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.
The Group takes compliance with international sanctions very seriously. As a rule*, no Group company is permitted to enter into a transaction if it would breach a sanction imposed by any of the following:
Note that in general, all Group companies must observe sanctions imposed by any of these bodies even if the body
has no direct jurisdiction over that Group entity. If this policy conflicts with local law, please raise the issue with Group
Trade Compliance or Group Legal for advice. The policy applies to all transactions, including but not limited to any
financial transaction and the sale or purchase of products and services.
Countries and territories that we do not normally transact with
All Group companies are required to implement and respect the following guidance. We do not normally transact with parties in the following territories:
For any proposed transaction involving a party in any of these countries, you must perform a sanctions check (see
2.3 below) and consult with the Group Head of Risk, Assurance and Trade Compliance at an early stage since
there is a high risk it could be sanctioned. Even if the transaction were permitted, there are practical issues (such
as reputational risk, banking, and insurance) that mean that any possible transaction must be reviewed on a case-by-case basis.
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 undertaking any contractual commitment:
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 committing to a transaction. For sales transactions, the sanctions check request form should be reviewed by the business unit’s Legal Representative and signed by the business unit’s Finance Director before it is sent to Group Legal. To avoid wasted effort you are advised to seek input from Group Trade Compliance or Group Legal at an early stage.
The requirement to perform a sanctions check applies if any party to the transaction (such as the vendor, end-user, customer, agent or distributor) is based in the territories specified.
Should you require further advice contact Group Legal or Group Compliance.
* If a business is not directly impacted by a sanction imposed by a foreign regime (e.g. a business in Germany in respect of
UK or US sanctions), it may seek an exception to the rule. Such requests require approval by either the CEO or CFO.
** Since March 2022 the Group operates a complete ban on transactions with parties in Russia, Belarus and, for the avoidance
of doubt, any illegally annexed regions of Ukraine (e.g. Crimea, the Donbas, etc). This extends above and beyond the scope
of international sanctions. No transaction with a party in these locations is permitted without the express approval of either
the CEO or CFO.
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