Mapei Trade Control Policy

Mapei’s products, and their sale and distribution, are subject to the laws, export controls, sanctions and regulations of the European Union. The European Union has issued far-reaching economic sanctions against Russia and Belarus in response to the conflict in Ukraine. The sanctions packages include both a strengthening and expansion of existing financial and personal sanctions as well as restrictions on the movement of goods with Russia and Belarus.

In order to combat the circumvention of export bans and more specifically the situation where goods exported to third countries are re-exported to Russia, the European Union has made it a requirement for EU-based exporters to insert a "no re-export to Russia" clause in export/sale/supply/transfer or similar contracts. While this obligation would apply only in respect of specific types of sensitive goods, Mapei has decided to extend the application of this obligation to all Mapei products.

As a result, the following provisions apply to all contracts (each of them, an “Agreement”) by which a third party (“Buyer”) buys and/or imports products from a Mapei Group company (“Mapei”).

(1) Buyer shall not sell, export or re-export, directly or indirectly, to the Russian Federation or for use in the Russian Federation any goods supplied under or in connection with the Agreement.

(2) Buyer shall not sell, export or re-export, directly or indirectly, to Belarus or for use in Belarus any goods supplied under or in connection with the Agreement.

(3) Buyer shall undertake its best efforts to ensure that the purpose of paragraph (1) and (2) is not frustrated by any third parties further down the commercial chain, including by possible resellers.

(4) Buyer shall set up and maintain an adequate monitoring mechanism to detect conduct by any third parties further down the commercial chain, including by possible resellers, that would frustrate the purpose of paragraph (1) and (2).

(5) Any violation of paragraphs (1), (2), (3) or (4) shall constitute a material breach of an essential element of the Agreement, and Mapei shall be entitled to seek appropriate remedies, including, but not limited to:

• (i) termination of the Agreement; and
• (ii) a penalty of 10 % of the total value of the Agreement or price of the goods exported, whichever is higher.