ELIGIBILITY CRITERIA JFK IMPORT-EXPORT LLC — CONFIRMA *** Draft for review. These documents were prepared as a starting point and have not been reviewed by a lawyer. Do not execute or publish any of them without review by qualified counsel in each relevant jurisdiction — the United States for the entity, the Democratic Republic of the Congo for the counterparties, and any jurisdiction whose law a counterparty insists upon. *** These criteria are given to every applicant before onboarding begins. They are applied uniformly. A decision that an applicant does not meet them is explained, and can be reviewed by a person on request. ## Any applicant - A company in good standing, registered in the jurisdiction where it operates, with current registration documents - Identified beneficial owners and directors, with identity documents - A bank account in the company's own registered name, verified independently of the person who supplied it - Clear screening against applicable sanctions lists, for the company and for its beneficial owners - No forced labour, no child labour, in the applicant's own operations - Written confirmation that no inducement has been offered to any person in connection with the approval of an invoice ## Suppliers, additionally - An existing contractual relationship with a participating operator - No identity link — bank account, address, telephone, identity document, or beneficial owner — between the supplier and any individual who requisitions, receives or approves that supplier's invoices at the operator. **This is disqualifying, and it is checked before onboarding completes, not at first funding.** - Invoices denominated in United States dollars - Work completed and accepted before an invoice is offered ## Operators, additionally - Capacity to pay a United States account in United States dollars, evidenced by a representation to that effect - Where the contracting entity is a local subsidiary, a payment guarantee from its parent - Ability to provide approved payables data generated by an accounting system and transmitted by the operator's own information technology function - Written answers from the operator's legal counsel to the Purchaser's counterparty control questionnaire, covering ownership and control of the contracting entity and its parent ## Counterparty control Every operator is assessed against a written control questionnaire completed by its own legal counsel. Where the answers place an operator outside the criteria applying to a particular funding arrangement, the operator is not refused — it is financed under a different arrangement, on different terms. **The platform records counsel's answers and applies them; it does not form its own view of ownership or control.** ## What is never a criterion Refusal is never based on the nationality, ethnicity, religion or political affiliation of an applicant's owners, directors or staff. ## Ongoing Eligibility is assessed at onboarding and reassessed on any change of control, change of beneficial ownership, change of bank details, or where new information comes to light. Loss of eligibility ends future purchases; it does not unwind receivables already bought. ## Review An applicant refused on these criteria may ask, in writing, for the decision to be reviewed by a person not involved in it. Where the refusal relates to sanctions or anti-money-laundering obligations, the explanation we can give may be limited by law, and we will say so rather than substitute a different reason. Effective 19 August 2026.