Export & Sanctions Policy

Applies to: TerraAqua products, software, technology, cloud services, support and international transactions

1. Purpose

This policy explains TerraAqua's approach to export controls, trade sanctions, financial sanctions and restrictions affecting the sale, supply, transfer, support or use of products, software, technology and services.

2. Compliance

TerraAqua will not knowingly supply a product or service where doing so would breach applicable United Kingdom export-control, trade-sanctions, financial-sanctions, customs or other trade laws.

3. Scope

This policy applies to:

• physical products and components;
• software, firmware and technical information;
• cloud, support and professional services;
• direct and indirect sales;
• customers, distributors, resellers and intermediaries; and
• exports, re-exports, transfers and making goods or technology available.

4. Restricted destinations and persons

TerraAqua may refuse, suspend or cancel a transaction involving a destination, person, entity, vessel, bank or other party subject to applicable restrictions or where there is a material risk of unlawful diversion.

5. Screening

TerraAqua may screen customers, beneficial owners, payment parties, delivery destinations and intermediaries against applicable sanctions and restricted-party information.

Screening may occur before acceptance, dispatch, account activation, payment, support, software access or renewal.

6. Customer information

Customers must provide accurate information reasonably requested for compliance, including:

• identity and contact details;
• delivery and end-user details;
• ownership or control information;
• intended destination and end use;
• intermediaries and freight arrangements; and
• licences, authorisations or declarations.

7. End use

Products and services must not be used, supplied or diverted for a prohibited end use. Customers must not use TerraAqua products in connection with weapons, unlawful surveillance, prohibited military activity or another restricted purpose where applicable law forbids the transaction or use.

8. No diversion

A customer, reseller or distributor must not sell, export, re-export, transfer or otherwise make a TerraAqua product or related technology available to a restricted destination or party, directly or indirectly, in breach of applicable law.

9. Licences and exceptions

Where a transaction requires an export or sanctions licence, exception or authorisation, TerraAqua may delay supply until the required approval has been obtained and verified.

Neither an application nor an apparent exception guarantees that TerraAqua will proceed with a transaction.

10. Software and remote services

Export and sanctions restrictions may apply to software downloads, firmware, encryption, technical support, remote access, cloud services, updates and technical data as well as physical goods.

11. Order refusal or cancellation

TerraAqua may refuse, hold, suspend or cancel an order or service where:

• required compliance information is not supplied;
• a party appears on an applicable restricted list;
• payment or delivery routing creates a sanctions concern;
• there is a credible diversion or prohibited-end-use risk;
• an authorisation is required but unavailable; or
• proceeding may breach law or expose TerraAqua or a service provider to legal risk.

Any refund will be handled lawfully, taking account of restrictions that may affect the return of funds.

12. Delivery and customs

The customer is responsible for import permits, local registration, customs declarations and destination-country requirements unless TerraAqua expressly agrees otherwise.

13. Resellers and distributors

Resellers and distributors must maintain proportionate compliance controls, avoid circumvention, keep appropriate records and pass relevant restrictions to downstream customers where required.

14. Record keeping

TerraAqua may retain transaction, screening, end-use, licence, shipping and compliance records for the period required by law or reasonably needed to demonstrate compliance.

15. Reporting concerns

Customers and partners must promptly notify TerraAqua if they become aware of a sanctions issue, licence condition, restricted party, diversion risk or inaccurate information affecting a transaction.

16. Cooperation

TerraAqua may cooperate with competent authorities, payment providers, carriers and professional advisers and may disclose relevant information where legally required or reasonably necessary for compliance.

17. Changes in restrictions

Sanctions and export controls can change rapidly. A transaction that was previously permitted may later become restricted. TerraAqua may change delivery, access or support arrangements to comply with new legal requirements.

18. Customer responsibility

Customers are responsible for their own compliance after receiving a product or service, including re-export, transfer, end use, local import controls and onward supply.

19. No legal advice

This policy is general information and does not constitute export-control or sanctions legal advice. Customers should obtain specialist advice for their own activities where necessary.

20. Contact

Trade-compliance enquiries may be sent to info@terra-aqua.co.uk.

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