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, including 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 (for example, 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 and dual-use measures where relevant (for example, the 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 or sanctioned territories or parties. Without a licence or legal authorisation, our Items must not be supplied to, shipped to, or used in embargoed regions (including Cuba, Iran, North Korea, Syria, Crimea/Sevastopol, Donetsk, and Luhansk) or with any territory, person, or entity 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, prohibited military end-uses or end-users (including Russia-related controls), unlawful surveillance, cyber intrusion, or human-rights abuses.
3.3 Screening. We screen counterparties against relevant denied and restricted party lists and apply risk-based due diligence, including red-flag escalation.

4.0 Customer and Reseller Obligations

4.1 You must comply with this policy and with all applicable export, re-export, sanctions, and customs laws.
4.2 You must not export, re-export, transfer, sell, lease, loan, consign, or otherwise divert GeiG Items contrary to law or this policy.
4.3 You must provide truthful and complete information about 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 You must notify us immediately if you know or suspect a violation, diversion, or restricted end-use.
4.5 Flow-down. If you resell, distribute, or integrate our Items, you must flow down obligations equivalent to Sections 3.0–7.0 in your contracts and operational controls.

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 and software. Certain software or firmware may be subject to encryption controls. Until Schedule A is published, you must not assume “NLR/No Licence Required.” Ask us if you need classification support.
5.3 Licensing. If a licence is required, shipping or access (including downloads or cloud activation) must not occur until a licence is granted and any 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 constitute 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 (including setup, troubleshooting, or remote support) is also controlled and may be withheld if a restriction applies.

7.0 Logistics, Returns, and Trans-shipments

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

8.0 Screening and Red Flags

8.1 Red flags may include mismatched addresses, unusual payment routes, refusal to disclose end-use, requests for atypical quantities or specifications, or insistence on routing through third countries.
8.2 If a red flag appears, we may pause fulfilment, request more information, apply additional checks, or cancel the transaction.

9.0 Record-Keeping and Audit

9.1 You must keep export-related records (orders, invoices, licences, end-use/end-user statements, shipping documents, and screening logs) for at least 5 years from the transaction date, or longer where the law requires.
9.2 GeiG may request copies to evidence compliance and 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 or export-control risk, missing information, or a licensing requirement.
11.2 Breach of this policy may result in account suspension or termination, contract cancellation, and reporting to authorities where required or appropriate.

12.0 Reporting Issues

12.1 Suspected violations or concerns may be reported to support@geig.co.uk or via our 24/7 web chat.
12.2 We will review reports in good faith and may request further details to assess risk and compliance requirements.

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

14.1 Items: GeiG hardware, software, firmware, cloud services, technology or 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 or US origin, or with controlled content, from one foreign country to another.
14.4 End-use/end-user: the intended application and the person or entity ultimately using the Item.
14.5 Denied or 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): [To be published].
15.3 The latest version of this policy, and any schedules and updates, are published on the Site and the posted version controls.

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