Export Control & Trade Compliance Statement

1. Our commitment

We comply with applicable export control, economic sanctions and trade compliance laws, including but not limited to the PRC Export Control Law, Foreign Trade Law and Customs Law, as well as United Nations Security Council resolutions, the US Export Administration Regulations (EAR) and the EU dual-use Regulation (EU 2021/821) where they apply to a transaction.

2. Screening and due diligence

• Screening customer names, consignees, end users, end uses, destination countries or regions and shipping routes against applicable sanctions, entity and restricted-party lists;
• Enhanced review of transactions involving sensitive destinations, multiple intermediaries or unusual payment routes;
• Retaining screening records and transaction files for inspection by regulators.

3. Transactions we will not undertake

• Where the destination or end use is a comprehensively sanctioned country or region;
• Where the counterparty appears on a sanctions, entity or other restricted-party list;
• Where the use relates to weapons of mass destruction or their delivery systems, military end use, or unauthorised re-export;
• Where the customer declines to provide end-user and end-use information;
• Where the consignee or end user cannot be identified.

4. Controlled items and licences

Some fluorochemicals (for example the fluorinated monomers and gases HFP and C-318) may constitute hazardous chemicals, controlled chemicals or dual-use items whose export requires a licence or notification. We establish whether an export licence is needed before quoting or accepting an order, and do not ship before any required licence is obtained.

5. End-user and end-use undertakings

For controlled items we may ask the customer to sign an end-user and end-use undertaking confirming that the products will not be used for prohibited purposes, will not be resold or transferred to restricted parties or destinations, and that the customer will cooperate with reasonable compliance checks.

6. Allocation of responsibility

Customers are responsible for ensuring that their purchase, import, use and re-export comply with the laws of their own and the destination country. We reserve the right to refuse, suspend or terminate any order in order to meet our compliance obligations, without liability to the customer for doing so.