Sanctions Policy


Summary of Sanctions Policy

Incitec Pivot has adopted a Sanctions Policy, which outlines the expected standards of conduct relevant to compliance with Australian and international sanctions laws when engaging in international trade.

Incitec Pivot strictly prohibits the making of any payment or engagement in any transaction that is in breach of any law or regulatory requirement (a Sanctions Law) 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 Incitec Pivot does business, or which otherwise apply to Incitec Pivot directors, officers and employees. Incitec Pivot 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 Incitec Pivot to engage in any conduct that is prohibited by a Sanctions Law; and

  • any measures intended to circumvent prohibitions imposed under a Sanctions Law.

Incitec Pivot 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 all directors, officers and employees of Incitec Pivot and each subsidiary, partnership, venture and business association, including distributors and agents and other contractors that are effectively controlled by Incitec Pivot or act on its behalf (either directly or indirectly). The policy applies where these persons or entities engage in any international trade on behalf of Incitec Pivot.

The policy outlines a reporting process for possible instances of improper practices. In line with its Group Whistleblower Protection Policy, Incitec Pivot 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.