Trade Compliance, Sanctions & Restricted Goods Policy

Executive Summary

Our Trade Compliance, Sanctions & Restricted Goods Policy protects Plutonia and our clients from illegal, restricted, sanctioned, or high-risk transactions. It defines what we will not handle and how we manage regulated goods responsibly.

International trade carries legal lines that must not be crossed — sanctioned parties, prohibited goods, and restricted items moved without proper documentation. Crossing them exposes buyers and intermediaries to severe legal and reputational consequences. This policy keeps Plutonia and its clients on the right side of those lines.

Where products are merely regulated rather than prohibited, we manage them responsibly — with the documentation, screening, and escalation that the category requires.

Policy Scope

This policy applies across the order chain Plutonia coordinates, including:

• Suppliers, manufacturers, and factories producing goods coordinated by Plutonia
• Subcontractors and second-tier production sites used by those suppliers
• Sourcing agents, trading companies, and intermediaries in the order chain
• Logistics partners, freight forwarders, and warehouse and consolidation providers
• Third-party inspection and testing partners engaged on a project basis
• Plutonia team members involved in sourcing, verification, and logistics coordination

Core Principles

• No dealings with sanctioned parties.
• No illegal or prohibited goods.
• No restricted goods without proper documentation.
• Escalate regulated products for proper handling.
• Reserve the right to refuse high-risk transactions.

What Plutonia Will Not Handle

• No sanctioned parties — no dealings with sanctioned individuals or entities
• No illegal goods of any kind
• No restricted goods without proper documentation
• No weapons, illegal drugs, counterfeit goods, or prohibited products

Regulated Products & Escalation

Many legitimate products are regulated rather than prohibited — for example certain chemicals, batteries, dual-use items, or controlled medical products. These are escalated for proper handling: confirming the documentation, licences, and destination-market requirements that apply before proceeding.

Screening, Buyer Responsibility & Refusal Rights

Where required, we screen suppliers and counterparties on a risk basis. The buyer holds responsibility for destination-market rules and end-use, while Plutonia reserves the right to refuse any transaction that appears illegal, sanctioned, or unacceptably high-risk.

Supplier Expectations

Suppliers engaged through the Plutonia network are expected to:

• Not offer illegal, prohibited, or sanctioned goods.
• Disclose regulated, restricted, or dual-use products honestly.
• Provide documentation and licences required for regulated goods.
• Submit to screening where required on a risk basis.
• Not attempt to disguise restricted or prohibited products.

Our Due Diligence Approach

Plutonia applies this policy in practice on a risk-based basis, through:

How This Helps International Buyers

Red Flags

On a risk basis, Plutonia watches for practical warning signs relevant to this policy:

• Counterparties that may be sanctioned or screened-listed
• Requests to ship prohibited or illegal goods
• Restricted or dual-use goods without documentation or licences
• Attempts to disguise the true nature of goods
• Unclear or evasive end-use or destination information
• Pressure to bypass screening or documentation

Corrective Action

Where risks or non-conformities are identified, Plutonia may take the following steps, proportionate to severity:

1. Request clarification and additional information from the supplier
2. Request supporting documentation, records, or evidence of compliance
3. Recommend a time-bound corrective action plan with defined milestones
4. Escalate the finding to the buyer where the order or project is affected
5. Increase verification intensity, including inspection where warranted
6. Suspend new orders pending remediation where risk is significant
7. Reject or remove the supplier where serious issues are not remediated
8. Record findings and actions where required for buyer or tender reporting

Reporting a Concern

Workers, suppliers, clients, logistics partners, and stakeholders may report concerns through Plutonia's grievance mechanism. Reports are treated confidentially, retaliation against good-faith reporters is prohibited, and concerns are reviewed on a risk basis.

Related Policies

Downloadable Resources

PDF documents are placeholders and will be made available here. Each policy can also be read in full online.

Frequently Asked Questions