To minimize the risk that third-party intermediaries enter into transactions, including transactions that involved the onward sale or distribution of ENVEA products, all engagements with third parties should comply with the ENVEA Third-Party Diligence Policy, and contracts with third-party intermediaries should include language prohibiting violations of Trade Compliance Laws (as per the Third-Party Due Diligence Policy).
For sales made on a purchase order or similar basis, the following language should be included in the invoice and any order confirmation communications:
“By accepting these goods, you agree not to give, sell, or otherwise distribute these products, directly or indirectly, (1) to any party located, organized under the laws of, or ordinarily resident in a country or territory subject to comprehensive OFAC sanctions, (2) to any party located, organized under the laws of, or ordinarily resident in a country or territory subject to partial or industry-based OFAC sanctions, or (3) to any individual, entity, or other end user subject to sanctions imposed by the United States, European Union or its Member States, or United Kingdom.”
Any deviations to the language contained in this Policy or the standard templates for third-party engagements must be pre-approved by the Designated Officer. Specifically, the removal of Russia, Myanmar, Venezuela, and/or Belarus from the standard purchase order language is only permissible with pre-approval from the Designated Officer.