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.
The export control system is operated in accordance with the internal rules for export control,including classification, confirmation of intended use, transaction screening, and shipment control.
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.
Our company examines the appropriateness of transactions under the export control system described above, including whether or not there is a possibility of circumventing export controls to Russia.
Has your company taken any other actions to prevent re-export of your products to Russia?
Our export control system is described above.