Pomegranate has, since its inception in 2014, implemented a sanctions compliance policy establishing strict guidelines for business dealings in relation to Iran. Under Pomegranate’s sanctions policy, all employees, officers, directors, and all contractors, agents and other persons engaged to act for or on behalf of any Pomegranate company, as well as Pomegranate’s portfolio companies, must comply with applicable sanctions laws and regulations in relation to each country in which we do business.
Pomegranate adopted the most recent version of its sanctions policy on June 14, 2023. It sets out the following sanctions compliance framework:
Responsibility: Pomegranate has a Compliance Officer who is responsible for overseeing Pomegranate’s sanctions policy and for promoting sanctions compliance.
Due diligence and screening: Pomegranate applies a conservative risk-based approach to due diligence, and conducts sanctions screenings of its significant contractual counterparties, including each investment target company and their shareholders and board members, against EU, UK, and US sanctions lists. In addition, external legal counsel conducts periodic reviews of Pomegranate’s investment portfolio companies and their shareholders and board members.
Continual monitoring: Pomegranate conducts a compliance review of its portfolio every twelve months, if there is any change in ownership or ownership status in a portfolio company, or if Pomegranate otherwise decides to do so.
Compliance obligations for portfolio companies: Pomegranate uses its best efforts to procure the adoption of, and compliance with, trade controls and sanctions policies and procedures by its portfolio companies (to the extent that Pomegranate has control over such companies).
Training: Pomegranate conducts sanctions compliance trainings on a periodic basis.
Recordkeeping: Pomegranate documents screening and monitoring measures undertaken and their results.
Violations: Failure to comply with the sanctions policy or applicable sanctions by a Pomegranate employee is grounds for disciplinary action up to and including termination of employment.
Reporting of violations: All Pomegranate employees are required to report suspected violations of sanctions to the Compliance Officer. Pomegranate does not tolerate any form of retaliation against a person that raises a sanctions-related concern in good faith.
Pomegranate monitors relevant sanctions developments and adapts its compliance measures and its Sanctions Policy accordingly.