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Export Control & Sanctions

Export Control & Sanctions

Effective date: 4 November 2026

INNAVISTA LTD (“INNAVISTA”, “we”, “us”) supplies enterprise servers, components, software and technology services to business customers in the United Kingdom and internationally. Some of these products are subject to economic sanctions and export controls. This Policy sets out the standards we apply and what we require from our customers.

1. OUR COMMITMENT

We comply with all trade and financial sanctions and export control laws that apply to our business, including:

  • the Sanctions and Anti-Money Laundering Act 2018 and the sanctions regulations made under it;

  • the Export Control Order 2008 and the UK Strategic Export Control Lists;

  • sanctions measures adopted by the United Nations Security Council;

  • where they apply to the goods, the transaction or the parties involved, the sanctions and export control laws of the European Union and the United States, including the U.S. Export Administration Regulations for items of U.S. origin.

We will not enter into or continue any transaction that would breach these laws, whatever its commercial value.

2. SCOPE

This Policy applies to every sale of new and refurbished hardware, components, software and services by INNAVISTA, to deliveries within the United Kingdom and abroad, and to our directors, staff, contractors and partners acting on our behalf.

3. RESTRICTED DESTINATIONS

We do not supply goods, software, technology or services, directly or indirectly, to or for use in:

  • Russia and Belarus;

  • Iran and North Korea;

  • the Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia regions of Ukraine;

  • any other country or territory subject to comprehensive UK, UN, EU or U.S. sanctions.

Supplies to other jurisdictions subject to targeted sanctions or arms embargoes are reviewed case by case and may be refused.

4. RESTRICTED PARTIES

We do not deal with any person or organisation that is:

  • designated on the UK Sanctions List, the UN Security Council Consolidated List, the EU consolidated list of financial sanctions, the U.S. OFAC Specially Designated Nationals List or the U.S. Entity List;

  • owned or controlled, directly or indirectly, by a designated person;

  • acting on behalf of, or at the direction of, a designated person.

5. CUSTOMER DUE DILIGENCE

Before accepting an order, we may:

  • verify the customer’s identity, registration details and beneficial ownership;

  • screen the customer, its owners, the delivery address and the end user against applicable sanctions lists;

  • confirm the final destination, the end user and the intended end use of the goods;

  • request supporting documents, such as company registration documents, VAT details or proof of trading address.

We repeat screening when an order, a delivery address or customer details change.

6. HIGH-PERFORMANCE COMPUTING AND CONTROLLED ITEMS

Certain servers, processors, GPU accelerators, network and storage equipment are designated as high-priority items under international sanctions or may be controlled under export control laws. For these items we:

  • require a signed end-user and end-use statement before supply;

  • check whether an export licence is required for the destination, the end user or the end use;

  • do not supply items for military, weapons of mass destruction, unlawful surveillance or any other prohibited end use;

  • refuse orders where we cannot confirm the end user or the final destination.

7. WARNING SIGNS

We treat the following as warning signs that require further review and may lead us to refuse an order:

  • reluctance to provide end-user or end-use information;

  • a delivery address at a freight forwarder, logistics hub or third country without a clear business reason;

  • requests for unusual payment methods, payments from third parties or payments from a country unconnected with the customer;

  • products, specifications or quantities inconsistent with the customer’s stated business;

  • requests to alter labels, shipping documents or descriptions of goods;

  • a newly established customer with limited verifiable trading history ordering high-value or high-specification equipment.

8. CUSTOMER OBLIGATIONS

By placing an order with INNAVISTA, the customer confirms and agrees that:

  • it is not a restricted party and is not owned or controlled by one;

  • the information it provides about the end user, end use and destination is accurate and complete;

  • it will not re-export, resell, transfer or supply the goods, software or technology in breach of applicable sanctions or export control laws, including to any restricted destination or party;

  • it will obtain any export licence required for its own onward supply;

  • it will notify INNAVISTA promptly if any of the above ceases to be true.

9. OUR RIGHTS

We may refuse, suspend or cancel any order, withhold delivery or terminate any agreement without liability where we reasonably believe that proceeding could breach sanctions or export control laws, or where the customer does not provide the information we request. Where required by law, we report suspected breaches to the relevant authorities.

10. RECORD KEEPING

We keep records of customer due diligence, sanctions screening, end-user statements and export documentation for at least six years, or longer where the law requires.

11. REVIEW OF THIS POLICY

Everyone involved in sales and logistics on our behalf is made aware of this Policy. We review it at least once a year and whenever the relevant laws change. This Policy forms part of our Terms of Business.

12. QUESTIONS AND CONCERNS

To ask a question about this Policy or report a concern, email hello@innavista.com with the subject line “Sanctions Compliance”. Concerns are handled confidentially.

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