We recognize the importance to adhere and commit to all current and applicable sanctions and/or prohibitions imposed by all States and Supranational or International Governmental Organizations, including but not limited to, United Nations, the United States of America, the United Kingdom, the European Union as well as all other applicable laws in the countries where we operate.
We are committed to:
• Carry on business in accordance with high ethical standards. This includes adhering to the economic sanctions laws and regulations or prohibitions imposed by the United Nations, the United States of America, the United Kingdom, the European Union and the economic sanctions laws, regulations and prohibitions that apply to our operations in the other countries where we do business, including but not limited to the “Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related Communities” issued on 14 May 2020 and its further updates.
• Adhere to all other applicable laws in relation to trade controls, export controls, embargoes, or international boycotts, including but not limited to those in relation to the trading and transportation of cargoes emanating from, or destined to, blacklisted or sanctioned entities, sectors or products (collectively the “Sanctions Laws”).
• Apply this Policy to our operations globally, including all subsidiaries and legal entities worldwide owned or controlled by Island Oil (Holdings) Ltd.
• Ask all our employees read, understand, commit, and comply with this Policy.
• Have zero-tolerance approach to violations of this Policy or applicable sanctions regimes. If an employee fails to comply with this Policy or with its spirit, then they may be subject to disciplinary action that may include dismissal from employment.
• Not enter into any transaction which our employee’s know, suspect or could reasonably conclude, involves a sanctions compliance issue, without prior approval from the Group’s Compliance Working Group. If an employee is in any doubt over a potential sanctions issue, they should escalate the matter to the Compliance Working Group.
• Urge our employees whenever they become aware or they have any suspicion of any issue or practice that involves a violation or potential violation of this Policy to report this issue or practice as soon as possible to the Compliance Working Group.
This Policy, which is reviewed annually, is communicated within the Group and to the public.