Compliance Framework

10-4 operates within a regulated environment and must comply with applicable EU and local laws. Before providing access to sensitive demonstrations or technical materials, or before entering into a commercial relationship, we carry out a proportionate compliance review of the prospective counterparty.
This process helps us meet our legal and regulatory obligations while ensuring that our technology is shared responsibly, securely and with appropriate partners.

Last updated 19 July 2026

1. Approach

Our compliance framework is built around four key areas. Each prospective engagement is reviewed across all four to ensure that we meet our legal, regulatory and responsible business obligations.
Where questions or concerns arise, we seek to address them with the counterparty wherever possible. However, we may be unable to proceed if the relevant legal or compliance requirements cannot be satisfied.

• 01Export controlTransfers of controlled software and technology are assessed under Regulation (EU) 2021/821 and applicable Polish strategic-goods laws.
• 02Sanctions & restricted partiesBefore sensitive access is granted or a business relationship begins, prospective counterparties are screened against applicable EU, Polish and UN sanctions lists, plus OFAC and other restricted-party lists where relevant.
• 03Know Your CounterpartyWe review the counterparty’s legal identity or status, authority to act and intended end use. Ownership and control are also considered where applicable.
• 04Financial crime riskMoney-laundering, terrorist-financing, bribery and corruption risks are considered where relevant to the proposed engagement and payment arrangements.

2. Preliminary screening

Relevant parties to a proposed engagement, including customers, integrators, suppliers, agents, distributors and investors, are screened on a risk-based basis before access to sensitive materials or before a business relationship begins. Ownership and control are reviewed where applicable.

Preliminary screening establishes, at minimum:

• Who the party is — its legal identity or official status, jurisdiction, authority to act, and ownership and control where applicable.
• Whether the party and relevant owners, controllers, representatives or intermediaries are subject to applicable sanctions or other legal restrictions.
• Whether relevant individuals hold prominent public functions, and whether their involvement, or the use of agents or intermediaries, creates additional bribery or corruption risk.
• Whether the stated end use, end user and destination are plausible and lawful, with no apparent diversion risk.

If required information cannot be obtained or material concerns cannot be resolved, we may pause or decline the engagement. The decision and its basis are recorded. Relevant information is reported to a competent authority where required by law.

3. Know Your Counterparty (KYC)

Our counterparty review is risk-based and proportionate to the proposed engagement. Additional checks may be carried out when specific risk indicators arise.

• IdentifyCollect relevant information on the counterparty’s legal identity or official status, jurisdiction, authority to act, ownership and control where applicable, and intended end use.
• VerifyConfirm the counterparty’s legal existence or official status and, where relevant, the identity and authority of its representatives using reliable, independent sources.
• AssessReview each proposed engagement for sanctions, bribery and corruption, export-control, diversion and, where relevant, money-laundering and terrorist-financing risks. Additional checks are carried out when specific risk indicators arise.
• MonitorReview relevant information that becomes available during the relationship and repeat screening where material changes or new risk indicators arise, including changes in sanctions status, ownership, control, end user or stated end use. Where credible information indicates possible misuse, diversion or non-compliance, we may suspend or terminate the relationship and take any action required by law.

• AMLMoney launderingWe review the identity of the payer, the source and route of payment, and any inconsistencies between the payment arrangements and the proposed engagement.
• ABCBribery & corruptionWhere public officials, agents or intermediaries are involved, we review their role, the services provided and the commercial basis for any fees or commissions.
• CFTTerrorist financingWe screen relevant parties against applicable sanctions and terrorism-related designation lists and do not proceed where a legal restriction applies.

4. Governance and record-keeping

Export-control records are retained for the periods required by applicable law. Other screening and counterparty-review records are retained for as long as necessary for compliance, legal and risk-management purposes. Records are provided to competent authorities where legally required. Personal data collected for screening and counterparty review is handled as described in our privacy policy.

5. Raising a concern

Suspected breaches of this framework may be reported to info@10-4.tech with the subject “Compliance”. Reports are handled with appropriate discretion, and retaliation against persons who raise concerns in good faith is not tolerated. Statutory protections apply where the requirements of the Polish Act of 14 June 2024 on the protection of whistleblowers are met.