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Sanctions and Export Control Policy

METADAT-AI LTD

Sanctions & Export Control Policy

Version 1.2
Effective Date October 2026
Owner Chief Executive Officer
Review Due Annually
Classification Public (Metadat-AI Policy)

About this Policy

This policy describes Metadat-AI's own sanctions and export control programme. It is published as one of the Metadat-AI Policies. Where an agreement requires a reseller or other partner to comply with it, only the obligations expressed to apply to that partner bind it. It does not create rights for any other person.

1. Purpose

METADAT-AI LTD (“Metadat-AI”) is committed to complying with all applicable sanctions and export control laws. This policy sets out the obligations of Metadat-AI and all personnel to ensure that the Metadat-AI Platform and related services are not made available to sanctioned persons, entities, or jurisdictions, and that the transfer of technology complies with applicable export controls.

Non-compliance with sanctions and export control laws can result in severe civil and criminal penalties, including unlimited fines and imprisonment, as well as significant reputational damage. Compliance is mandatory.

2. Scope

This policy applies to:

  • All Metadat-AI employees, directors, officers, and contractors.

  • All resellers, introducers, and channel partners operating under agreement with Metadat-AI.

  • All customers accessing the Metadat-AI Platform directly or through a reseller.

This policy applies to all activities of Metadat-AI, including licensing, distribution, technical assistance, and any other dealing with the Metadat-AI Platform or associated technology.

3. Applicable Sanctions Regimes

Metadat-AI is subject to the following principal sanctions regimes:

  • United Kingdom: sanctions administered by His Majesty’s Treasury Office of Financial Sanctions Implementation (“OFSI”) under the Sanctions and Anti-Money Laundering Act 2018 and relevant statutory instruments implementing UK autonomous sanctions regimes, including regimes targeting Russia, Belarus, Iran, North Korea, Myanmar, and other jurisdictions.

  • United Nations: UN Security Council sanctions, which are implemented in UK law and apply automatically.

  • United States (awareness only): Metadat-AI is aware of US Office of Foreign Assets Control (“OFAC”) sanctions regimes, which may apply to US persons, US-incorporated entities, US-dollar transactions, and any business involving US technology or personnel. Where Metadat-AI engages with US counterparties or relies on US technology, legal advice will be sought on the applicability of OFAC sanctions.

  • European Union: EU sanctions apply where Metadat-AI deals with EU-based customers, partners or end users, or makes the Platform available in the EU. Metadat-AI complies with them in those cases.

The applicable sanctions regimes are subject to frequent change. Metadat-AI monitors relevant OFSI, UN, EU and (where applicable) OFAC updates and guidance.

4. Prohibited Activities

Metadat-AI prohibits the following activities:

  • Providing access to the Metadat-AI Platform, services, or technology to any person or entity that is the subject of applicable sanctions (“Sanctioned Person”).

  • Entering into any commercial arrangement with a Sanctioned Person, including as customer, reseller, introducer, investor, or supplier.

  • Making funds, economic resources, or technology available (directly or indirectly) to or for the benefit of a Sanctioned Person.

  • Providing services in connection with any transaction involving a Sanctioned Person or a sanctioned jurisdiction.

  • Circumventing or facilitating the circumvention of applicable sanctions.

5. Sanctioned Jurisdictions

Metadat-AI does not conduct business with customers, resellers or end users in jurisdictions subject to comprehensive UK or EU sanctions, or in territories subject to wide-ranging UK trade restrictions (including Russia, Belarus, Iran, North Korea and the Russian-occupied regions of Ukraine). The current position is published by OFSI and the Department for Business and Trade and is checked before entering a new jurisdiction.

The Software is supplied for installation on customers' own hardware (Customer-Hosted Deployment) and, for some customers, as a service hosted by Metadat-AI. Metadat-AI takes reasonable steps to prevent supply to, and use in, sanctioned jurisdictions through contractual controls, screening and, where technically feasible, access restrictions, and will take appropriate action on becoming aware of any such use.

6. Export Controls

Certain technology, including software incorporating dual-use technology, machine learning models, and AI systems, may be subject to export controls under UK law (“UK Strategic Export Controls”), administered by the Export Control Joint Unit (“ECJU”) of the Department for Business and Trade.

Metadat-AI will assess its technology against applicable export control classifications before the first supply of on-premise software outside the United Kingdom and when its products change materially, and will seek export licences where required. Metadat-AI does not knowingly export or transfer controlled technology without the required authorisation.

Where Metadat-AI’s technology is developed using or incorporates open-source components subject to US Export Administration Regulations (“EAR”) or other non-UK export control regimes (by reason of US-origin technology), Metadat-AI will take reasonable steps to identify and comply with such obligations, including seeking legal advice where appropriate.

7. Customer and Counterparty Screening

Before entering into a commercial relationship with any customer, reseller or business partner, Metadat-AI carries out proportionate sanctions screening to check that the counterparty does not appear on applicable sanctions lists. Screening is repeated where there is a material change, such as a change of ownership or territory, or reason to suspect a change in status.

Metadat-AI's standard agreements include a sanctions compliance commitment from the counterparty confirming that it is not a Sanctioned Person and will not use Metadat-AI's services in a way that would cause Metadat-AI to breach applicable sanctions laws.

Where screening identifies a potential match or concern, the matter is escalated to the Chief Executive Officer and, where appropriate, external legal counsel is consulted before any business is conducted with the relevant party.

8. Reseller Obligations

Resellers and other partners must comply with the sanctions and export control obligations in their agreement with Metadat-AI, including not making the Platform available to Sanctioned Persons or in sanctioned jurisdictions, screening their customers, and notifying Metadat-AI promptly of any concern.

9. Reporting and Escalation

Any employee, contractor, or third party who becomes aware of a potential or actual breach of this policy, or who has concerns about a counterparty’s sanctions status, must report this to the Chief Executive Officer immediately.

Where Metadat-AI becomes aware that it has provided services to a Sanctioned Person or has otherwise breached applicable sanctions, it will:

(a) immediately cease the relevant services;
(b) seek legal advice on its reporting obligations to OFSI or other relevant authorities;
(c) take all steps required to comply with applicable law, including voluntary disclosure to OFSI if appropriate.

Failure to comply with this policy may result in disciplinary action.

10. Training and Awareness

Metadat-AI makes relevant personnel aware of sanctions and export control obligations at onboarding. Personnel should raise any concerns with the Chief Executive Officer.

11. Review

This policy is reviewed at least annually, or earlier if required by changes to applicable sanctions or export control law, regulatory guidance, or material changes to Metadat-AI’s business model or geographic reach.