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Financial and trade sanctions

Sanctions take many forms and can have an impact on whole countries, specific sectors, designated entities or individuals. The sanctions most relevant to Drax relate to financial matters and trade, and Drax will always comply with all those that are applicable.

The sanctions that the UK, US, Canada, Japan, European Union (EU) or United Nations (UN) impose are the most relevant. However, colleagues should be aware of any other regimes that may apply to them due to their nationality or their location. Please refer to the Financial and Trade Sanctions policy and the Recusal policy.

Fair competition

We never enter into anti-competitive agreements, abuse our market position, or make improper use of commercially sensitive information. Examples of behaviour that could lead to penalties include (but are not limited to) entering into understandings or agreements to:

• Allocate products, territories, customers or employees
• Bid, not bid, or agree on the content of any proposed bid
• Fix, increase, decrease, stabilise, or standardise prices or production output or capacity - Fix, increase, decrease, stabilise, or standardise prices or production output or capacity

What you need to do:

• Not do business with certain companies, customers, distributors or suppliers
• Familiarise yourself with our suite of financial crime policies (see Resources section)
• Not solicit a competitor's customers, distributors, suppliers or employees
• Look out for any fraudulent or illegal activity and immediately report any suspicions to Group Business Ethics

What you need to do:

• Make sure that any corporate disclosures (i.e. external reporting) you're responsible for are accurate and verified
• Familiarise yourself with our Fair Competition policy and guide
• Leave any discussion (e.g. at a trade association meeting or social event) where others are engaging in improper discussions and ensure the reason for departure is noted. Merely being present at an inappropriate discussion can be enough for the competition authorities to infer involvement in an anti-competitive agreement
• Don't make any 'false representations' in statements or reports, or in any of your dealings on behalf of Drax
• Don't abuse a position in which you're expected to safeguard the financial interests of another party or individual
• Comply with all applicable tax laws, and don't knowingly facilitate others to commit tax evasion
• Refuse all attempts by a competitor, customer or supplier to have an improper discussion, and promptly report the situation to your line manager and to a member of Group Legal
• Don't be involved in any way with the concealment, transfer, arrangement, use or possession of criminal property
• Don't make formal or informal agreements with competitors that result in price fixing, bid rigging, market allocation or arrangements to limit supply
• Don't be involved in any way with the provision, use, possession or arrangement of funds or property that could be used to contribute to terrorist activity
• Don't share with competitors any commercially sensitive information relating to prices, ongoing bids, terms and conditions of sales, market share, costs or profit margins
• Be careful not to violate - or appear to violate - domestic and international sanctions in any commercial activities