in the
export or import of products or technology, sale of controlled products or technology, international
payments or international travel you should check this list regularly and be alert to updates from the
SCET.

No transactions, respectively travels, are permitted with countries in the “Transactions banned” or
“Travel banned” categories. For countries listed in the other categories approval must be obtained
from the relevant BA Manager Export Control, the BU/Functional Director or the SCET. In addition to
following these rules, prior to engaging in an international transaction, you must always consult and
comply with the OFAC, EU and UN sanctions lists and any other sanctions that may apply to your
transaction.

If you have questions, please contact the Compliance function: compliance@akzonobel.com

 02

Sensitive Country List

Trade Restrictions Countries

Transactions banned Syria and North Korea

Approval required from relevant BA Afghanistan, Belarus, Burundi, Central African

Manager Export Control Republic, Crimea, Congo (Democratic Republic),
Cuba, Eritrea, Iran, Iraq, Lebanon, Libya,
Myanmar/Burma, Republic of Guinea (Conakry),
Russia, Somalia, South Sudan, Sudan, Sevastopol,
Venezuela, Yemen and Zimbabwe

Approval required from SCET for
permanent establishment or residence
Afghanistan, Belarus, Burundi, Central African
Republic, Crimea, Congo (Democratic Republic),
Cuba, Eritrea, Iran, Iraq, Lebanon, Libya,
Myanmar/Burma, Republic of Guinea (Conakry),
Russia, Somalia, South Sudan, Sudan, Sevastopol,
Venezuela, Yemen and Zimbabwe

Travelers are expected to consult the International SOS website (AkzoNobel member login:
30BCPA000011) before travelling. Travel to an area that is indicated as extreme risk is banned.
Travel to an area that is indicated as “high risk” should be avoided, if possible. In any event, approval
from the relevant BU/Functional Director is required for travel to high risk areas and all necessary
precautions must be taken. Exceptions to the travel rules must be approved by the ExCo member
responsible for the relevant territory.

Travel Restrictions Countries

Travel banned (extreme risk) Afghanistan, Burkina Faso (Provinces of Oudalan,

Soum (both Sahel region) and Loroum (Nord region)),
Cameroon (areas of extreme North region bordering
Nigeria), Central African Republic, Congo (DRC)
(North Kivu province (except Goma and Beni), South
Kivu province (except Bukavu), Ituri province
(Orientale province) (except Bunia), Tanganyika
province), Egypt (North Sinai), Iran, Iraq, Libya, Mali
(Gao, Kidal, Menaka, Mopti, Taoudeni and Timbuktu
regions), Nigeria (Borno state), North Korea, Pakistan
(Districts in Khyber Pakhtunkhwa bordering the
former Federally Administered Tribal Areas (FATA),
Balochistan (except for Gwadar and central districts),
The former Federally Administered Tribal Areas
(Khyber Pakhtunkhwa province)), Palestinian
Territories (Gaza), Somalia, South Sudan, Syria,
Ukraine (Eastern border regions Donetsk and
Luhansk), Venezuela, Yemen

Approval required from relevant Areas indictated as “high risk”

BU/Functional Director
 03

Related documents
Directive 7.10 Export Control
Export Control Manual