COTT Electronics Sp. z o.o. International Sanctions Compliance Policy

Policy Overview

COTT Electronics Sp. z o.o. (hereafter referred to as "the Company") is committed to operating its global business activities within the framework of international law, EU regulations, and Polish law, adhering strictly to all sanctions imposed by the European Union, Poland, and relevant international bodies, including those related to the regions of Abkhazia and South Ossetia. This policy delineates the Company’s structured approach to ensuring comprehensive compliance with these sanctions regimes, demonstrating our unwavering commitment to uphold ethical business practices and legal compliance across all jurisdictions in which we operate.

Scope and Application

This policy is universally applicable to all employees, affiliates, subsidiaries, contractors, and third-party agents of COTT Electronics Sp. z o.o. It encompasses all business dealings, including procurement, sales, distribution, service provision, financial transactions, and any other form of commercial engagement that the Company undertakes, particularly in the hospitality sector where we provide IPTV services.

Sanctions Compliance

The Company acknowledges the complexity of international sanctions laws, which are subject to change based on geopolitical developments and legislative amendments. As such, COTT Electronics Sp. z o.o. pledges to:

  1. Adhere to Sanctions Lists: Comply with all sanctions lists published by the European Union, Poland, and relevant international bodies (e.g., UN Security Council), ensuring no business dealings contravene the restrictions placed on individuals, entities, or regions, including specific measures related to Abkhazia and South Ossetia.
  2. Prohibited Activities: Strictly prohibit any transactions, direct or indirect, that may breach the sanctions imposed by the EU, Poland, or international bodies, ensuring no part of our business operations supports sanctioned activities or contributes to the violation of sanctions laws, in line with Council Regulation (EU) No 833/2014 and Polish law (Ustawa o szczególnych rozwiązaniach w zakresie przeciwdziałania wspieraniu agresji na Ukrainę).

Due Diligence and Monitoring

COTT Electronics Sp. z o.o. commits to rigorous due diligence processes to identify and mitigate risks associated with sanctions compliance. This includes:

  • Conducting comprehensive background checks on all business partners, suppliers, customers, and third parties to ensure they are not subject to, or indirectly involved with, any sanctioned activities or entities, using tools compliant with EU and Polish regulations.
  • Continuous monitoring of transactions for potential sanctions violations, employing advanced compliance software and methodologies where applicable, to detect and prevent breaches.
  • Immediate escalation of any potential sanctions breach to the Company’s dedicated compliance officer or legal department for further investigation and resolution, ensuring compliance with EU and Polish reporting obligations.

Employee Training and Awareness

Understanding the critical role of our employees in maintaining sanctions compliance, the Company will:

  • Provide regular, mandatory training sessions on sanctions laws and regulations, tailored to the specific roles and responsibilities within the Company, covering EU, Polish, and international sanctions frameworks.
  • Cultivate a culture of compliance and ethical conduct, encouraging employees to report any suspected breaches of sanctions without fear of retaliation, in line with Polish whistleblower protections (Ustawa o ochronie sygnalistów, implementing EU Directive 2019/1937).

Reporting and Violation Management

In the event of a suspected violation of this policy or applicable sanctions laws, employees are required to report their concerns immediately through established reporting channels. The Company guarantees a thorough investigation of all reports and will take appropriate corrective actions, which may include:

  • Disciplinary measures for employees involved in violations.
  • Adjustments to business practices to prevent future breaches.
  • Legal action or reporting to authorities, such as the Polish Internal Security Agency (ABW) or EU bodies, if required by law.

Review and Amendments

This policy will be reviewed annually to ensure its relevance and effectiveness, with revisions made in response to changes in sanctions laws, regulatory guidance, or the Company’s operational landscape. Updates to this policy will be communicated promptly to all relevant stakeholders, in compliance with EU transparency requirements.

Sanctioned Countries

As of the most recent updates, countries sanctioned by Poland (in alignment with EU sanctions) include, but are not limited to:

  • Afghanistan
  • Belarus
  • Central African Republic
  • Democratic People’s Republic of Korea (North Korea)
  • Democratic Republic of the Congo
  • Iran
  • Iraq
  • Lebanon
  • Libya
  • Mali
  • Myanmar
  • Russia
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Venezuela
  • Yemen

For the most current and comprehensive list of sanctioned countries, entities, and individuals, please refer directly to the official resources provided by the EU (EU Sanctions Map) and the Polish government (Polish Ministry of Interior and Administration). Sanctions are dynamic and may change in response to geopolitical developments, so it’s crucial to consult these resources regularly for the latest information.

Conclusion

COTT Electronics Sp. z o.o.’s International Sanctions Compliance Policy underscores our resolve to conduct business responsibly, ethically, and in full compliance with all sanctions laws. Through steadfast adherence to this policy, we aim to protect our operations from legal risks and contribute to global peace and security efforts.

Contact Us

For inquiries about this Sanctions Compliance Policy, please contact us at:
COTT Electronics Sp. z o.o.
Mikołaja Kopernika 30 / 11A, 00-336 Warszawa, Polska
Email: [email protected]
Phone: +48 22 1530505