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Global Sanctions Policy and Governance Process

Last Updated October 2020

Axora is committed to maintaining the highest standards of business conduct and ethics everywhere we operate or carry out business. This means that we will comply with economic and export sanctions laws to the extent they are applicable to Axora. This includes applicable economic sanctions (e.g., those imposed by the United Nations, United Kingdom, United States, European Union, and others) meant to hinder terrorism, narcotics trafficking, human rights abuses, the proliferation of weapons of mass destruction, and other malign activity and export sanctions (e.g. those imposed by the United Nations, United Kingdom, United States, European Union, and others) meant to restrict the use of, and access to, specified goods, technology, software, and information for reasons of national security or other foreign policy objectives.

Oversight of this policy is provided by the Axora Chief Executive and Chief Commercial Officer.

This Policy applies to all of our engagements with users, partners, employees, consultants, or anyone else we interact with on behalf of Axora.

The Basics

Axora takes a risk-based approach to identifying users and technology that may be subject to economic or export (trade) sanctions. Types of sanctions include:

  • Economic or financial sanctions (e.g. targeted asset freezes, restrictions on financial markets and financial services and bans from conducting business with certain individuals, groups or countries)

  • Trade sanctions or export controls (e.g. restrictions on the export of goods or technology to certain countries, individuals or groups).

Many sanctions are list-based and individuals, entities or governments or goods that are subject to economic or trade sanctions can be found on specific sanctions lists. For example, in the U.S., the Office of Foreign Assets Control publishes a Sanctions List. In the UK, HM Treasury publishes a list of financial sanctions targets and the Department for International Trade publishes information about export controls. Globally, individual states have differing policies in relation to who or what is sanctioned and how those sanctions are enforced.

Economic Sanctions

Economic sanctions prohibit any business dealings by Axora with a sanctioned individual, entity or jurisdiction. Jurisdictions currently subject to economic sanctions include Iran, Iraq, North Korea, Syria and Ukraine.

Axora takes a risk based approach to economic sanctions by screening users who apply to join the Axora community. Axora also periodically reviews its user accounts. However, Axora requires employees to remain vigilant for any indication that a user or partner may be subject to economic sanctions. Any indications should immediately be raised to the Chief Commercial Officer or the Chief Executive Officer.

Trade Sanctions and Export Controls

Export controls or trade sanctions restrict certain items from being sent to or received from particular jurisdictions or persons. Typically, these are known as Controlled Items and can include certain physical goods, certain software and certain technology that can be used for both civil and military purposes. Technology can also include any information needed to develop, produce, use operate, install, maintain, repair, overhaul, or refurbish any Controlled Item. For example, technology that could be used to service physical goods that are themselves Controlled Items. Export controls require that an export licence be obtained from the relevant government authority before the item can be exported. Some Controlled Items cannot be exported at all. Becoming involved in the export of Controlled Items without the appropriate licence in place or where a licence is not available may be a breach of export controls.

Axora takes a risk based approach to export controls and trade sanctions by screening technology descriptions prior to posting on the Axora platform. Axora requires employees to remain vigilant for any indication that a user is using the platform to buy or sell a technology that may be subject to Export Controls. Any concerns should immediately be raised to the Chief Commercial Officer or the Chief Executive Officer.

Axora is committed to the highest standards of openness, probity and accountability and comply with our obligations to protect whistleblowers. 

Axora External Sanctions Process

Axora is committed to execute our carefully designed processes and procedures to ensure compliance with our Sanctions Policy. We use the Dow Jones’ Risk Centre to support us with expert and up to date information to ensure we can conduct robust and reliable assessments and, if needed, investigations.

There are two high level processes that we conduct:

  • Each time a new prospective customer engages with Axora, we complete the sanctions check on the organisation.

  • On a quarterly basis, we check the entire customer & prospective customer list through the same process to ensure we are using up to date sanctions data against our customer lists.

In both cases, we store the outcomes of these tests in our SalesForce system to ensure auditability and robust tracking.

In the event of a sanctions flag, we immediately suspend interaction with the customer and the matter is escalated to the Axora Chief Commercial Officer and Chief Executive Officer for a deeper assessment, including taking legal advice if required. If the outcome of the manual assessment is that the organisation, or associated individuals, or states, are confirmed as under sanctions, we will cease all engagement with immediate effect.