Export Control and Sanctions Policy

Principles

We are committed to complying with the strategic export control and sanctions laws, regulations and procedures of all countries where we operate.
Non-compliance with these legal requirements is a principal risk for the Company and can result in reputational damage, financial penalties and loss of business.

understand export control involves the physical transfer of goods, software and technology, the electronic transfer of technology and the provision of technical assistance and maintenance services for our products;
consult with dedicated specialists to help manage export control and sanctions awareness and compliance;
incorporate export control and sanctions requirements into other business procedures to ensure that compliance is integrated into the way we operate;
monitor suspicious enquiries from those attempting to obtain items on behalf of sanctioned parties;
use online screening and compliance tools (as detailed further in our more detailed guidance documents); and
read the introduction to our Code and Group Policies to understand to whom they apply and the consequences for breaching them.

involve their export control and sanctions specialists at all stages of business activity including strategy, product sourcing, contracting offset, "off-shoring", technology licensing and the delivery of hardware and its associated documentation, changes to IT infrastructure and IT tools, cloud computing strategies, R&D projects, M&A, and integration to ensure that the export control or sanctions implications of a decision are clearly understood from the outset; and
ensure that their team utilise online screening and compliance tools correctly and to maximum effect.