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SPARX SYSTEMS

Trade Sanctions Policy


1. Purpose

This policy outlines the principles and guidelines regarding trade sanctions compliance for Sparx Systems Pty Ltd. The purpose of this policy is to ensure that Sparx Systems Pty Ltd conducts its international trade activities in compliance with applicable trade sanctions laws and regulations.


2. Scope

This policy applies to all individuals, including contractors, consultants, and agents of Sparx Systems Pty Ltd, regardless of their role or location, who are involved in international trade activities or transactions that may be subject to trade sanctions laws and regulations.

In line with Australian and international export restrictions during the Russia/Ukraine conflict, Sparx Systems wishes to continue to ensure and enforce full compliance with all sanctions and restrictions throughout its Reseller Network.

  • Sales to any entity (company or individual or entity associated with a sanctioned individual) on the Australian sanction list are explicitly forbidden.
  • Sales to existing Russian customers (individuals and companies) NOT on the Australian sanction list AND not on any local sanction list in the reseller's region are acceptable.
  • Sales to new Russian customers are not automatically approved. In the case where a new customer is a long-established Russian entity and is NOT sanctioned, then an approval may be sought and granted.
  • Sales to new Russian customers that are recently established companies are NOT approved.
  • Sales to single individuals are NOT approved.

The Australian list of sanctioned individuals and entities can be found here: https://www.dfat.gov.au/international-relations/security/sanctions/consolidated-list


3. Policy Statements

  • Compliance with Laws: Sparx Systems Pty Ltd is committed to complying with all applicable trade sanctions laws and regulations, including those imposed by Australia, the United States, the European Union, the United Nations, and other relevant jurisdictions.
  • Prohibited Transactions: It is strictly prohibited to engage in any transactions or business activities that violate trade sanctions laws or regulations. This includes, but is not limited to, transactions involving countries, entities, or individuals subject to comprehensive or targeted sanctions.
  • Restricted Countries, Entities, and Individuals: Sparx Systems Pty Ltd will maintain a list of countries, entities, and individuals subject to trade sanctions. All personnel must ensure that they do not engage in any transactions involving parties on these lists without proper authorization.
  • Due Diligence: Prior to engaging in any international trade activities, individuals must conduct due diligence to ensure compliance with trade sanctions laws and regulations. This includes screening counterparties, customers, suppliers, and other business partners against applicable sanctions lists.
  • Training and Awareness: Sparx Systems will provide regular training and resources to individuals involved in international trade activities to raise awareness about trade sanctions laws and regulations, as well as the importance of compliance.
  • Reporting and Monitoring: Individuals are required to promptly report any actual or potential violations of this policy to [Designated Department]. Sparx Systems Pty Ltd will regularly monitor and audit its international trade activities to ensure compliance with this policy and applicable laws.

4. Responsibilities

  • Senior Management: Senior management is responsible for establishing and overseeing the implementation of effective trade sanctions compliance programs within their respective areas of responsibility.
  • Compliance Department: The Compliance Department is responsible for administering and enforcing this policy, including conducting risk assessments, providing guidance, and overseeing training and monitoring efforts.

5. Consequences of Non-Compliance

Non-compliance with this policy, including violations of trade sanctions laws and regulations, may result in disciplinary action, up to and including termination of employment or contract, as well as potential civil or criminal penalties for individuals and Sparx Systems Pty Ltd.


6. Policy Review

This policy will be reviewed periodically and updated as necessary to ensure it remains current and effective in addressing regulatory requirements and changes in the business environment.


7. Classification

Sparx Systems Pty Ltd does not guarantee the accuracy or reliability of the classifications presented in this classification table. Users utilize these classifications at their own risk, and Sparx Systems Pty Ltd disclaims any responsibility for any damages, whether direct, consequential, incidental, or otherwise, that may arise from the use or reliance upon these classifications for any purpose.

Product Name ECCN
Sparx Systems Enterprise Architect EAR99
Pro Cloud Server EAR99
Prolaborate EAR99

8. Contact Information

For questions or additional information regarding this policy, individuals may contact the Compliance Department at [email protected].