GEIG – EXPORT & TRADE COMPLIANCE POLICY (v1.0)
Effective from: 01/08/2025

1.0 Purpose and Scope
1.1 This policy sets the rules for exporting, re-exporting, transferring, brokering, or otherwise making available GeiG products, software, technology, and related services (“Items”).
1.2 It applies to everyone who deals with our Items: customers, resellers, distributors, logistics partners, and GeiG staff.
1.3 This policy sits alongside our Terms of Sale (Business and Consumer), Hardware Warranty Policy, Returns & Warranty Policy, Privacy Policy, Cookie Policy, Website Terms of Use, and Security & Vulnerability Disclosure Policy.

2.0 Laws and Regimes We Follow
2.1 GeiG complies with UK export control and sanctions laws, including the Export Control Act 2002, Export Control Order 2008, Sanctions and Anti-Money Laundering Act 2018, UK OFSI sanctions, and the UK Strategic Export Control Lists (UK Military, Dual-Use, and Miscellaneous Lists).
2.2 We observe applicable US laws where they reach our Items or transactions (e.g., EAR 15 CFR 730–774 for re-exports and de minimis/foreign direct product rules; OFAC sanctions).
2.3 We take into account EU and UN sanctions/dual-use measures where relevant (e.g., EU Dual-Use Regulation and consolidated sanctions lists).
2.4 If regimes conflict, the stricter control applies.

3.0 Core Commitments
3.1 No business with embargoed/sanctioned territories or parties. Without a licence or legal authorisation, our Items must not be supplied to, shipped to, or used in: currently embargoed regions (e.g., Cuba, Iran, North Korea, Syria, Crimea/Sevastopol, Donetsk, Luhansk) and any other territory or party listed by UK OFSI, US OFAC, the EU, or the UN.
3.2 No restricted end-uses. Our Items must not be used for weapons of mass destruction, military end-uses/end-users where prohibited (including Russia-related controls), unlawful surveillance, cyber-intrusion, or human-rights abuses.
3.3 Screening. We screen counterparties against relevant denied/restricted party lists and apply risk-based due diligence, including “red-flag” escalation.

4.0 Customer & Reseller Obligations
4.1 You must comply with this policy and with all applicable export, re-export, sanctions, and customs laws.
4.2 Do not export, re-export, transfer, sell, lease, loan, consign, or otherwise divert GeiG Items contrary to law or this policy.
4.3 Provide truthful, complete information on end-use, end-user, and ultimate destination when requested, and promptly supply any End-Use/End-User Statements or export licences we require.
4.4 Notify us immediately if you know or suspect a violation, diversion, or restricted end-use.
4.5 Flow-down: if you resell or integrate our Items, you must flow down obligations equivalent to Sections 3–5 in your contracts.

5.0 Classification, Licensing, and Encryption
5.1 Classification. Some Items may be controlled under the UK Dual-Use List and/or the US EAR (ECCN). GeiG will publish model-specific classifications in Schedule A – Export Classifications when available.
5.2 Mass-market encryption/software. Certain software/firmware may be subject to encryption controls. Until Schedule A is published, do not assume “NLR/No Licence Required.” Ask us if you need classification.
5.3 Licensing. If a licence is required, shipping or access (including downloads or cloud activation) must not occur until licence grant and all conditions are met. We may decline or delay an order pending screening or licensing.

6.0 Cloud Services, Downloads, and Technical Assistance
6.1 Remote access, downloads, keys, updates, and cloud dashboards can be an “export” to the receiving location. Access must comply with this policy and applicable controls.
6.2 We may restrict access from sanctioned territories, IP ranges, or to sanctioned parties.
6.3 Technical assistance (setup, troubleshooting, remote support) is likewise controlled and may be withheld if a restriction applies.

7.0 Logistics, Returns, and Trans-shipments
7.1 Shipping documents must be accurate: correct HS codes, valuation, origin, and any licence references.
7.2 Trans-shipment via high-risk hubs and re-routing to conceal destination are prohibited.
7.3 Returns and cross-border RMAs must follow export laws and our instructions; do not ship Items back to us from sanctioned territories.
7.4 Lithium batteries and other hazardous materials must be shipped under applicable dangerous-goods rules (IATA/ICAO/ADR/IMDG).

8.0 Screening and Red Flags (Examples)
8.1 Mismatched addresses, unusual payment routes, refusal to disclose end-use, requests for atypical quantities/specs, or insistence on routing through third countries can be red flags.
8.2 If a red flag appears, we may pause, request more information, or cancel the transaction.

9.0 Record-Keeping and Audit
9.1 Keep export-related records (orders, invoices, licences, end-use/end-user statements, shipping docs, screening logs) for at least 5 years from the transaction or longer if the law requires.
9.2 GeiG may request copies to evidence compliance. We may audit resellers against this policy on reasonable notice.

10.0 Training and Governance
10.1 Relevant GeiG staff receive periodic export-control and sanctions training.
10.2 We review this policy at least annually and when laws materially change.
10.3 We maintain an internal escalation path to our compliance lead for licensing and sanctions decisions.

11.0 Enforcement and Consequences
11.1 We may refuse, suspend, or cancel orders or access where we believe there is a sanctions/export risk, missing information, or licensing requirement.
11.2 Breach of this policy may result in account suspension/termination, contract cancellation, and reporting to authorities where required.

12.0 Reporting Issues
12.1 Suspected violations or concerns can be reported to support@geig.co.uk (operated by Computerko Limited for GeiG) or via our 24/7 web chat.
12.2 We will review in good faith and may request further details.

13.0 Legal and Jurisdiction
13.1 This policy and any dispute are governed by the laws of England and Wales.
13.2 The courts of England and Wales have jurisdiction, without prejudice to mandatory venue rights that cannot be waived.
13.3 Nothing in this policy requires or permits conduct that would violate applicable law.

14.0 Definitions (Quick Reference)
14.1 Items: GeiG hardware, software, firmware, cloud services, technology/technical data, and related support.
14.2 Export: any shipment, transfer, download, disclosure, or access of Items across borders (including remote access).
14.3 Re-export: export of a non-UK item of UK/US origin or with controlled content from one foreign country to another.
14.4 End-use/End-user: the intended application and the person/entity ultimately using the Item.
14.5 Denied/Restricted party: a person or entity listed by sanctions or export-control authorities.

15.0 Schedules and Publication
15.1 Schedule A – Export Classifications (ECCN/Control Entries): [To be published].
15.2 Schedule B – Sanctioned Territories/Parties (working list): 
15.3 The latest version of this policy, and any schedules, controls.

End of Export & Trade Compliance Policy (v1.0)