The year was dominated by revised restrictive measures and changed conditions

In the spring of 2022, the EU decided to impose restrictive measures on Russia because of the war in Ukraine. More restrictive measures were added several times during the year. The most significant restrictive measures affecting public procurement were imposed by Council Regulations on persons and sectors.

Personal restrictive measures involve the freezing of the assets of private persons and corporations, as well as travel restrictions. Among other measures, the Council Regulation on restrictive measures on individuals prohibits the payment of financial benefits to persons subject to the restrictions. Meanwhile, the restrictive measures on sectors aim to restrict the operations of different sectors of the Russian economy, and these measures include export and import bans and restrictions on the financial sector.

Public procurement suspended

The April 2022 amendment to the Regulation on sectoral restrictive measures also prohibited the award and continued execution of public contracts and concessions if the contracting party had Russian ownership or if there were Russian subcontractors or suppliers in the supply chain.

Following the entry into force of the Regulation on sectoral restrictive measures, Hansel terminated a framework agreement on marine fuels with Teboil on 9 October 2022 and reopened the joint procurement to competition for 2022–2024. The purchase of liquid fuels from Teboil service stations was also discontinued.

In joint procurement, we carried out audits on behalf of our customers

Due to the restrictive measures, Hansel commissioned studies from external service providers in the spring and autumn on whether any beneficiaries or responsible persons of the contractual suppliers of the joint procurement contracts were subject to the restrictive measures. Contractual suppliers were also asked to provide an assurance that there was no Russian ownership in the contractual supplier companies or their subcontractors or suppliers, and that they were not subject to any other restrictive measures.

“We aim to make things easier for our customers by handling the auditing of restrictive measures in a centralised manner.”

A phase for screening restrictive measures was also added to the tendering process for joint procurement. In addition, contractual terms on restrictive measures were drafted for the new joint procurement contracts and templates intended for customers. Restrictive measures were also discussed at several customer events and in our communications in general.

The restrictive measures are designed to put pressure on Russia to end the war, so it is important that they are respected. However, the measures are complex, and their application requires plenty of effort. We aim to make things easier for our customers by handling the auditing of restrictive measures related to joint procurement contracts in a centralised manner.


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