Global Trade Sanctions and Export Controls Policy
Effective Date: January 10, 2019
Last Reviewed: November 1, 2024
Purpose
This policy outlines DRILLIT Energy and Mining’s (“DRILLIT”) commitment to compliance with all applicable global trade sanctions, export control regulations, and related laws. It provides guidelines for conducting business ethically, ensuring that our operations, supply chains, and partnerships adhere to international trade laws.
Scope
This policy applies to all DRILLIT employees, contractors, suppliers, distributors, agents, and business partners globally. It governs the export, import, transfer, or re-export of goods, technology, software, and services.
Policy Statements
1. Compliance with Trade Sanctions and Export Control Laws
DRILLIT complies with all applicable trade sanctions and export control regulations, including but not limited to:
United Nations Security Council Sanctions
U.S. Export Administration Regulations (EAR)
Office of Foreign Assets Control (OFAC) Sanctions
European Union Sanctions
Canadian Export Control Regulations
Local laws in jurisdictions where we operate.
2. Prohibited Transactions
DRILLIT does not engage in business activities with entities, individuals, or countries subject to trade sanctions, embargoes, or restricted-party lists issued by recognized authorities.
This includes, but is not limited to:
Transactions with entities on the OFAC Specially Designated Nationals (SDN) List.
Transactions involving countries under comprehensive sanctions (e.g., North Korea, Iran, or Syria).
3. Export and Import Controls
DRILLIT ensures all exports and imports of goods, technology, and services comply with applicable export control classifications, licenses, and documentation requirements.
Employees must verify whether a license or authorization is required before exporting controlled items.
4. Screening and Due Diligence
DRILLIT conducts thorough due diligence and screening of customers, suppliers, and partners against relevant restricted-party lists and embargoed destinations.
Automated and manual tools are used to verify compliance with trade restrictions.
5. Restricted Technologies and Dual-Use Items
Certain technologies, software, and equipment (dual-use items) that can be used for both civilian and military purposes are subject to strict controls.
DRILLIT ensures compliance with these regulations by obtaining appropriate licenses or authorizations before engaging in transactions involving dual-use items.
6. Reporting and Recordkeeping
All documentation related to export and import transactions, including licenses, invoices, and shipping records, must be retained for a minimum of five years or as required by law.
Employees must immediately report any suspected violations of trade sanctions or export controls to the compliance team.
Implementation and Enforcement
1. Training and Awareness
All employees involved in international trade activities must undergo regular training on trade sanctions and export control compliance.
Training sessions cover applicable laws, screening procedures, and reporting obligations.
2. Risk Assessment
DRILLIT periodically conducts risk assessments of its operations, supply chains, and partnerships to identify and mitigate potential violations of trade laws.
3. Monitoring and Auditing
Regular audits and monitoring are conducted to ensure adherence to trade sanctions and export control laws.
Non-compliance identified during audits will result in corrective action plans.
4. Disciplinary Measures
Violations of this policy may result in disciplinary action, including termination of employment or contracts. Severe violations may also lead to legal consequences.
Governance and Review
This policy is overseen by DRILLIT’s Compliance and Legal Teams. It will be reviewed annually or as necessary to reflect changes in trade sanctions, export control laws, or business operations.
Reporting Concerns
Concerns or suspected violations can be reported through the following channels:
Email: info@drillitenergy.com
Phone: +1(780)863-0160
Approved by: Francis Amankwa
Date: January 10, 2019
Last Reviewed: November 1, 2024
Purpose
This policy outlines DRILLIT Energy and Mining’s (“DRILLIT”) commitment to compliance with all applicable global trade sanctions, export control regulations, and related laws. It provides guidelines for conducting business ethically, ensuring that our operations, supply chains, and partnerships adhere to international trade laws.
Scope
This policy applies to all DRILLIT employees, contractors, suppliers, distributors, agents, and business partners globally. It governs the export, import, transfer, or re-export of goods, technology, software, and services.
Policy Statements
1. Compliance with Trade Sanctions and Export Control Laws
DRILLIT complies with all applicable trade sanctions and export control regulations, including but not limited to:
United Nations Security Council Sanctions
U.S. Export Administration Regulations (EAR)
Office of Foreign Assets Control (OFAC) Sanctions
European Union Sanctions
Canadian Export Control Regulations
Local laws in jurisdictions where we operate.
2. Prohibited Transactions
DRILLIT does not engage in business activities with entities, individuals, or countries subject to trade sanctions, embargoes, or restricted-party lists issued by recognized authorities.
This includes, but is not limited to:
Transactions with entities on the OFAC Specially Designated Nationals (SDN) List.
Transactions involving countries under comprehensive sanctions (e.g., North Korea, Iran, or Syria).
3. Export and Import Controls
DRILLIT ensures all exports and imports of goods, technology, and services comply with applicable export control classifications, licenses, and documentation requirements.
Employees must verify whether a license or authorization is required before exporting controlled items.
4. Screening and Due Diligence
DRILLIT conducts thorough due diligence and screening of customers, suppliers, and partners against relevant restricted-party lists and embargoed destinations.
Automated and manual tools are used to verify compliance with trade restrictions.
5. Restricted Technologies and Dual-Use Items
Certain technologies, software, and equipment (dual-use items) that can be used for both civilian and military purposes are subject to strict controls.
DRILLIT ensures compliance with these regulations by obtaining appropriate licenses or authorizations before engaging in transactions involving dual-use items.
6. Reporting and Recordkeeping
All documentation related to export and import transactions, including licenses, invoices, and shipping records, must be retained for a minimum of five years or as required by law.
Employees must immediately report any suspected violations of trade sanctions or export controls to the compliance team.
Implementation and Enforcement
1. Training and Awareness
All employees involved in international trade activities must undergo regular training on trade sanctions and export control compliance.
Training sessions cover applicable laws, screening procedures, and reporting obligations.
2. Risk Assessment
DRILLIT periodically conducts risk assessments of its operations, supply chains, and partnerships to identify and mitigate potential violations of trade laws.
3. Monitoring and Auditing
Regular audits and monitoring are conducted to ensure adherence to trade sanctions and export control laws.
Non-compliance identified during audits will result in corrective action plans.
4. Disciplinary Measures
Violations of this policy may result in disciplinary action, including termination of employment or contracts. Severe violations may also lead to legal consequences.
Governance and Review
This policy is overseen by DRILLIT’s Compliance and Legal Teams. It will be reviewed annually or as necessary to reflect changes in trade sanctions, export control laws, or business operations.
Reporting Concerns
Concerns or suspected violations can be reported through the following channels:
Email: info@drillitenergy.com
Phone: +1(780)863-0160
Approved by: Francis Amankwa
Date: January 10, 2019