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Sanctions

 
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We are committed to ensuring that our business is conducted in compliance with all lawful sanctions regimes, and that we do not engage with any sanctioned parties

Sanctions include prohibitions or restrictions on:

  • exports or re-exports to a sanctioned country
  • imports from, or dealings in property originating from, a sanctioned country
  • travel to or from a sanctioned country
  • investments and other dealings in a sanctioned country, or with designated parties
  • making funds or resources available to designated parties
  • transfer of restricted software, technical data or technology by email, download or visiting a sanctioned country
  • supporting boycott activity

Awareness of, and compliance with, sanctions

We must be aware of, and fully comply with, all lawful sanctions regimes affecting our business. We must ensure that we never:
  • supply our products, or allow our products to be supplied, to any person
  • purchase goods from any person, or
  • otherwise deal with any person or property
in contravention of any applicable sanction, trade embargo, export control or other trade restriction.

Sanctions may be imposed by individual countries or supra-national bodies, such as the UN and EU.

Some sanctions regimes apply both to US persons (wherever located), to the use of US currency for payments and to exports/re-exports of US-origin products and products with US-origin content (whether or not the entity handling them is a US person).

Breaching sanctions carries serious penalties, including fines, loss of export licences and imprisonment.

Minimising the risk of breach

Group companies' internal controls must minimise the risk of breaching sanctions, and provide training and support to ensure that employees understand them and implement them effectively, particularly where their work involves international financial transfers or cross-border supply or purchase of products, technologies or services.

Sanctions no longer just target whole countries with economic, trade or diplomatic restrictions. Increasingly, they are also aimed at designated individuals or groups, and the companies or organisations associated with them.

The list of prohibited countries and designated persons changes frequently. If our work involves the sale or shipment of products, technologies or services across international borders, we must keep up-to-date with the rules.

We must also notify our local LEX Counsel immediately if we receive any sanctions-related communications or requests from official bodies or our business partners. For more information, see the Sanctions Compliance Procedure on The Hub.

Who to talk to

Your line manager
Higher management
Your local LEX Counsel
Head of Compliance:
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