Export Controls Compliance And Sanctions Policy

Policy 

It is the policy of DerbySoft and any of its personnel, including any regular employees, paid temporary employees, or contractors (collectively, “DerbySoft”) to require strict compliance with all laws and regulations concerning the export and re-export of our products and/or technical information. DerbySoft is committed to maintain high standards of business and professional conduct, and has developed a multi-layered, risk-based approach taking into consideration both the products and services offered to customers, and an understanding of the full range of export controls and economic sanctions measures, whether involving countries or jurisdictions, activity-based sanctions, transnational criminal organizations, or individuals who may be subject to sanctions for a number of reasons.

Every DerbySoft employee shall comply with all applicable export control requirements, including relevant economic and trade sanctions laws in all jurisdictions in which DerbySoft operates. Unless approved by the Legal Department and all government authorizations are obtained, DerbySoft does not export to denied parties, restricted end users, or the following embargoed countries Cuba, Iran, North Korea, Russia, Belarus, Syria, and the Crimea, Donetsk People’s Republic, and Luhansk People’s Republic regions of the Ukraine. DerbySoft employees shall also comply with internal policies and procedures for due diligence and other activities used to support sanctions and export controls compliance. Failure to comply may result in fines, loss or restriction of export privileges, or adverse publicity for DerbySoft. 

Violations of these standards due to negligent or reckless conduct will not be tolerated and, in accordance with applicable laws and regulations, might result in the imposition of appropriate disciplinary actions, up to and including termination of engagement. Intentional violation of these requirements may also be a criminal offense and can result in fines, imprisonment, or other punishment. All employees are encouraged to scrutinize the legitimacy of an export transaction and report any concerns. 

Responsibilities 

Each supervisor and manager is responsible for ensuring employee understanding and compliance with export regulatory requirements associated with the activities in which the employee is engaged. Business situations having the appearance of not complying with the regulations or the terms of export licenses should be reported promptly to the supervisor and the Legal Department. Any employee may bring export control issues to the attention of higher management for review or by sending an email to legal@derbysoft.net, with “Confidential and Privileged Communications” legend included in the subject matter line.  

Questions about this policy are encouraged. Any questions concerning this policy, its application to a specific situation, or the legitimacy of a transaction should be addressed to the Legal Department.