Compliance

Why this matters in this trade

Fertilizers and chemical raw materials sit inside export control, sanctions and security frameworks that change frequently. Several grades in our catalogue are dual-use in practice, and one is supplied only against verified end use.

Compliance is therefore part of how an order is taken, not a policy document filed away from operations.

Counterparty screening (KYC)

• Identity, registration and ownership of every counterparty are established before contracting.
• Counterparties, their beneficial owners and the destination are screened against applicable sanctions and export control designations.
• Screening is repeated during a relationship, not performed once — listings and ownership both change.
• For restricted grades we additionally establish the stated end use and verify the buyer's licences.
• Where a check fails, we decline the business. Where we may lawfully explain why, we do.

Sanctions and export control

We comply with the sanctions and export control regimes of the European Union and of every jurisdiction on the route of a shipment. We do not structure transactions to avoid them, and we do not accept instructions to disguise an end user, an end use or a destination.

Anti-bribery

We do not offer, promise, give, request or accept any improper advantage to obtain or retain business, and we do not make facilitation payments. The same standard applies to agents and intermediaries acting for us; an agent who requests such a payment ceases to act for us.

Reporting a concern

Concerns about conduct, compliance or safety can be reported to office@privatut.com, marked for the attention of management.

[Dedicated reporting channel — to be established. Under Directive (EU) 2019/1937 and the Hungarian implementing act, a company of the relevant size must provide an internal reporting channel with defined acknowledgement and feedback deadlines and protection against retaliation. Confirm applicability with counsel and publish the channel here.]

Status of this document

This document is a draft prepared for legal review. It has not been adopted and must be checked and approved by qualified counsel before the site goes live.