Sanctions & Export Control Policy

Purpose & Scope

Aetherops Sentinel Technologies Pvt. Ltd. ("Aetherops," the "Company," "we," "our," or "us"), which operates the TheCloudbox brand and platform, is committed to full compliance with the economic sanctions, trade embargoes, and export-control laws that apply to our business. Because we provide cloud, DevOps, and security technology across borders, these laws directly affect who we may deal with and what we may share.

This policy applies to all directors, officers, employees, contractors, and interns, and to all Company products, software, source code, technical data, and services.

Policy Statement

We do not sell, supply, export, re-export, or transfer products, software, technology, or services to sanctioned parties or embargoed destinations, or in support of prohibited end-uses, except where clearly permitted by law or an authorisation. When in doubt, we stop and seek guidance before proceeding.

Key Definitions

• Export — sending or taking controlled items, software, or technology out of a country, by any means, including electronic transfer or cloud access.
• Re-export — transferring items from one foreign country to another.
• Deemed export — releasing controlled technology or source code to a foreign national, even within a single country.
• Restricted party — any person or entity on a government sanctions, denied-persons, or debarment list.
• End-use / end-user — the ultimate use and user of an item, including sensitive uses such as military or WMD applications.

Applicable Laws & Regimes

We comply with all trade-control laws that apply to us, including:

• India: the Foreign Trade (Development & Regulation) Act, the Foreign Trade Policy and DGFT rules, and the SCOMET list for dual-use, munitions, and technology items.
• United States: the Export Administration Regulations (EAR) administered by BIS, sanctions programs administered by OFAC, and the ITAR where applicable.
• European Union and United Kingdom trade sanctions and dual-use export controls.
• United Nations Security Council sanctions and other applicable national regimes.

Restricted & Prohibited Parties

Before onboarding a customer, partner, supplier, or reseller — and before providing access to controlled products or technology — we screen the party and its key stakeholders against applicable sanctions and denied-party lists, and we re-screen when relationships or lists change. We do not transact with a party that is a prohibited match.

Embargoed & Restricted Destinations

We do not provide products, software, technology, or services to comprehensively embargoed or sanctioned territories, or to parties located there, except under a valid licence or exemption. Dealings connected with restricted destinations require prior review and, where required, authorisation.

Controlled Products, Software & Technology

Some of our software and technology — particularly items with encryption or security functionality — may be subject to export classification and controls. We:

• Classify products, software, and technology to determine their control status before export.
• Control the release of source code and technical data, including deemed exports to foreign nationals.
• Manage cloud access so that controlled technology is not made available to restricted parties or destinations.
• Obtain licences or rely on valid exemptions where an export would otherwise be restricted.

Customer & Partner Due Diligence

We conduct risk-based due diligence on customers, partners, and end-users, confirm legitimate end-use, and include export-compliance and sanctions terms in our contracts. We do not facilitate transactions structured to evade trade controls.

Red Flags

Be alert to warning signs such as a customer reluctant to give end-use or end-user information, requests to route shipments or access through third countries, mismatched addresses, requests to under-declare or mislabel items, or end-uses connected to military, nuclear, or other sensitive applications. Escalate red flags before proceeding.

Recordkeeping

We maintain accurate records of classifications, screenings, licences, approvals, and relevant transactions for the periods required by law, so that our compliance can be demonstrated and audited.

Reporting, Roles & Enforcement

Report any potential sanctions or export-control concern — including a possible violation — to the Compliance function immediately through the channel below; do not attempt to resolve it yourself. The Compliance function owns this policy, provides guidance and training, and manages licences and voluntary disclosures. Violations can carry severe civil and criminal penalties for the Company and individuals, and breach of this policy may lead to disciplinary action up to and including termination.

Contact & Reporting

Questions about this policy, or reports of a suspected violation, may be raised in confidence at: