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Sanctions Compliance Policy
DD Shipping Ltd., S.A. and its wholly owned subsidiaries (the “Company”) is committed to carrying on its business in accordance with the highest ethical standards. This includes complying with all applicable trade sanctions laws, rules and regulations (“Sanctions Laws”) in the jurisdictions in which it operates.
Policy Applicability
The Sanctions Compliance Policy shall be applied to all directors, officers, contractors and offshore and onshore employees of the Company.
Policy Statement on Sanctions
It is the Company’s policy to comply with all Sanctions Laws in its operations worldwide. To this end, the Company will comply with all Sanctions Laws applicable to its business activities.
Policy Enforcement
The Company’s board of directors has overall responsibility for ensuring this Policy complies with its legal and ethical obligations, and that all those under its control comply with it.The Fleet Director and Chief Legal Officer have primary and day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective.
Meaning of Sanctions
- Sanctions Laws enacted by governments (such as the government of the United States (“U.S.”), international organizations (such as the United Nations (“U.N.”) and supranational bodies (such as the European Union (“E.U.”)) to promote foreign policy and other objectives.
- Sanctions Laws are implemented largely by prohibiting companies and individuals from doing business with persons, entities, countries and governments that are the targets of the sanctions. Such restrictions can include:
- • export bans, import bans and prohibitions on the provision of certain specified services;
- • prohibiting certain commercial activities (such as joint ventures and other investment);
- • barring the transfer of funds to and from a sanctioned country;
- • targeted financial sanctions, which include freezing the assets of and prohibiting any dealings with a government, country, or territory, and designated entities and individuals;
- • travel bans; and
- • other financial restrictions.
Policy Violation Risks
Violations of Sanctions Laws may lead to significant monetary, reputational, commercial and legal consequences for the Company.
Employee Responsibility
All employees of the Company have the obligation to read and comply with this Policy, to understand and identify any red flags that may arise and to escalate potential compliance concerns relating to sanctions.
Non-Compliance
Any employee who violates this Policy may be subject to disciplinary action in addition to any other potential actions or penalties resulting from a breach.
Updates, Review and Ownership of this Policy
This Policy is subject to review and update from time to time.