We are committed to complying fully with all applicable anti-money laundering and terrorist financing laws throughout the world.
Money laundering is the process through which an individual or organisation seeks to make the proceeds of criminal activity appear legitimate. The term “money laundering” is also sometimes used to refer to the handling of any benefit that arises from acquisitive crimes, such as theft, fraud or tax evasion. Stora Enso strictly prohibits knowingly engaging in transactions that facilitate money laundering and terrorist financing or that otherwise result in the unlawful diversion of assets. We are committed to conducting business only with customers who are involved in legitimate business activities, with funds that are derived from legitimate sources.
Stora Enso’s employees play an integral role in helping the Company detect customer relationships and transactions that may involve money laundering and terrorist financing. Participating in such relationships and transactions could seriously jeopardise the Company‘s integrity and reputation.
Before entering into a supplier or customer relationship and throughout the supplier/customer relationship measures need to be taken and questions asked in order to identify any of the following events or activities, which may indicate that money laundering and/or terrorist financing is taking place:
You should not proceed with any relationship or transaction that you believe raises any money laundering concerns until those concerns have been investigated and addressed by Legal, and you have been given confirmation that you may proceed with the relationship or transaction.
For a variety of business reasons a supplier or customer might establish a legal entity in more than one country. There might be also proper business reasons for owning a company in a country, which offers beneficial tax treatments or where its administration is reluctant to exchange tax relevant information with other countries. For the purpose of this Policy, Stora Enso has listed certain particularly tax sensitive countries (“Tax Haven Country”) which can be found HERE, and will be changed from time to time. Engagement with a counter party domiciled in a Tax Haven Country is permitted only after a successful substance test. Payments to a bank account located in a Tax Haven Country are never permitted if the contracting party in question is not domiciled in the Tax Haven Country.
It is not forbidden to run an operation or a company in a Tax Haven Country, or supply or to buy goods or services from a counter party which is domiciled in a Tax Haven Country. However, as some companies use Tax Haven Countries for tax fraud, money laundering or other illegal schemes, there are increased risks for Stora Enso to be alleged to have supported or even collaborated in an illegal activity should we do business with these counter parties. In addition to the potential juridical consequences, an involvement in tax fraud, money laundering or similar might also lead to reputational damages for Stora Enso. To keep Stora Enso’s high ethical standards and to avoid any involvement in illegal activities, Stora Enso’s shall make business with a counter party (customer or supplier) in a Tax Haven Country only if the counter party runs business in such Tax Haven Country with a legitimate purpose and sufficient substance.
Process and instructions for the substance test are as following: