Compliance and Anti-Separatist Policy

for attorney Anna Bondarenko's website

1. General Provisions

Attorney Anna Bondarenko conducts professional activities in strict accordance with international, European, and national compliance standards, as well as principles of the rule of law, independence of the legal profession, and compliance with the legislation of Ukraine, the European Union, and Spain.

2. Policy of Refusing Service to Sanctioned Persons and Separatist Entities

The Attorney does not provide and will not provide legal services to:

● Persons subject to international, national, or sectoral sanctions imposed by the UN, EU, USA, Ukraine, and other states and international organizations; ● Persons, companies, and organizations directly or indirectly associated with financing terrorism, money laundering, violation of international sanctions, as well as separatist entities not recognized by Ukraine and the international community.

Grounds:

● International norms: UN Security Council Resolutions, EU Regulations and Directives on sanctions, 4th and 5th EU Anti-Money Laundering Directives (AML), FATF Recommendations; ● Law of Ukraine "On Sanctions", Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction"; ● Professional standards: Code of Professional Ethics for Attorneys of Ukraine, Code of Conduct for European Lawyers, provisions of the National Association of Attorneys of Ukraine.

3. Compliance and Client Verification

The Attorney conducts mandatory client due diligence:

● Identification of individuals and beneficial owners; ● Verification against sanctions lists, connections with separatist entities, suspicious financial transactions; ● In case of risk identification — refusal to provide services without explanation of reasons.

The Attorney does not participate in operations aimed at circumventing sanctions, masking sources of funds, concealing beneficiaries, and other actions contrary to international and national compliance requirements.

4. Anti-Separatist Policy

● The Attorney does not provide and will not provide services to persons, organizations, and structures directly or indirectly supporting separatism, encroaching on the territorial integrity and sovereignty of Ukraine, as well as persons whose actions are aimed at undermining the national security of Ukraine.

● All professional activities are based on principles of inadmissibility of assistance to illegal entities, annexation, occupation, and any forms of interference in the internal affairs of Ukraine.

5. Adherence to Professional and Ethical Standards

The Attorney is guided by:

● Law of Ukraine "On Advocacy and Advocacy Activity"; ● Rules of Professional Ethics for Attorneys of Ukraine; ● Code of Conduct for European Lawyers; ● International standards for combating money laundering and terrorist financing (FATF, EU AMLD).

The Attorney does not give advice or perform actions aimed at circumventing the law, legalizing criminal proceeds, financing terrorism, evading sanctions, and violating the territorial integrity of Ukraine.

6. Public Position of the Website

● The website policy and all internal documents explicitly provide for the impossibility of providing services to persons subject to sanctions, as well as separatist and occupation entities

● In case of identifying relevant risks, cooperation is terminated immediately, and information may be transferred to competent authorities in accordance with the law.

This policy is mandatory for implementation and cannot be changed at the request of a client or third parties.

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