Has your company put in place appropriate internal mechanisms and tools to carry out enhanced due diligence of your supply chains, intermediaries, customers and end-users to understand the risk of your products’ diversion to Russia? If yes, please provide details.

Alfa Laval Group has a Group Export Control and Trade Sanctions Policy ("the Policy") which establishes compliance requirements applicable to all Alfa Laval Group entities, such as requirement to follow all applicable Export Control and Trade Sanctions.

Does your company consider potential red flags that suggest the use of front companies that may hide the true end-users of your products and thereby evade sanctions and export controls? If yes, please provide details. (Potential red flags may include companies registered recently; companies based in Armenia, Belarus, Turkey, Kazakhstan, Kyrgyzstan, Uzbekistan or other countries helping Russia circumvent sanctions; companies making large orders of products within a short space of time; companies with obscure beneficial ownership structures, etc.)

As per our Policy, transactions must be reviewed for any red flags of potential non-compliance with export controls or sanctions, e.g., unusual shipping arrangements, payment terms, customer designations or shipping addresses. An essential part of our due diligence process is screening of customer and end-user. Such red flag assessments are in line with the published Best Practices overview from EU, US, UK authorities.

Has your company taken any other actions to prevent re-export of your products to Russia?

Since March 3, 2022, Alfa Laval Group has stopped accepting new orders to Russia or for use in Russia and implement specific measures to prevent re-export to Russia, such as collecting and verifying of end-user certificates