Trade Compliance Policy

Last updated: 7 July 2025

HAKO Global Trading Limited ("the Company") is a Hong Kong registered entity engaged in the international export of brand-new Chinese vehicles. We are committed to conducting our business in full compliance with applicable trade control, sanctions, anti-bribery, and ethical sourcing laws.

This Trade Compliance Policy sets out the principles and procedures that govern our export operations and the responsibilities of our customers.

1. Export Control Compliance

1.1 Hong Kong Export Controls

The Company complies with the Import and Export Ordinance (Cap. 60) of Hong Kong and all applicable regulations governing the export of goods from the Hong Kong Special Administrative Region. We ensure that all export documentation, including certificates of origin, commercial invoices, and bills of lading, is accurately prepared and submitted to the relevant authorities.

1.2 People's Republic of China Export Controls

As vehicles are sourced from manufacturers in the People's Republic of China, the Company works with suppliers and freight forwarders to ensure compliance with applicable Chinese export procedures. We do not export goods subject to specific Chinese export licences without obtaining the required authorisations.

1.3 Destination Country Regulations

The Company supports customers in understanding destination country import requirements; however, the Customer bears ultimate responsibility for obtaining any import licences, authorisations, or compliance approvals required by the destination jurisdiction.

2. International Sanctions

2.1 Sanctions Screening

The Company conducts sanctions screening on all customers and transaction counterparts against published sanctions lists, including:

• The United Nations Security Council Consolidated List;
• The European Union Consolidated Financial Sanctions List;
• The United Kingdom HM Treasury Office of Financial Sanctions Implementation (OFSI) list;
• The United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list;
• The Hong Kong Monetary Authority list of designated persons.

2.2 Restricted Countries

The Company does not engage in transactions involving parties located in, or goods destined for, countries subject to comprehensive United Nations, European Union, or Hong Kong sanctions. Where partial sanctions apply, the Company will assess the specific transaction and may decline or impose additional conditions.

2.3 Prohibited Parties

The Company will not enter into any transaction with a party that appears on a sanctions list, or with a party that we reasonably believe is acting on behalf of a sanctioned person or entity.

3. Anti-Bribery and Anti-Corruption

3.1 Zero-Tolerance Policy

The Company maintains a zero-tolerance policy toward bribery and corruption in any form. We comply with the Prevention of Bribery Ordinance (Cap. 201) of Hong Kong, the United Kingdom Bribery Act 2010, and other applicable anti-corruption laws.

3.2 Prohibited Conduct

No employee, agent, or representative of the Company may:

• Offer, promise, give, or accept a bribe or improper advantage;
• Make facilitation payments to expedite routine government action;
• Make political contributions or charitable donations as a means to secure improper advantage;
• Engage in any activity that creates a conflict of interest with the Company's ethical obligations.

3.3 Third-Party Due Diligence

The Company conducts due diligence on agents, freight forwarders, customs brokers, and other intermediaries to ensure they uphold equivalent anti-corruption standards.

4. Ethical Sourcing

4.1 Authorised Sourcing

The Company sources vehicles exclusively from manufacturers and authorised distributors. We do not engage in the trade of used, reconditioned, stolen, or counterfeit vehicles.

4.2 Manufacturer Compliance

We select manufacturing partners that demonstrate compliance with applicable labour, environmental, and quality standards. While we rely on manufacturer representations regarding their own compliance, we prioritise partners with established export track records.

4.3 Quality Assurance

Every vehicle is subject to pre-shipment inspection at the Chinese port of loading before export. The inspection verifies the vehicle's condition, configuration, and documentation.

5. Regulatory Compliance

5.1 Hong Kong Regulation

The Company operates under the regulatory framework of the Hong Kong Special Administrative Region, including:

• The Companies Ordinance (Cap. 622);
• The Inland Revenue Ordinance (Cap. 112);
• The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615);
• The Personal Data (Privacy) Ordinance (Cap. 486).

5.2 International Compliance

Where transactions involve parties in the European Union, the United Kingdom, or other regulated jurisdictions, the Company respects applicable extraterritorial regulations, including the GDPR and relevant trade control regimes.

6. Customer Responsibilities

6.1 Accurate Information

Customers must provide accurate and complete information when requesting quotations, placing orders, and submitting KYC documentation. The provision of false or misleading information may result in order cancellation and reporting to the relevant authorities.

6.2 Import Compliance

Customers are responsible for ensuring that the import of vehicles into the destination country complies with all local laws, including customs declarations, duty payments, and vehicle registration requirements.

6.3 Prohibited Use

Customers must not use the Company's services for any illegal purpose, including money laundering, terrorism financing, sanctions evasion, or tax evasion. Any suspected prohibited use will be reported to the relevant authorities.

6.4 Cooperation

Customers agree to cooperate with the Company's compliance procedures, including KYC verification, sanctions screening, and transaction monitoring, as described in our KYC Information and AML Policy pages.

7. Reporting and Whistleblowing

The Company encourages employees, customers, and business partners to report any suspected violation of this policy. Reports may be made confidentially to CONTACT@hakoautomobile.com. The Company does not tolerate retaliation against any person who reports a suspected violation in good faith.

8. Review and Updates

This Trade Compliance Policy is reviewed at least annually and may be updated to reflect changes in law or business practice. The "Last updated" date indicates the most recent revision.

9. Contact

For questions regarding this Trade Compliance Policy, please contact us:

• Company: HAKO Global Trading Limited
• Email: CONTACT@hakoautomobile.com
• WhatsApp: +213 780 442 267