Dyno Nobel strictly prohibits the making of any payment or engagement in any transaction that is in breach of any law or regulatory requirement relating to the implementation of sanctions against any country, individual or entity, that has been imposed by the United Nations or by any country with or in which Dyno Nobel does business, or which otherwise apply to Dyno Nobel directors, officers and employees (Sanctions Laws).
Dyno Nobel prohibits conduct that is in breach of Sanctions Laws. This includes:
- the providing or receiving of any payment, other benefit, good or service, directly or indirectly, to or from any individual or entity that is subject to a Sanctions Law;
- any activity in connection with a designated country, where that activity is prohibited by a Sanctions Law;
- encouraging, permitting or otherwise allowing any person or entity acting on behalf of Dyno Nobel to engage in any conduct that is prohibited by a Sanctions Law; and
- any measures intended to circumvent prohibitions imposed under a Sanctions Law.
Dyno Nobel also prohibits engaging or continuing to engage with a third party where it is expected or likely that the nature of the engagement may breach Sanctions Laws.
The policy provides that there must be appropriate due diligence in relation to third parties, transactions or activities that present a potential risk in relation to Sanctions Laws compliance. The policy sets out a process for conducting due diligence.
The policy applies to Dyno Nobel and each of its owned and controlled subsidiary, partnership and venture all directors, officers and employees of these entities and third parties act on its behalf (either directly or indirectly), including distributors and agents and other contractors. The policy applies where these persons or entities engage in any international trade on behalf of Dyno Nobel.
The policy outlines a reporting process for possible instances of improper practices. In line with its Group Whistleblower Protection Policy, Dyno Nobel will take all available steps to provide protection to persons who make such reports from any victimisation or detrimental action in reprisal for the making of a report.