Supplier questions checklist

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Ownership

• ☐ Who owns you, all the way to the top? Can you share a current ownership chart?
• ☐ Does any single owner hold 25% or more? Do owners tied to a covered nation hold 40% or more together?
• ☐ Are any shares held through nominees, trusts or funds? Who votes them?
• ☐ Do any owners have ties to the government of China, Russia, Iran or North Korea, including regional or local government bodies?

Control

• ☐ Who has the right to appoint your directors and senior officers?
• ☐ Do any agreements give an outside party a say over what you make, how you make it, or where you buy?

Debt and money

• ☐ Who holds your debt, including loans from related companies? Is 15% or more held by entities tied to a covered nation?
• ☐ Has any lender taken a pledge over your shares or your subsidiaries' shares?
• ☐ Have you made payments under any contract that gives a foreign entity control over your operations?

Technology and supply

• ☐ Do you license your core technology from another company? From whom, and on what terms?
• ☐ Who supplies your key materials and components? Are any of them on US government restricted-party lists?
• ☐ Where is the product actually made, and which company in your group makes it?

Documents

• ☐ Will you provide a signed certification covering these points, and update it if anything changes?
• ☐ Can you share the supporting documents behind it (ownership chart, lender list, key licence terms)?

What to check yourself

A supplier's answers carry more weight when they match the public record. A buyer that knows, or has reason to know, a certification is wrong can't rely on it.

• ☐ Securities filings and annual reports: major shareholders, subsidiaries, related-party loans and licence agreements.
• ☐ Company registries in each country where the group operates.
• ☐ Official US restricted-party lists, for the supplier, its group, its owners and its officers.
• ☐ Filings by the supplier's investors and lenders, which sometimes describe the relationship from the other side.
• ☐ Keep a dated note of what you checked, where, and what you found.

Want this done for a specific supplier? See a sample report or email contact@batterypulse.co.

General information, not legal or tax advice. Your counsel and tax advisers decide how the rules apply. Current as of November 2026.