As we informed our readers already, the activities of the so called “Post of Crimea” included, asminimum since 2015, the commercial agreements with “Avon Beauty Products Company”, registered in Moscow. This company is owned by the Netherland’s company “Avon Netherlands Holdings II B.V.”,located and registered at Amsterdam. The common commercial activities of the “Avon BeautyProducts Company”, “Avon Netherlands Holdings II B.V.” and “New Avon LLC” (New York, USA)regarding the Crimea are the direct, systematic and massive violation of the sanctions regimes, established by the European Union. So in August 2021 our Association sent official submissions, describing those facts, to the governing institutions of the European Union and United States with mandate in areas of external relations and sanctions policy, where asked them to react, in the framework of their mandates, on the abovementioned brutal violation of the sanction policy by “Avon” companies united in common corporation and to inform our Association on the achieved results of their activities.

Later we got an answer from the European Commission’s Directorate-General for Financial Stability, Financial Services and Capital Market Union dated 22 September 2021 FISMA.E.5/MK/6539296 regarding our submission. In this document Directorate-General points that it is allegedly not evident that an EU operator has breached its obligations by exporting prohibited goods from the European Union to the Crimea. So we addressed again to the European Commission and pointed its attention to the fact of the essential financial support the “Post of Crimea” by “Avon” companies. As the agreements between “Avon” and “Post of Crimea” are the direct form of financial support by “Avon” companies, the Russian illegal “governing infrastructure” in the Crimea in large volumes, which allows the “Post of Crimea” to get large commercial income.

We stressed in our address that regarding the article 2a of the Council Regulation (EU) 692/2014 it shall be prohibited for EU states’ companies to grant or be part of any arrangement to grant any loanor credit or otherwise provide financing, including equity capital, to an “entity” in Crimea or Sevastopol, or for the documented purpose of financing such “entity”. This Regulation also bans the creation any “joint venture” in Crimea or Sevastopol or with an “entity” in Crimea or Sevastopol, and the provision of investment services directly related to the activities referred to such issues. More, article 4 of that Regulation 692/2014 pointed that it shall be prohibited to participate, knowingly and intentionally, including indirectly, in activities the object or effect of which is to circumvent the
prohibitions laid down in this Regulation.

And on 11th of November we got additional communication from the above-pointed European
Commission’s Directorate-General stating that “in order to ensure that all possible angles are taken
into account”, European Union had forwarded our Association’s complaint regarding violation of the
sanction regime by “Avon” companies, to the Netherlands’ national competent authorities for further
investigation. So the research of this issue by the competent authorities is going on now and we will
inform our readers on any results of those proceedings on “Avon” network companies’ illegal activities in the Crimea.

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