- Conduct appropriate, ongoing due diligence to understand the business and background of customers and business partners. This includes identifying the ultimate beneficial owner of the business.
- Follow appropriate sanctions processes to ensure we do not engage in any transaction with sanctioned countries, regions, companies, individuals, goods or services
- Never engage in a business transaction if we suspect that it involves funds derived from illegal activity
Trade sanctions and money laundering

We adhere to applicable laws and regulations governing trade sanctions and anti-money laundering. We conduct business with reputable customers and business partners involved in legitimate business activities with funds derived from legitimate sources.
This means that we:

Trade sanctions are legal instruments used by governments and multinational bodies to influence foreign policy either by prohibiting business dealings with certain countries, individuals and entities, or by restricting the import or export of certain products or services.
Money laundering is the act of disguising the illegal source of money or assets to make them appear legitimate.
Red flags for money laundering
- To or from someone who is not a party to the contract
- To or from offshore accounts, or accounts in countries outside our usual markets
- To make payments to accounts other than the ones specified in the original agreement
- To make or receive payments in cash
- To make or receive overpayments
- To split payments into several smaller batches

I am about to enter into a contract with a new supplier where the ownership structure is unclear. Am I allowed to sign the deal anyway?
No. We must understand the background of our suppliers before contracting with them. This includes identifying the ultimate owner of the business. First, ask the supplier to provide this information to you, then do a sanctions check along with any other required due diligence before signing the agreement.
Questions or concerns?
Consult your Ethics or Legal teams for guidance.