Antiboycott Policy

Purpose

This Antiboycott Policy ("Policy") is established to ensure that Woltmann & Bonventre, Inc. and its employees comply with all applicable U.S. antiboycott laws and regulations. This Policy outlines the company's commitment to adhering to the requirements of the U.S. Export Administration Act, the Tax Reform Act of 1976, and any other relevant regulations.

Scope

This Policy applies to all employees, officers, directors, agents, representatives, and affiliates of Woltmann & Bonventre, Inc.

Policy Statement

Woltmann & Bonventre, Inc. strictly prohibits participation in or cooperation with any international boycott that is not sanctioned by the United States government. This includes providing information, making agreements, or taking actions that support such boycotts.

Prohibited Actions

Employees and representatives of Woltmann & Bonventre, Inc. must not:

· Refuse to do business with or in a boycotted country or with blacklisted companies and individuals.

· Furnish information about business relationships with or in boycotted countries or with blacklisted companies and individuals.

· Discriminate against individuals or companies based on race, religion, sex, national origin, or any other unlawful criteria in support of a boycott.

· Use or include boycott-related terms or conditions in contracts, agreements, or business dealings.

Reporting Requirements

Any requests to participate in, support, or furnish information concerning an unsanctioned boycott must be immediately reported to the Compliance Officer. This includes:

· Receipt of boycott-related requests in writing, verbally, or through any other means.

· Inclusion of boycott-related terms in contracts or business documents.

· Inquiries or demands to provide information that could support a boycott.

Compliance and Training

Woltmann & Bonventre, Inc. will provide regular training to employees on U.S. antiboycott laws and this Policy. Employees are expected to familiarize themselves with the Policy and attend required training sessions.

Penalties for Non-Compliance

Failure to comply with this Policy and U.S. antiboycott laws can result in severe penalties for both the company and the individuals involved, including fines, imprisonment, and loss of export privileges. Any employee found violating this Policy may face disciplinary action, up to and including termination of employment.

Review and Updates

This Policy will be reviewed annually and updated as necessary to ensure compliance with current laws and regulations.

Contact Information

For questions or to report a potential violation, please contact the Compliance Officer at 718.656.6633.

Acknowledgment

I acknowledge that I have read and understand the Antiboycott Policy of Woltmann & Bonventre, Inc. and agree to comply with its terms.

Signature: _________________________

Name: _____________________________

Date: _____________________________