Service Restriction Policy

Last updated: 28.09.2026

This Service Restriction Policy (the “Policy”) is issued by PeopleForce (the “Company”) in accordance with applicable law and governs the categories of persons and entities to whom the Company does not provide, and will not provide, its services.

In view of the armed aggression of the Russian Federation against Ukraine, the Russian Federation is recognized as an aggressor state, and the Republic of Belarus, in view of its support for that aggression, is recognized as a state supporting the aggressor state (together, the “Aggressor States”). Accordingly, the Company following the legislation and public position of the Company does not cooperate with, or provide services to, any person or entity directly or indirectly connected to the Aggressor States, other restricted jurisdictions, or sanctioned parties, as further described in this Policy.

This Policy sets out: (i) the categories of persons and entities with whom the Company will not cooperate; (ii) the restrictions on access to the Company’s platform; (iii) the Company’s right to verify and act upon information concerning prospective and existing clients; and (iv) the consequences of a determination made under this Policy.

1. Restricted Persons and Entities

The Company shall not provide services to, and shall not enter into or continue any contractual relationship with, any person or entity falling within any of the categories described in this Section 1 (each, a “Restricted Party”).

1.1 Restricted jurisdictions

A Restricted Party includes any company, individual, individual entrepreneur, or other entity that is established, incorporated, or registered under the laws of, or is located in, any of the following jurisdictions:

the Russian Federation;
the Republic of Belarus;
the temporarily occupied territories of Ukraine;
the Islamic Republic of Iran; or
the Republic of the Union of Myanmar.

1.2 Sanctioned persons and entities

A Restricted Party includes any person or entity in respect of which any of the following applies under the sanctions regimes of the United Nations, the United States, the European Union, the United Kingdom, or Ukraine (the “Applicable Sanctions”):

the person or entity itself is designated under, or otherwise subject to, the Applicable Sanctions;
the owner or ultimate beneficial owner of the entity is designated under, or otherwise subject to, the Applicable Sanctions; or
the person or entity conducts business, directly or indirectly, with any person or entity designated under, or otherwise subject to, the Applicable Sanctions.

1.3 Relocated companies retaining a presence in the Aggressor States

A Restricted Party includes any company that has relocated, or claims to have relocated, its business out of the Russian Federation or the Republic of Belarus but retains any Presence in either of those jurisdictions. For the purposes of this Policy, “Presence” means any one or more of the following, irrespective of materiality or scale:

any employee or other personnel working in the Russian Federation or the Republic of Belarus;
any proxy, agent, or representative acting on the company’s behalf in the Russian Federation or the Republic of Belarus;
any active recruitment conducted in the Russian Federation or the Republic of Belarus, including the publication of job vacancies there;
any office, management function, or production facility located in the Russian Federation or the Republic of Belarus;
any citizen of the Russian Federation, or any entity located in the Russian Federation, being a major shareholder of the company; or
any domain, email service, or other technical infrastructure used by the company that is registered in, hosted in, or otherwise linked to the Russian Federation or the Republic of Belarus.

1.4 Persons and entities supporting or justifying Russian aggression

A Restricted Party includes any person or entity that supports, finances, or publicly justifies, in any manner, the aggression of the Russian Federation against Ukraine.

1.5 Persons and entities refusing due diligence

A Restricted Party includes any person or entity that refuses or fails to complete the due diligence and compliance procedures required by the Company.

1.6 Circumvention of this Policy

A Restricted Party includes any person or entity that circumvents, or attempts to circumvent, this Policy or any other policy of the Company, whether directly or indirectly, including through the use of intermediaries or nominees, or by providing false, incomplete, or misleading information.

2. Access Restrictions

Independently of, and in addition to, Section 1, the Company blocks, and shall not grant, access to its platform to any user accessing or attempting to access the platform from the Russian Federation or the Republic of Belarus.

3. Verification and Decision-Making

The Company reserves the right, at its sole discretion and at any stage of the relationship, to verify the history, ownership structure, and reputation of any prospective or existing client for the purpose of determining whether such client constitutes a Restricted Party.

Where the Company determines that a prospective or existing client satisfies one or more of the criteria set out in Section 1 of this Policy, the Company reserves the right to refuse to enter into, or to terminate, the relevant relationship, and shall be under no obligation to reconsider such decision.

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