This Schedule forms part of the Master Service Agreement between AR HANG SERVICE (HK) LIMITED and [CLIENT FULL LEGAL NAME].

1. Definitions

1.1 "Sanctioned Person" means any person or entity:

• designated on any applicable sanctions list;
• located, organised or resident in a comprehensively sanctioned jurisdiction;
• owned 50% or more, directly or indirectly, by any of the above;
• otherwise subject to sanctions that restrict the relevant transaction.

1.2 "Sanctions Laws" means sanctions laws and regulations administered or enforced by:

• the United Nations Security Council;
• Hong Kong;
• the European Union;
• the United Kingdom;
• the United States, including OFAC;
• any other jurisdiction applicable to the Parties or the Services.

1.3 "High-Risk Activity" includes activities involving:

• sanctioned persons or jurisdictions;
• weapons of mass destruction;
• military end-use where restricted;
• prohibited dual-use technology;
• bribery, corruption or facilitation of tax evasion;
• money laundering or terrorist financing;
• forced labour or human trafficking;
• evasion or circumvention of sanctions or export controls.

2. Mutual Representations

Each Party represents and warrants that, as of the Effective Date and each Service Order date:

2.1 it is not a Sanctioned Person;

2.2 it is not owned or controlled by a Sanctioned Person;

2.3 it is not acting on behalf of, or for the benefit of, a Sanctioned Person;

2.4 it has the power and authority to enter into this Agreement;

2.5 entering into and performing this Agreement does not violate Sanctions Laws applicable to it.

3. Service Provider Representations

The Service Provider represents that, to the extent within its reasonable control:

3.1 Personnel engaged for the Services have undergone reasonable identity and compliance screening;

3.2 it will not knowingly assign Personnel who are Sanctioned Persons;

3.3 it will not use the Client's funds, systems or information to facilitate High-Risk Activity;

3.4 it will maintain reasonable compliance procedures appropriate to its business.

4. Client Representations

The Client represents that:

4.1 it will not use the Services to support High-Risk Activity;

4.2 it will provide accurate onboarding and compliance information;

4.3 it will promptly notify the Service Provider if it becomes aware of any sanctions, export control, AML or anti-bribery issue affecting the Agreement;

4.4 it shall not require the Service Provider to act in breach of Sanctions Laws.

5. Anti-Bribery and Anti-Corruption

Each Party shall comply with applicable anti-bribery and anti-corruption laws, including:

• Prevention of Bribery Ordinance, Cap. 201 of Hong Kong;
• UK Bribery Act 2010, where applicable;
• U.S. Foreign Corrupt Practices Act, where applicable;
• other applicable anti-corruption laws.

Neither Party shall offer, give, promise, request or accept any undue financial or other advantage to or from any person with the intention of improperly influencing a business decision.

6. Anti-Money Laundering and Counter-Terrorist Financing

Each Party shall:

6.1 not use the Agreement for money laundering, terrorist financing or proliferation financing;

6.2 provide accurate beneficial ownership information when reasonably requested;

6.3 use only bank accounts in the name of the Party or its authorised payment provider;

6.4 promptly notify the other Party of any suspicious request or circumstance.

7. Export Controls

Each Party shall comply with applicable export control laws and shall not export, re-export, transfer or release any technology, software or technical data in violation of applicable export controls.

8. Modern Slavery and Human Rights

Each Party shall comply with applicable laws relating to modern slavery, forced labour, child labour and human trafficking, and shall not knowingly use such practices in its business or supply chain.

9. Tax Compliance

Each Party shall comply with applicable tax laws and shall not knowingly facilitate tax evasion.

10. Enhanced Due Diligence

The Client may request, and the Service Provider shall provide where reasonable, information necessary for compliance due diligence, including:

• corporate registration documents;
• business registration information;
• beneficial ownership information;
• director and shareholder information;
• bank account confirmation;
• source of funds information, where reasonably required.

11. Changes and Notification

Each Party shall notify the other Party within [5] business days if it becomes aware that:

• it is or may become a Sanctioned Person;
• a director, officer, beneficial owner or key Personnel is or may become a Sanctioned Person;
• a sanctions, AML, anti-bribery or export control investigation is initiated;
• a material compliance breach has occurred.

12. Remedies

If a Party materially breaches this Schedule, the non-breaching Party may, without prejudice to other rights:

• suspend performance;
• require remediation;
• terminate the Agreement or a Service Order immediately;
• refuse to make further payments until the issue is resolved;
• recover losses caused by the breach, subject to the MSA.

13. No Waiver

A delay in exercising rights under this Schedule is not a waiver.

14. Survival

The obligations in this Schedule survive termination of the Agreement to the extent necessary for compliance, investigation or legal proceedings.