Email 27.01.2025:

The information that FAULHABER products have allegedly been delivered to Belarus first reached us through your research. We are surprised and concerned by the information because our company quickly and consequently broke off all business relations with Belarus and Russia on the day on which Russia invaded Ukraine – even before the sanctions were imposed and this became a legal requirement. Since then we have strictly ensured that we comply with all legal requirements. 

In response to your request, we immediately commenced internal investigations and looked into the matter. As of today, we can inform you that we have not delivered any motors to the companies you mention. The Chinese company listed in your email is not one of FAULHABER's business partners. There are therefore no business relations between Hebei Nanuo Alloy Material Co. and FAULHABER. We are pleased to answer your specific questions below:

1. No, we cannot confirm this. We do not know the companies mentioned in your email and there are no business relations between FAULHABER and the two companies mentioned.. Based on the information you provided, we immediately blocked the Chinese company in our systems so that business relations are excluded in this respect as a matter of principle.
   
   
2. We strictly adhere to the export regulations and sanctions that apply in Germany, the EU, Switzerland and the USA. In order to ensure that this is the case, we work with computerized export compliance software. This enables us to ensure that we are informed without undue delay of changes in export laws and sanctions regulations that apply to sanctioned companies, governments or countries. In addition, we contact the export authorities in Germany (BAFA) and Switzerland (SECO) on an ad hoc basis to ensure that we comply with laws and applicable regulations when delivering to sensitive markets. What is more, we point out to our customers in our terms and conditions of supply that export regulations and sanction regulations must be complied with.
3. No, we are not aware of any intermediaries or third-party companies involved in the supply chain that may pass our products on to sanctoned entities. If we were to discover that this were the case, we would terminate the business relations immediately. We have also established this in our published Code of Conduct. This is available at:  https://www.faulhaber.com/en/aboutus/company/compliance/
   
   
4. We strictly adhere to the applicable regulations and laws to determine and document the end use of products to the extent that this is required by law for specific markets or products. As soon as we have indications of possible misconduct, we look into these. We have set up a whistleblower system for reports of actual or suspected misconduct. If business partners were to act in violation of sanctions, we would terminate the business relations with these business partners without undue delay.
   
   
5. Following Russia's illegal invasion of Ukraine, we immediately stopped all direct and indirect sales to the Russian Federation and Belarus. We did this despite the fact that no sanctions had yet been imposed on these countries. Instead, we acted in line with our values and our inner convictions. We also accepted the financial disadvantages of doing so. We have a strict corporate policy with regard to Belarus and Russia. It is therefore very important for us to receive further information so that we can clarify the facts and conduct further investigations in an even more targeted manner

We would therefore be grateful if you could provide us with the following information as soon as possible for the purpose of our further investigations:

1. Which specific FAULHABER product is it that the Chinese company Hebei Nanuo Alloy Material Co. has allegedly supplied to the Belarusian company "Integral"?
2. Do you have any information on how the alleged FAULHABER product is used?
3. Unfortunately, we often see our trademark being used worldwide without authorization. Can you be sure beyond doubt that the motor mentioned in your email is not a counterfeit product, but actually a FAULHABER product?
4. Could you provide us with a product number so that we can check when the product was manufactured and distributed? Can it be ruled out that the product mentioned is a second-hand product, has been reconditioned or is a product from stocks that were built up before the sanctions against Belarus were imposed? Can it also be ruled out that the product originates from another appliance that was delivered to Belarus before the sanctions came into force, was then removed from that appliance and reused by the company "Integral"?

Should you have any queries, please do not hesitate to contact us at any time. [*] [*] [*]

Email 28.01.2025:

We deeply appreciate your work for independent journalism and your investigations to uncover misconduct and fake news.

In your article “Deadly chips. How Integral bypasses sanctions and helps Russia keep the war going”, published on January 28th, 2025, you mentioned FAULHABER as the manufacturer of 44 mini-electric motors. As stated in our statement, sent on January 27th, 2025 at 18:24, where we answered your questions, we informed you that we have not delivered any motors to the companies the article mentions. The Chinese company mentioned in your article is not one of FAULHABER's business partners. There are therefore no business relations between Hebei Nanuo Alloy Material Co. and FAULHABER.

We understand mistakes can happen in journalism, especially when issues are complex. Nevertheless, it is important that what is written is true. We would therefore kindly ask you to remove the reference to FAULHABER in the description of the allegedly delivered products from the article.

As of today, we have no clear evidence that the motors mentioned are original FAULHABER products. We are very interested in clarifying the facts and conducting further investigations whether and how such alleged deliveries could happen. It is in our own interest and therefore a joint goal of the BIC and FAULHABER to contribute to stopping deliveries of such goods to Belarus.

As already kindly requested in our yesterday´s email to you, we would be grateful if you could answer the following questions:

1. Which specific FAULHABER product is it that the Chinese company Hebei Nanuo Alloy Material Co. has allegedly supplied to the Belarusian company "Integral"?
2. Do you have any information on how the alleged FAULHABER product is used?
3. Unfortunately, we often see our trademark being used worldwide without authorization. Can you be sure beyond doubt that the motor mentioned in your email is not a counterfeit product, but actually a FAULHABER product?
4. Could you provide us with a product number so that we can check when the product was manufactured and distributed? Can it be ruled out that the product mentioned is a second-hand product, has been reconditioned or is a product from stocks that were built up before the sanctions against Belarus were imposed? Can it also be ruled out that the product originates from another appliance that was delivered to Belarus before the sanctions came into force, was then removed from that appliance and reused by the company “Integral”?

We kindly ask to answer our questions and to remove the reference to FAULHABER in the description of the allegedly delivered products until Thursday, January 30th, 2025. [*] [*]

Email 04.02.2025: Thank you very much for your email and the information as well as the documents that you provided to us.

We have thoroughly reviewed the official procurement documents and did comprehensive research regarding the products mentioned in the official procurement documents.

According to our previous statements and correspondence, we would like to clarify again: We have not delivered any motors to the companies that are mentioned in your article and in the official procurement documents. The Chinese company mentioned in your article and in the official procurement documents is not one of FAULHABER's business partners. There are therefore no business relations between Hebei Nanuo Alloy Material Co. and FAULHABER.

As also stated before, we have no evidence that the products listed in the official procurement documents are original FAULHABER products. The product numbers in the official procurement documents are partly wrong or incomplete. Furthermore, we cannot rule out the possibility that the products are counterfeit products. We frequently encounter counterfeit FAULHABER products in the market.

The products mentioned in the official procurement documents – according to the product numbers – indicate that these products were produced at least five to ten years ago – assumed that the products were original FAULHABER products. Products like these do not remain in stock long. That means the products would have been manufactured and distributed long before any sanctions in relation to Belarus came into force.

Taken this altogether, your statement that the alleged sale of mini-electric motors through FAULHABER is "another example of sanctions circumvention", is false, misleading and must be corrected without any delay.

We are very interested in clarifying the facts and conducting further investigations whether and how such alleged deliveries by third parties that do not have any relationship to FAULHABER could happen. It is in our own interest and therefore a joint goal of the BIC and FAULHABER to contribute to stopping deliveries of such goods to Belarus.

Therefore, we are pleased to answer your further questions below:

Can Faulhaber confirm or refute that the specified motor models were manufactured and shipped from its facilities?

We cannot confirm that these items listed in the official procurement documents were manufactured or shipped from our facilities. We confirm that FAULHABER consequently broke off all business relations with Belarus and Russia on the day on which Russia invaded the Ukraine; i.e., even before the sanctions were imposed and this became a legal requirement. FAULHABER strictly ensures that it complies with all legal requirements. We can also confirm that we have not delivered any motors to the companies mentioned in the article and in the official procurement documents. The Chinese company listed in the official procurement documents and in the article is not one of FAULHABER's business partners. There are therefore no business relations between Hebei Nanuo Alloy Material Co. and FAULHABER.

In addition, the part numbers are incomplete in reference to our products. The part numbers contain likely references to other companies, organizations, or part numbering codes such as “Orbitran”. An online research indicated that “Orbitran” could have been a manufacturer of scaling and weighing devices. However, we cannot identify these references with certainty. So, there is no evidence that the products listed in the official procurement documents were manufactured and shipped from FAULHABER´s facilities.

How does Faulhaber monitor its supply chain to prevent potential third-party resale to Belarus?

We strictly adhere to the export regulations and sanctions that apply in Germany, the EU, Switzerland and the USA. In order to ensure that this is the case, we work with computerized export compliance software. This enables us to ensure that we are informed without undue delay of changes in export laws and sanctions regulations that apply to sanctioned companies, governments or countries. In addition, we contact the export authorities in Germany (BAFA) and Switzerland (SECO) on an ad hoc basis to ensure that we comply with laws and applicable regulations when delivering to sensitive markets. What is more, we point out to our customers in our terms and conditions of supply that export regulations and sanction regulations must be complied with. If we were to discover that this were not the case, we would terminate the business relations immediately. We have also established this in our published Code of Conduct. This is available at. 

Please note, as a company we can only determine in a binding manner what our direct clients do with our products. For example, we determine and document the end use of products to the extent that this is required by law for specific markets or products. We are not in a position and do not have the power to monitor or prevent the clients of our clients – e.g. individuals or companies – from potentially removing parts from other devices and refurbishing or reselling them as new or exporting them illegally to sanctioned countries or entities. Having said that, such kind of behavior may qualify as criminal or an illegal breaking of international sanctions. We do not and would never tolerate or support these actions in any way.

Does Faulhaber consider it possible that these products were acquired via grey market channels or parallel imports?

If your reference to a “grey market” refers to the potential that our products may be removed from other products, refurbished, repurposed, or resold, or purchased as old stock from bankrupt or defunct companies and resold, or collected from private sales on websites such as ebay, Alibaba or other and resold, then the answer is: yes, that is well possible. However, as stated above, we cannot confirm that these are indeed FAULHABER products and, if so, we do not know whether and how these products have been shipped to Belarus.

We will be grateful if you inform us on the progress and results of your informal investigation.

Due to the fact that the part numbers are not our own and contain only partial references to our product codes, we are unable to perform any more research into this matter. If these products are indeed our products and have somehow been imported into Belarus without our knowledge or permission, the partial numbers seem to indicate that some of these products were produced at least five to ten years ago and may have been removed from other devices and resold and exported into Belarus. That means the products were produced much earlier than sanctions against Belarus were imposed.

Further research into the matter would only be possible after obtaining one or more of these products to verify their authenticity and a closer estimation of where and when they were produced or sold. We will not engage with Belarus or any individual or company in Belarus in order to request more information.

Since the facts above clearly provide that there has been no circumvention of sanctions by FAULHABER, we ask you to remove the reference to FAULHABER from your article. For the same reason, the following sentence needs to be corrected: “Another example of sanctions circumvention that BIC journalists discovered was the purchase of mini-electric motors manufactured by the German company Faulhaber Group.“ The sentence is false and misleading. It indicates there would be a direct connection between FAULHABER and sanction circumventions which does not exist.

As a result of your article, other media outlets such as The Moscow Times and United24 Media have put FAULHABER in an even more direct context regarding sanction circumventions by referring to your article. These false allegations are directly caused by your misleading article and we must now ensure that other media do not adopt these false claims as well, thereby deepening the legal infringement on our company.

Finally, we ask you to publish this letter, i.e. our official position regarding the allegation, as part of your article.

Should you have any questions, please do not hesitate to contact us at any time. [*] [*] [*]

In your article by Sviatlana Yatskova entitled Deadly chips. How Integral bypasses sanctions and helps Russia keep the war going, published on your website in the Investigations section on 28 January 2025, Carl Zeiss AG is cited as being the supplier of Axiotron microscopes for chip quality control to Belarusian firm Integral. A corresponding device can be seen in the referenced TV report about Integral. Your article goes on to say “that Integral makes products using Western equipment. The operation of this equipment is dependent on a constant supply of Western raw materials and components, without which its use is impossible. Sanctions prohibit the sale of Western raw materials and components to Belarus.”

Thus, your report suggests that ZEISS supplies Integral with the latest microscope technology and evades sanctions.

In fact, ZEISS does not have any supply relationships with Integral. The production of the Axiotron microscope shown in the TV report ceased in 1997. ZEISS sold off its business in microscopes suitable for wafer inspection in 2003. The existence of a device from the 1990s in a Belarusian company in 2024 does not justify an allegation of non-compliance with sanctions that have been imposed in recent years.

ZEISS fully complies with all sanctions imposed on Russia and Belarus by the European Union, the United Kingdom and the US. Immediately after the outbreak of the war in Ukraine, the strategic business unit Research Microscopy Solutions (RMS) discontinued all deliveries to Russia and Belarus. ZEISS has put contractual arrangements in place requiring its business partners to comply with these sanctions and regularly reviews them.

We would kindly ask you to take corrective action as per your own editorial policy published on your website. By the same token, we would have appreciated an offer to comment prior to publication.