Responsible Sourcing Policy

Version 1.0 · November 2026

Commitment

We buy and sell in many markets and want to know where what we move comes from. We do not trade goods that we know, or have reason to suspect, were produced in breach of human or labour rights, environmental rules or the law.

Human and labour rights

We do not tolerate forced labour, child labour, human trafficking or working conditions that violate people's dignity. We expect suppliers to comply with the fundamental conventions of the International Labour Organization and with local law. In the European Union, we take into account Regulation (EU) 2024/3015, which bans products made with forced labour and applies from 14 December 2027.

Environment and origin

  • We verify the origin of goods and the certificates required, especially for higher-risk products (timber, agricultural products, metals and minerals).
  • For covered products, we comply with, or require compliance with, where applicable, the European Union rules on deforestation (Regulation (EU) 2023/1115) and on minerals from conflict areas (Regulation (EU) 2017/821).
  • We do not trade protected species, or goods obtained in breach of CITES or of extraction licences.

Prohibited, restricted and counterfeit goods

We do not move goods that are prohibited, counterfeit or that infringe intellectual property rights. Dangerous, controlled or licensed goods are accepted only with the correct classification, documentation and authorisations, in line with our Sanctions and Trade Controls Policy.

How we check

  • We ask suppliers for information on origin, production and relevant certificates, according to the risk of the product and the country.
  • We include in contracts the obligations in this text and in the Partner Code of Ethics, and the right to request clarification and evidence.
  • We carry out checks proportionate to risk, reinforced when there are red flags, complaints or credible reports.

When there is a problem

If we identify a breach, we suspend the operation, ask the supplier to correct it within a reasonable period and, if it does not, or if the breach is serious, we end the relationship. We record the decision and, where the law requires, inform the authorities.

Raising a concern

Anyone can raise a concern about the origin of products or production conditions confidentially through the Whistleblowing Channel.