Anti-bribery, sanctions and export controls

What we do not do

We sell software. We do not buy, sell, ship goods or hold money. We do not clear customs and we do not apply for an export licence on your behalf. You remain responsible for your own goods, counterparties and routes.

Bribery

We do not offer or accept bribes, kickbacks or improper gifts to win or keep business. That includes public officials and private counterparties. You must not use the software, or our name, to offer or hide a bribe. The UK Bribery Act, the US Foreign Corrupt Practices Act and Brazilian anti-corruption law are the kinds of rules this statement is written to respect. This page is not a legal opinion on those statutes.

Sanctions and export controls

You may not use the software if you are a denied party, or to deal with a person or place that applicable sanctions forbid. Applicable sanctions include those of the United States (including OFAC), the European Union, the United Nations, and the United Kingdom, and Brazilian rules where they apply to you.

You may not use the software to export, re-export or transfer goods, software or technical data in breach of US export controls or other export law that applies to you. The software itself is commercial business software, not designed for military use.

We may suspend an account if we have a credible reason to think this section is being broken. We do not screen every counterparty you type into a record. That check is yours.