Trade Compliance & Sales Territory Policy

Compliance Commitment

Wellav adheres to global trade controls, export regulations and applicable sanctions. Wellav does not sell or supply products to prohibited jurisdictions, entities or end users, including but not limited to Russia, Belarus, Iran, North Korea and Cuba. All official sales and distribution channels are published on our corporate website: www.wellav.com. Wellav reserves the right to perform customer and transaction due diligence for all orders.

Disclaimer on wellav.ru

The website wellav.ru is a fraudulent and unauthorized domain. It has no connection, affiliation, or authorization from Wellav. The site contains outdated and misleading information and shall not represent the Company's current operational status in any respect. Accordingly, all content, transactions and related activities originating from wellav.ru shall have no binding effect on Wellav, and Wellav assumes no legal liability whatsoever.

Distribution and Resale Controls

Wellav products are sold only through authorized channels, all of which are subject to compliance screening. Wellav has ceased all sales activities in Russia since 2022. Partners shall not circumvent export controls or sanctions through Wellav's distribution network.

Authorized distributors and partners must:

• • Comply with applicable trade laws and local regulatory requirements;
  • Refrain from selling or transferring Wellav products to any restricted parties or sanctioned jurisdictions (including entities on the U.S. Commerce Department Entity List);
  • Prevent products from being deployed for prohibited end uses, including applications related to nuclear, missile, chemical or biological weapons;
  • Conduct proper due diligence on downstream channels and end-use purposes.

End-User and End-Use Verification

Wellav reserves the right to decline or suspend any transaction where there is uncertain shipment routing, unverifiable end users, restricted end use, risk of diversion to sanctioned territories, or any non-compliant trade activity.

Policy Updates

Applicable regulations and sanctions lists are subject to change. Wellav regularly reviews its sales and distribution activities on an ongoing basis to ensure continuous compliance.