Prevents the company from dealing with sanctioned parties or in restricted goods and technology.
Scope
This policy applies to all business relationships, payments and transfers of goods, software or technical data entered into by the company.
Position
The company does not do business with, or for the benefit of, any person, entity, vessel or government subject to sanctions administered by the United Nations, the United States Office of Foreign Assets Control, the United Kingdom, the European Union, Australia or Hong Kong.
Screening
Before a counterparty is onboarded, and before any payment is made to a new payee, the counterparty and its known owners are screened against the consolidated sanctions lists. The screening result and its date are recorded.
Ongoing obligation
Counterparties are re-screened on renewal, on any change of ownership that comes to the company's attention, and before any material payment. A positive or possible match stops the transaction until a director has reviewed it.
Equipment and technology
Solar modules, inverters and battery energy storage equipment are procured only from suppliers whose supply chains the company has examined. Supply chain provenance is assessed under the Modern Slavery and Human Rights Policy as well as this policy.
Payments
The company does not route payments through jurisdictions or entities designed to obscure the identity of the ultimate recipient.
Escalation
Any question about whether a transaction is permitted is escalated to a director before the transaction proceeds. Where the position remains unclear, external legal advice is taken.
Reporting a concern
Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.