Our approach to embargoes and export control
Embargoes are restrictive measures unilaterally adopted by a State or international governmental organisation that impact international economic transactions and the freedom of movement of individual persons as a measure of sanction.
Embargo measures target States or criminal organisations, their citizens and members (individuals and legal entities), and are related to economic activity.
ENGIE's embargo policy defines the applicable internal Group rules for any matter involving countries, individuals, legal entities, or activities subject to an embargo. It details for the Group the general framework for embargo issues and the process for managing the relevant transactions, including for them export control for dual-use goods and services (i.e. those that may have both civil and military purposes) that are part of our projects and that may require export licenses.
Depending on the potential embargo risk according to the criteria of the ENGIE Embargo Policy, an embargo analysis will be carried out concerning the country, the stakeholders and activities considered under the project. If the latter reveals risks related to countries, persons or activities, it is then necessary to evaluate and build the best possible solution in accordance with the applicable sanctions measures (for example: add a strong ethical clause, provide for monitoring, limit or avoid commercial relations with sanctioned persons, add a strong ethical clause, use safety recommendations, etc.).