Effective Date: May 2025
Issued by: Executive Management
Applies to: All Skyline s.r.o. business units, employees, partners, and suppliers
PURPOSE
This policy defines Skyline’s commitment to conducting all export and trade activities in full compliance with applicable national, European Union, and international laws and regulations. As a company operating in the defense, dual-use, aerospace, and security sectors, Skyline s.r.o. is subject to strict control frameworks regarding the cross-border movement of goods, technologies, services, and technical data.
The policy establishes the standards and procedures that ensure Skyline’s compliance with export control regulations, sanctions regimes, and trade compliance requirements in all jurisdictions where we operate.
SCOPE
This policy applies to:
- All physical exports, re-exports, and transshipments
- Transfers of controlled technical data, software, or know-how (including electronically)
- Trade in goods classified as military, dual-use, or otherwise restricted
- Third-country brokering or transit operations
- Sales, procurement, and partnership activities involving foreign parties
- All employees, contractors, and intermediaries involved in relevant operations
It applies to all global operations of Skyline s.r.o., regardless of geographic location, mode of transport, or legal structure.
REGULATORY FRAMEWORKS
Skyline’s export and trade compliance system is built around the following key regulatory pillars:
- EU Dual-Use Regulation (Regulation (EU) 2021/821)
- Czech Act on Export Control of Military Material (Act No. 38/1994 Coll.)
- Common Military List of the European Union
- Arms Trade Treaty (ATT)
- Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods
- Applicable UN Security Council Resolutions
- US Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) (as relevant for US-origin content)
- National and EU sanctions and embargo regimes (e.g., against Russia, Iran, DPRK)
CORE PRINCIPLES
4.1 Licensing and Authorization
- No export, re-export, or technical transfer may occur without valid authorization from relevant authorities.
- Skyline applies for and monitors all necessary export licenses, end-use certificates (EUCs), and import authorizations in destination countries.
- Re-export of controlled goods is only permitted when explicitly authorized in the original license.
4.2 End-Use and End-User Screening
- All transactions are screened for:
- Final user identity and risk
- Intended use (civil, defense, or prohibited application)
- Geographic sensitivity (e.g., embargoed countries, conflict zones)
- End-use certificates must be obtained and verified for all military and dual-use items.
- Skyline does not participate in transactions involving weapons of mass destruction (WMD), missile technology, or human rights abuses.
4.3 Denied Parties and Sanctions Screening
- Customers, suppliers, and intermediaries are screened against:
- EU consolidated sanctions list
- US OFAC SDN list and BIS Denied Persons List
- UN and UK sanctions lists
- If a match is found, transactions are automatically blocked pending investigation.
4.4 Technical Data and Digital Transfers
- The transmission of controlled technical data (e.g., via email, cloud, or remote access) is regulated as an export.
- Employees must verify classification status before sharing information with foreign persons.
- Sensitive information must be encrypted, access-restricted, and only transferred with documented approval.
4.5 Third-Party and Broker Controls
- All agents, resellers, and brokers must be contractually bound to adhere to export control obligations.
- Due diligence is conducted on all intermediaries involved in cross-border sales.
- Skyline avoids involvement in transshipment schemes that obscure end-use or evade licensing.
ORGANIZATION & RESPONSIBILITIES
5.1 Export Compliance Officer (ECO)
- Manages licensing processes, recordkeeping, and risk assessments
- Advises project and commercial teams on classification and license scope
- Maintains Skyline’s export compliance manual, procedures, and training program
5.2 Senior Management
- Provides resources and authority for effective compliance
- Approves high-risk exports and receives regular compliance reports
5.3 Employees
- Must be familiar with this policy and act in accordance with its requirements
- Are required to report violations, risks, or unclear export situations to the ECO immediately
TRAINING & AWARENESS
- All relevant employees receive annual export control training
- Training includes classification, sanctions awareness, red flag indicators, and case studies
- Specialized modules are provided to commercial, engineering, logistics, and legal teams
- New hires receive onboarding briefings on export and sanctions risk
RECORDKEEPING & AUDIT
- All export-related records (licenses, shipping documents, EUCs, internal approvals) are retained for a minimum of 10 years
- Skyline conducts periodic internal audits of export and trade compliance activities
- Records must be complete, accurate, and retrievable at any time for inspection by regulators
VIOLATIONS & DISCIPLINARY ACTIONS
- Any suspected or actual violation of this policy must be reported to the ECO or compliance team
- Retaliation against whistleblowers is prohibited
- Breaches may result in:
- Revocation of export privileges
- Regulatory penalties or criminal liability
- Contract termination and disciplinary actions, up to dismissal
CONTINUOUS IMPROVEMENT
- This policy is reviewed annually and updated to reflect changes in regulation or operational scope
- Feedback from employees, clients, and regulators is used to strengthen procedures
- Skyline benchmarks its compliance practices against industry peers and regulatory guidance
DECLARATION
Skyline s.r.o. is committed to acting as a responsible participant in the global defense and dual-use ecosystem. We will not compromise on legal integrity, and we will continuously work to ensure that every export or transfer meets both the letter and the spirit of international trade laws.
Signed,
Executive Management
Skyline s.r.o.
Tržiště 13, 118 00 Prague, Czech Republic