1. Scope and Incorporation into Contracts

1. This policy governs compliance with sanctions, embargo, and export control regulations in connection with all deliveries of goods, software, technology, and services (“Deliverables”) by Steinberg GmbH.
2. The policy forms part of all contracts between Steinberg GmbH and customers, distributors, resellers, suppliers, and other business partners (“Partners”). It applies in addition to GTCs/individual contracts and prevails in the event of conflict (insofar as sanctions/export control matters are concerned).
3. By ordering, accepting, using, or passing on the Deliverables, and by referencing this policy (e.g., in offers, order confirmations, invoices, emails), the Partner agrees to be bound by this policy. The current version is available at https://steinberg.gmbh/en/no-russia/.

2. Legal Framework

The applicable regulations include, in particular, the EU sanctions regulations (including Regulation (EU) No. 833/2014, 765/2006, 269/2014, each as amended), anti-circumvention and listing rules, the German Foreign Trade and Payments Act/Ordinance (AWG/AWV), as well as relevant national provisions of the Partner’s country.

3. Definitions

• Sanctioned Territories: The Russian Federation, the Republic of Belarus, as well as EU-sanctioned occupied/annexed Ukrainian territories.
• Sanctioned Persons/Entities: Persons/entities listed on EU sanctions lists, as well as companies owned/controlled by them or acting on their behalf.
• Re-export/Onward Supply: Any transfer to third parties, including transit/transshipment, integration into products, technical support, and provision of software/technology.
• Circumvention: Actions that evade sanctions (e.g., concealment of end-use/end-user, use of third countries/shell companies).

4. Core Principles “No-Russia & No-Belarus”

1. Absolute Prohibition: No direct/indirect delivery, provision, use, or support in or for the benefit of Russia or Belarus, or for end-users/end-uses located there.
2. No dealings with listed parties or companies controlled by listed parties.
3. No military or sanctions-relevant dual-use end-use, where applicable.
4. No circumvention via third countries, free zones, sham transactions, or false/incomplete documentation.

5. Partner Obligations

1. Transparency & Cooperation: Partner discloses end-users, end-use, destination country/location, transport route, and intermediaries, and keeps such information up to date.
2. Screening & Documentation: Partner performs sanctions and ownership/control (UBO) checks and retains evidence for 10 years.
3. End-Use Certification: Partner obtains end-use statements from its customers and provides them to Steinberg GmbH upon request.
4. Flow-down: Partner contractually binds all customers/agents in writing to equivalent No-Russia/No-Belarus requirements, including audit, documentation, and sanctions provisions.
5. Notification Duty: Partner promptly informs Steinberg GmbH of red flags, listed owners/UBOs, authority inquiries, or suspected cases.

6. Steinberg GmbH Due Diligence

Steinberg GmbH operates an internal compliance program (ICP) with risk-based classification, list screening, end-user/end-use checks, documentation (10 years), and training. Deliveries may be suspended/declined until completion of the checks.

7. Licenses and Legal Changes

Deliveries are subject to required licenses and the applicable legal situation. In case of legal changes/authority measures, Steinberg GmbH may modify, suspend, or terminate deliveries. Claims for delay/non-performance do not exist, except in cases of intent or gross negligence by Steinberg GmbH.

8. Audit & Information

Steinberg GmbH is entitled, upon reasonable notice, to conduct audits (remote/on-site) at Partners and relevant subcontractors or have them conducted. Partner grants access to relevant documents (orders, invoices, shipping/customs documents, screening records, end-use statements).

9. Breach and Sanctions

1. Contractual Penalty: In case of breaches of Sections 4–8, the Partner owes an appropriate contractual penalty (Sec. 339 German Civil Code) per breach; Steinberg GmbH determines the amount at its reasonable discretion (Sec. 315 German Civil Code). Guideline: EUR 100,000 per breach or—if higher—5% of the net annual revenue from the affected Deliverables. Further claims remain unaffected.
2. Indemnification: Partner indemnifies Steinberg GmbH against fines, damages, and costs (including legal enforcement) arising from Partner breaches (including the flow-down chain).
3. Termination: In the event of material breaches, Steinberg GmbH may terminate affected contracts with immediate effect and suspend ongoing deliveries.

10. Data Protection & Confidentiality

Audit-related information is confidential. Personal data is processed only to the extent necessary and in accordance with applicable data protection law.

11. Governing Law, Venue, Order of Precedence

German law applies, excluding the UN Convention on Contracts for the International Sale of Goods (CISG). The place of jurisdiction (where permissible) is Meonchengaldbach, Germany. This policy prevails over conflicting contractual provisions insofar as sanctions/export control issues are concerned.

12. Amendments & Versioning

Steinberg GmbH may adapt this policy to the legal situation. The version published at https://steinberg.gmbh/en/no-russia/ at the time of the respective delivery/onward supply is authoritative. Earlier versions can be provided upon request.

13. Sample Red Flags (Excerpt)

• Unclear/changing end-users or atypical third-country routes (e.g., EAEU, Caucasus, Central Asia, Gulf, Eastern Balkans).
• Payments from third parties/offshore entities without objective reason; “neutral” packaging/labels; concealment of serial numbers.
• Urgent orders for dual-use-adjacent goods without a plausible need.
• Negative press, authority inquiries, indications of listed UBOs.