Export control & sanctions policy.

Scope

This policy applies to all business of Hlaváč Business, s.r.o., Company ID (IČO) 50 150 880 ("we"): the supply of software and AI agents, services provided remotely, including operation of and remote access to systems, and the purchase, use and deployment of hardware, in particular servers and graphics accelerators (GPUs).

Territorial scope

• We provide services and hardware exclusively within the European Union. We provide no services and deliver no hardware outside the EU.
• Computing hardware (servers and GPUs) is operated on our own premises in Bratislava and on-premise at the premises of our clients in the EU, as part of the AI solutions we deliver.
• We do not resell, export or transfer hardware outside the EU.

Rules we comply with

• Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items, and Slovak Act No. 39/2011 Coll. on dual-use items.
• EU restrictive measures, in particular Council Regulation (EU) No 833/2014 (Russia), Council Regulation (EC) No 765/2006 (Belarus) and Council Regulation (EU) No 269/2014, UN sanctions as implemented in the EU, and Slovak Act No. 289/2016 Coll. on the implementation of international sanctions.
• Where they apply to the products, technology or transaction, the export control and sanctions rules of the United States (EAR, OFAC) and the United Kingdom (OFSI), and the conditions of hardware manufacturers and suppliers.

What we do not do

• We do not do business with persons or entities on EU, UN, US (e.g. SDN List, Entity List, MEU List) or UK sanctions lists, or with entities owned 50 % or more or controlled by them.
• We do not supply goods, software, technology or services to, or for use in, Russia, Belarus, Crimea, the so-called Donetsk and Luhansk regions, Iran, North Korea, Cuba or Syria, or to persons from these countries, in breach of applicable sanctions.
• We do not provide computing hardware, or services based on it such as AI model training, inference or remote server access, to parties headquartered in countries subject to restrictions on advanced computing items, or to their parent companies, in breach of applicable rules or manufacturer conditions.
• We do not support military end use, the development of weapons of mass destruction, or the circumvention of sanctions through third countries or intermediaries.

How we screen customers and transactions

• Before entering into a contract we check the customer, its owners and the end user against the EU consolidated sanctions list and, where relevant, against UN, US and UK lists.
• When hardware is deployed at a client, we require an end-use confirmation and a commitment that the equipment will not be exported or transferred outside the EU.
• If an item were subject to authorisation (e.g. under Regulation (EU) 2021/821), the transaction would only proceed after the competent authority has granted it.
• We do not grant remote access to systems we operate to persons from the countries listed above.
• We keep screening records for the duration of the contractual relationship and for the periods required by law.

Right to refuse

We reserve the right to refuse an order, suspend performance or withdraw from a contract if the customer does not provide the requested information, if there is a suspicion of a breach of sanctions or export control rules, or if performance would breach the law or manufacturer conditions.

Ethics and anti-corruption

• We do not offer, promise, give or accept bribes or any other undue advantage - to public officials or in the private sector.
• Gifts and hospitality are given and accepted only in reasonable value, transparently and never to influence a decision.
• We comply with the Slovak Criminal Code (Act No. 300/2005 Coll., corruption offences) and Act No. 91/2016 Coll. on the criminal liability of legal persons.
• We expect the same standards from our suppliers and partners.
• We follow the rules on competition and on the prevention of conflicts of interest.

Responsibility and contact

The Managing Director, Gustáv Hlaváč, is responsible for compliance with this policy. We review it whenever applicable sanctions rules change materially. Questions and suspected breaches can be sent to info@hlavac.business.