1. Purpose
This Addendum establishes Murzo Group’s approach to compliance with export controls, sanctions regimes, and trade restrictions applicable to its activities.
It is intended to ensure compliance with applicable UK export control and sanctions laws, allocate responsibility for lawful use, transfer, and disclosure of controlled items, mitigate legal, financial, and reputational risk, and provide a clear basis for refusal, suspension, or termination of engagements.
This Addendum operates in conjunction with Murzo Group’s Global Compliance Statement, Defence & Security Compliance Policy, and Terms & Conditions.
2. Legal Framework
Murzo Group complies with applicable export control and sanctions laws, including but not limited to:
- UK Export Control Act 2002 and associated regulations
- UK Strategic Export Control Lists
- UK sanctions and anti-money laundering legislation
- Relevant United Nations sanctions and resolutions
Murzo Group does not align itself with, or assume obligations under, foreign military alliances or non-UK regulatory regimes unless legally required.
3. Scope
This Addendum applies to:
- Goods, software, technology, designs, and technical data
- Digital transfers, disclosures, and remote access
- Dual-use and defence-adjacent items
- Research, development, and design outputs
- All Murzo Group operations, platforms, and communications
Export controls apply regardless of whether transfer is physical or electronic.
4. Controlled & Dual-Use Items
Certain items may be subject to export controls due to their nature or potential application.
- Software, algorithms, or source code
- Technical designs, schematics, or specifications
- Sensors, robotics, or UAV/UUV-related technologies
- Cryptography or cybersecurity tools
- AI models or datasets with dual-use potential
Murzo Group assesses classification on a risk-based and precautionary basis.
5. Licensing & Authorisations
Where export controls apply:
- Required licences or authorisations must be obtained before export, transfer, or disclosure
- Activities may be delayed or refused pending regulatory approval
- Murzo Group reserves sole discretion to determine whether to seek a licence
- Murzo Group is under no obligation to pursue licences where risk or uncertainty exists
6. Sanctions Compliance
Murzo Group does not engage in activities that would breach applicable sanctions, including restrictions relating to:
- Certain countries or regions
- Designated individuals or entities
- Prohibited end uses or end users
Murzo Group may conduct due diligence and screening to assess sanctions risk.
7. Client & Partner Responsibilities
Clients, partners, and counterparties acknowledge that export and sanctions laws may apply to Murzo Group deliverables and that they are responsible for lawful receipt, use, and onward transfer.
They must not request or cause Murzo Group to act unlawfully. Murzo Group relies on representations provided but reserves the right to verify or refuse engagement.
8. Right to Refuse, Suspend, or Terminate
Murzo Group reserves the absolute right to refuse to provide goods, services, or information, suspend or terminate engagements, or withhold delivery or access where compliance cannot be assured.
No liability shall arise from such refusal or suspension.
9. No Circumvention
Murzo Group does not participate in, nor tolerate, attempts to circumvent export controls or sanctions, misrepresentation of end use or end user, or indirect transfers intended to avoid restrictions.
Such conduct may result in immediate termination and notification to authorities where required.
10. Record Keeping
Murzo Group maintains records relating to export control and sanctions compliance where required by law, including classification assessments, licences, and due diligence materials.
Retention aligns with Murzo Group’s Records Retention & Legal Hold Policy.
11. Limitation of Liability
To the fullest extent permitted by law, Murzo Group is not liable for losses arising from refusal, delay, or termination due to compliance concerns, nor for unlawful use or onward transfer by third parties.
12. Reporting & Escalation
Concerns regarding export or sanctions compliance may be escalated internally. Murzo Group will assess risks objectively, take corrective action where required, and notify authorities where legally obligated.
Retaliation against individuals raising genuine compliance concerns is not tolerated.
13. Limitations
This Addendum does not constitute legal advice, create contractual rights beyond existing agreements, or override mandatory legal obligations.
Murzo Group retains discretion in its application.
14. Review & Updates
This Addendum is reviewed periodically and updated to reflect changes in law or sanctions regimes, evolving risk profiles, and operational developments.
Revised versions will be published on Murzo Group platforms.
