Group Sanctions Policy

Governments, including the UK Government, use sanctions as a mechanism to pursue foreign policy objectives. The targets of sanctions are typically involved in serious breaches of human rights or violations of international law.

1. Policy Requirements

The Group takes compliance with international sanctions very seriously. In particular no Group company is permitted to enter into a transaction if it would breach a sanction imposed by any of the following:

Note that all Group entities must observe sanctions imposed by any of these bodies even if the body has no direct jurisdiction over that Group entity. The policy applies to all transactions, including products and services.

1.1 Countries and territories that we do not normally sell to

All Group companies are required to implement and respect the following guidance. We do not normally sell to:-

If a commercial opportunity arises in one of these countries, please consult with Group at an early stage since it is highly likely to be sanctioned and even if not, we are unlikely to be able to approve the transaction without very careful consideration.

1.2 Countries and territories for which a sanctions check is mandatory

In respect of the following countries, you must complete a sanctions check with Group before accepting an order:

Please complete the sanctions check request form with the required information about the end user and intermediaries to enable sanction checks to be  performed before an order is placed. The sanctions check request form should be reviewed by the business unit Contracts Manager and signed by the business unit Finance Director before it is sent to Group Legal. To avoid wasted effort you are advised to seek input from Group Legal at an early stage.

Note that this covers transactions where any of the end-user, agent or distributor are based in these countries/regions.

Should you require further advice contact Group Legal or Group Compliance.