In response to your inquiries, we reply as follows:
- 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.
A. Including the export to Russia, we have internal rules and policies for export controls. For basic export control policies, we will help maintain international peace and security through compliance with all applicable laws and regulations concerning import and export, and will operate appropriately according to our internal rules and policies. We have established Corporate Regulations concerning Security Export Control based on this policy to ensure implementation of strict export control practices in line with relevant laws and regulations, screening all goods and technologies intended for export against such factors as destination countries and regions as well as intended end use and end users.
2. 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.
A. Including the export to Russia, we consider such potential red flags. When screening goods and technologies intended for export, we use red flag indicators to find and avoid trading with any front companies hiding true end-users to evade sanctions and export controls.
3. Has your company taken any other actions to prevent re-export of your products to Russia?
A. Including the export to Russia, we take actions to confirm true end-users of products. To confirm true end-users of the products, we screen all goods and technologies intended for export against such factors as destination countries and regions as well as intended end-use and end-users. In some sensitive transactions, we obtain from customers notes of confirmation stating that they will not reexport our products in violation of any applicable export control laws and regulations.