OVERVIEW
Export control refers to a set of legal restrictions on the transfer of certain goods, technology, software and knowledge from the United Kingdom to a destination outside the UK. An export licence is needed before the export of controlled military goods, software and technology and items on the UK dual-use list from the United Kingdom to another country. Export controls are designed to restrict the export and communication of sensitive technology or strategic goods, with the aim of preventing weapons of mass destruction (WMD) proliferation and countering international threats such as terrorism. In the UK, exports of strategic goods and any licences required are administered by the Export Control Joint Unit (ECJU).
COMMITMENT TO EXPORT CONTROL COMPLIANCE
In pursuit of its mission to provide world-class data analytics, Earth-i engages customers globally. However, some of the knowledge held, software developed, and activities conducted by Earth-i have the potential to be misused. Compliance with Export Control is seen as part of the broader responsibility for research integrity and Earth-i will ensure research is undertaken in line with relevant legislation, guidance, and ethical principles.
The COO has overall responsibility for the export control compliance at Earth-i and is supported by external Export Control professionals in matters relating to export control. Although responsibility for compliance with Export Control regulations rests with the individual, Earth-i will take adequate measures to support staff to achieve compliance and ensure that itself has complied with the law. To achieve this, Earth-i will:
- Ensure that all necessary licences are applied for prior to exporting any controlled goods or technology, and that any licences we hold are correctly used in line with their terms and conditions. Raise awareness, knowledge and understanding of export control regimes within our academic community.
- Maintain clear and effective export control processes and procedures and processes including appropriate record keeping and internal audit arrangements.
- Provide advice and training to support our staff and the development process.
- Keep up to date with evolving legislation and relevant regulations.
Failure to adhere to export control obligations is a criminal offence and can lead to financial penalties for both the individuals concerned and Earth-i, legal costs, reputational damage for Earth-i, and even imprisonment.
INDIVIDUAL RESPONSIBILITIES
It is the responsibility of individual staff to be aware of and comply with export control laws and Earth-i’s relevant procedures. Staff, particularly in technology and engineering disciplines, should ensure that they:
- Have read and understood Earth-i’s guidance on Export Control;
- Are aware whether their technical areas may be subject to Export Control legislation;
- Where their work is subject to legislation, have undertaken appropriate training;
- Consider the Earth-i’s guidance on Export Control whenever embarking on an activity that could:
- lead to the physical or electronic export of restricted goods, software, data, technology or know how outside the UK;
- involve goods, software or technology with the potential for military or WMD use;
- involve the transfer of knowledge within the UK for use in a WMD programmes outside the UK (including through teaching);
- involve the transit of restricted goods, software, data, technology through the UK.
- Seek advice and apply for licences as necessary.
Should an employee suspect that Export Controls may apply to their work, they should seek advice from the COO. The COO can advise on whether activity is subject to controls and support the use of existing Open General Export Licences held by Earth-i or apply for a specific export licence from the ECJU to carry out an activity. Although responsibility for compliance with Export Control regulations rests with the individual employee, Earth-i will ensure that it takes adequate measures to support employees to achieve compliance and ensure that Earth-i itself has complied with the law. Further Information on Export Control support is provided within the Earth-i employee handbook.
CONTACT
If you have any questions, comments or requests relating to Export Control, you can contact us by email at exportcontrol@earthi.co.uk.