Sanctions Policy – Intershim BV Ridderkerk

Intershim BV conducts its business activities with the utmost care to ensure compliance with national and international laws and regulations.
Our sanctions policy outlines the measures we take to prevent direct or indirect dealings with individuals, companies, or countries subject to international sanctions.

We value transparency, integrity, and responsible entrepreneurship.

1. Purpose

The purpose of this policy is to prevent Intershim BV from directly or indirectly conducting business with countries, companies, or individuals that are subject to sanctions. This is required to comply with EU sanction regulations, OFAC rules (US), and the Dutch Sanctions Act 1977.


2. Scope

This policy applies to:

  • All customers, suppliers, and intermediaries of Intershim;
  • All export transactions, including resale and end users;
  • All employees involved in sales, purchasing, logistics, and administration.

3. Responsibilities

  • Management: ultimately responsible for compliance with sanction regulations.
  • Sales & Export staff: responsible for conducting checks on counterparties.
  • Compliance/responsible officer: monitors compliance and documents all checks performed.

4. Sanction Risks

Sanction risks may arise from:

  • Exports to or through countries listed on sanction lists;
  • Customers or end users appearing on sanction lists;
  • Products that may have a strategic or military application.

5. Procedure for High-Risk Counterparties

The following steps are mandatory when dealing with (potentially) high-risk counterparties:

  1. Sanction list check: Verify the company name, end user, and involved countries using official EU and OFAC sanction lists.
  2. Documentation: Store proof of the check in the customer file (e.g., screenshot of verification, completed form, or email confirmation).
  3. Assessment: In case of doubt, consult management or the compliance officer before delivery.
  4. Block: If a party appears on a sanction list → no delivery until the full investigation has been completed.

6. Recordkeeping and Monitoring

  • All checks must be recorded in the CRM system or the customer file.
  • Files for high-risk customers must be retained for a minimum of 5 years.

7. Consequences of Non-Compliance

Failure to comply with this policy may result in disciplinary measures and, for the company, in legal sanctions or fines.