Sanctions and Export Control Policy

1. Principle

We comply with the sanctions regulations of Switzerland as well as with the regulations of the EU, the United States and the United Nations that are relevant to our business. We do not deliver to embargoed territories and not to listed persons or organisations.

2. Screening

• Screening of new customers, suppliers and beneficial owners against the relevant sanctions lists before the first transaction and periodically thereafter.
• Verification of country of destination, end user and intended use for every export.
• Clarification of the licensing requirement for goods with possible dual use.

3. Prohibition of circumvention

Deliveries via third countries that evidently serve to circumvent sanctions are prohibited. Where there are indications of circumvention, the transaction is halted and submitted to Executive Management.

4. Documentation

Screening results, export documents and end-use declarations are retained for at least ten years.