Code of business conduct
We conduct all our operations with integrity and honesty and comply with all applicable UN, US, EU and host country laws and regulations governing trade [import and export] and sanctions.
We are committed to establishing mutually beneficial relations with our business counterparties – customers, contractors, suppliers, agents, professional advisers, JV partners and any other business partners – based on transparency, accountability and compliance with all relevant laws and regulations. To this end, we take reasonable and appropriate actions to identify and assess their integrity.
Our Sanctions Compliance Policy
As a U.S. registered company subject to U.S. jurisdiction, as well as having controlled subsidiaries in foreign locations that conduct business with the United States, U.S. persons and use U.S. goods and services, we are committed to a culture of compliance throughout our company.
We employ a risk-based approach to sanctions compliance by developing, implementing and routinely updating our Sanctions Compliance Program which is relevant to our operations and markets and other factors affecting our risk profile.
We are committed to complying with applicable anti-money laundering, corruption and terrorist financing laws and regulations. By adhering to risk-based due diligence processes, we seek to conduct business only with counterparties involved in legitimate business activities, with funds derived from legitimate sources.
Anti-bribery and corruption
We do not give or receive, whether directly or indirectly, bribes or other improper advantages for business or financial gain, whether in the private or public sector. We comply with all laws and regulations that prohibit bribery and corruption, and we do everything we can to make sure our suppliers, contractors and JV partners do the same.
Implementing our Code of Conduct
We communicate our code of business conduct to all our employees, suppliers and business partners and induct our managers at all levels to monitor it.