Sanctions are measures imposed by governments and international bodies (such as the United Nations, the United States and the European Union) to restrict dealings with certain countries, entities and individuals.
Odfjell will maintain effective measures to ensure compliance with and awareness of our sanctions-related obligations. The responsibility for sanctions screening lays in the concerned units: Commercial, Finance, Legal & Insurance.
Odfjell is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists, and will therefore screen against sanctions lists in all jurisdictions in which we operate, including:
- the United States Government
- the United Nations Security Council
- the European Union
- the United Kingdom
- the Flag State
- the People’s Republic of China
- the respective governmental institutions and agencies of any of the foregoing, including without limitation, the Office of Foreign Assets Control (OFAC), the United States Department of State, and Her Majesty's Treasury (HMT)
Sanctions apply to individuals – not just companies – so EU and US nationals operating outside the EU/US must be aware of the specific Sanctions applicable to them in addition to those that apply to their employer.
Odfjell and our subsidiaries must also be aware of sanctions-related obligations in third-party agreements (such as lending and insurance agreements), and ensure that we do not breach the terms of such obligations, particularly where these extend beyond Odfjell’ own legal obligations (e.g. agreements between US banks and EU Odfjell entities).
Failure to comply with sanctions can lead to severe civil and criminal penalties, both for our business and individual employees, officers and directors, as well as significant reputational damage for Odfjell. Non-compliance with this policy is a serious matter that may lead to disciplinary action, up to and including dismissal. Violations of sanctions can also have legal consequences for individuals involved, including severe monetary fines and imprisonment. Employees shall report any suspected violations of this policy to their superior or the Compliance Officer according to Whistleblowing Policy.