Sanctions & Trade Control

Many countries are subject to and have to adhere to International Trade Control (“ITC”) restrictions concerning the use of, and/or the import and/or export of goods, services, technology, and software, from or through certain restricted countries, entities, or individuals.

Non-compliance with such Sanctions may have serious cross border consequences for those who violate these regulations. Although not all Sanctions may be directly applicable to PDO, we need to consider the constraints those Sanctions may have on our international shareholders, vendors, suppliers, contractors, manufacturers, and other service providers.

Although Sanction related compliance was part of our business partners’ selection process on a high level, this is now formalized through a newly developed Code of Practice. Our practice aims to mitigate the risk of non-compliance by PDO and/or its staff with Sanctions and Trade Controls, by providing clear unambiguous guidance

Our ITC due diligence review, verification, and approval process should identify, asses, and guide decision makers in developing mitigating controls, and/or responses to vendor applications, and the appointment of sub-contractors involving entities that may be subject to Trade Controls or Sanctions.

The process deliverables are governed by a risk-based approach, approving or declining vendor registrations and/or the appointment of sub-contractors based on the levels of risk and exposure relevant to Local and/or International Trade and Sanction Controls, and/or the relevance thereof to PDO, its shareholders and associated business partners/vendors.​