Please find the answers of BMW Group below:
- Has your company put in place appropriate internal mechanisms and tools to carry out enhanced due diligence of your supply chains, intermediaries, customers and end-users to understand the risk of your products’ diversion to Russia? If yes, please provide details.
We have provided detailed and continuous communication to our distribution network and internal stakeholders regarding the product limitations and red flags to watch out for during the due diligence process regarding diversion risks. As far as we have reliable information we also apply preventive measures with monitoring mechanisms being in place for risk markets identified.
- Does your company consider potential red flags that suggest the use of front companies that may hide the true end-users of your products and thereby evade sanctions and export controls? If yes, please provide details.
We have communicated red flags to watch out for regarding critical end-users to our distribution partners and we monitor end-user compliance in some cases using various detection methods.
- Has your company taken any other actions to prevent re-export of your products to Russia?
No, not at this point in time.