As a company, we are committed to carrying on business in accordance with the highest ethical standards. This includes complying with all applicable trade sanctions regulations (“Sanctions Laws“) in the countries in which we operate.
This Policy applies to all employees, officers, directors, and contracted personnel of CartFlows “Company”, and, all persons that perform services for or on behalf of Company, including without limitation, supply chain business partners, suppliers, consultants, contractors, distributors, and agents (including without limitation, sales agents/representatives) (each an “Associated Person”, collectively “Associated Persons”).
What do we mean by sanctions?
Sanctions are laws and regulations enacted by governments (such as the government of the United States (“U.S.”), international organisations (such as the United Nations (“U.N.”) and supranational bodies (such as the European Union (“E.U.”) to promote foreign policy and other objectives, including: a) limiting the adverse consequences of a situation of international concern (for example, by denying access to military or paramilitary goods, or to goods, technologies or funding that enable international terrorism or the proliferation of weapons of mass destruction); b) seeking to influence other persons or governments to modify their behaviour; c) penalizing other persons or entities (for example, by blocking or “freezing” their assets, or denying access to international travel or to the international financial system).
Sanctions are intended to deter a range of activities, which may include political or military aggression, providing sanctuary for criminals and terrorists, developing nuclear or other weapons programs, and abusing human rights. Sanctions are implemented largely by prohibiting companies and individuals from doing business with persons, entities, countries and governments that are the targets of the Sanctions. Such restrictions can include: a) Export bans, import bans and prohibitions on the provision of certain specified services. b) Prohibiting certain commercial activities (such as joint ventures and other investment) c) Barring the transfer of funds to and from a sanctioned country; targeted financial Sanctions, which include freezing the assets of and prohibiting any dealings with, a government, country, or territory, and designated entities and individuals. d) Travel bans and other financial restrictions.
One key method of imposing Sanctions is to designate a country, territory, government, individual or entity as a target of Sanctions (a “Sanctions Target”). For example, the United States publishes a list of Specially Designated Nationals (or “SDNs”), which includes individuals and entities. In general, persons subject to U.S. jurisdiction must block (or freeze) any assets of an SDN within the U.S. person’s possession or control, and may not have any dealings with, or provide any services to, an SDN. The United States also imposes economic sanctions and embargoes that target geographic regions and governments; some programs are comprehensive in nature and block the government and include broad-based trade restrictions, while others target specific individuals and entities. In non-comprehensive programs, there may be broad prohibitions on dealings with countries, and also against specific named individuals and entities.
CartFlows’s principles and measures to comply with Sanctions and to identify, mitigate, and manage Sanctions risk
All CartFlows employees and contractors must be aware of and follow to their countries and or business related activities. We should comply with the requirements of the U.S., U.N. and E.U. Sanctions regimes (whenever these apply to its operations) wherever it operates, and will not undertake any business that would breach those Sanctions regimes.
In addition to complying with the requirements of the U.S., U.N. and E.U. Sanctions regimes (whenever these apply to its operations), Company complies with other Sanctions regimes whenever they apply to particular CartFlows operations, and will not undertake any business that would breach those Sanctions regimes.
The potential measures to comply:
Where we do business: We should ensure compliance with sanctions on restricted countries/territories;
Who we do business with: We should ensure compliance with sanctions on restricted persons/entities;
How we do business:
a) We should ensure we do not circumvent, evade, or facilitate the contravention of sanctions rules; and Red flags: ensuring we report any suspicions which may raise sanctions concerns. We should not provide products or services even where it is permitted by law, particularly where the circumstances present reputational risk.
Some examples of red flags to be reported include:
- The customer is reluctant to offer information or clear answers on routine commercial issues
- (including intended geography of sales, beneficial ownership, or locations of operation);
- The consignee has a different name or location than the customer or ultimate end user;
- The counterparty is evasive about its customers;
- Unusual invoicing, shipping, or packaging requests;
- Abnormal shipping route;
- Unusual volume requests compared to the anticipated size of the market;
- Unusually favorable payment terms or large cash payments;
- Any suspicion or evidence to suggest the possible involvement of a Restricted Territory or
- Restricted Party;
- Any suspicion or evidence to suggest that products to be exported, re-exported, or otherwise
- provided to a customer may be “dual-use” (i.e., having a potential civilian and military
- application) (although most of our finished consumer products should not be “dual-use”);
- Any suspicion or evidence to suggest a military related end-use (e.g., military end-user).
b) All commercial relationships and transactions, directly or indirectly, involving Sanctioned Countries and nationals of Sanctioned Countries shall be immediately canceled and/or not pursued until screened and cleared for action in accordance with this policy, processes and procedures.
c) Commercial relationships and transactions with persons whose name is not on a list of Specially Designated Nationals may still be prohibited if that commercial relationship or transaction directly or indirectly, involves Sanctioned Countries and nationals of Sanctioned Countries. In such cases commercial relationships and transactions shall also be immediately canceled and/or not pursued until screened and cleared for action in accordance with this policy.
Any CartFlows employee or officers or directors, or contracted personnel contractor or “Associated Persons” , who violates this Policy may be subject to appropriate disciplinary action, independently from potential other penalties resulting from their behavior. Internal Audit shall conduct regular checks on local businesses to ensure compliance with Sanctions Laws.
Updates, Review and Ownership
This Policy may be updated from time, and the updated version of the Policy will be immediately made available at https://cartflows.com/sanctions-policy/