1. Policy Statement

Business Together Limited (company registration number 9593738), trading as BTLITC, is committed to full compliance with all applicable sanctions laws and regulations and export control requirements. We will not engage in any business activities or transactions that are prohibited by applicable sanctions or export control regimes, regardless of the commercial opportunity involved.

This policy applies to all BTLITC directors, employees, contractors, agents, and other persons acting on our behalf.

2. Applicable Regimes

BTLITC operates primarily in the United Kingdom and is subject to:

UK financial sanctions administered by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury
Export control licensing requirements under the Export Control Act 2002 and associated legislation administered by the Export Control Joint Unit (ECJU)
United Nations Security Council sanctions
Where relevant to our clients, operations, or partners: EU, US OFAC, and other international sanctions and export control regimes

3. Prohibited Activities

BTLITC will not:

provide services, technology, or software to any sanctioned individual, entity, or jurisdiction
facilitate transactions that breach applicable sanctions
export, re-export, or transfer controlled goods, software, or technology without obtaining the required export licences
take steps to circumvent, evade, or facilitate the circumvention of applicable sanctions or export controls
engage any sub-contractor, agent, or partner whom we know or suspect to be subject to sanctions

4. Screening and Due Diligence

Before entering into any new business relationship, and periodically for existing relationships, BTLITC conducts screening against:

HM Treasury Consolidated List of Financial Sanctions Targets
Relevant international sanctions lists (UN, EU, OFAC) where business activity warrants it

We maintain records of screening checks conducted and their outcomes. Where a match or potential match is identified, the matter is escalated to the Managing Director before any engagement proceeds.

5. Technology and Software Controls

Given the nature of our services (IT infrastructure, cybersecurity, cloud, and AI solutions), BTLITC recognises that certain technology and software products we use, supply, or develop may be subject to export controls. Where this is the case:

we will identify the relevant export control classification
we will obtain the necessary licences before any export or re-export takes place
we will comply with all end-use and end-user conditions attached to any licences granted

Any uncertainty about whether a product, service, or technology is subject to export controls must be escalated to the Managing Director before proceeding.

6. Responsibilities

The Managing Director holds overall accountability for sanctions and export control compliance. All personnel must:

complete relevant training as required
immediately report any suspected breach, red flag, or request to engage in a prohibited transaction
not proceed with a transaction where there is any doubt about its compliance until cleared by a director

7. Reporting

Any concerns about potential sanctions or export control breaches must be reported immediately to the Managing Director or by email to [email protected].

BTLITC will not retaliate against any individual who raises concerns in good faith. Reports may also be made to OFSI (for sanctions matters) or the ECJU (for export control matters) as required by law.

8. Record Keeping

Records of screening checks, export licence applications and decisions, and any compliance assessments are retained for a minimum of 7 years, in line with HMRC and ECJU requirements.

9. Consequences of Breach

Breach of sanctions or export control requirements can result in criminal prosecution, significant fines, and reputational damage for both the company and the individuals involved. Any breach of this policy by an employee may result in disciplinary action including dismissal.

BTLITC will cooperate fully with any investigation by OFSI, the ECJU, or any other relevant authority.

10. Review

This policy is reviewed annually or whenever there are material changes to applicable legislation or to our business activities. All personnel will be notified of any material changes.

11. Contact

Business Together Limited (trading as BTLITC)
Oak House, Central Park, Reeds Crescent, Watford, WD24 4QN
Email: [email protected]
Phone: +44 1923 751 624
Company Registration: 9593738 | VAT Number: 306383317

Sanctions and Export Control Policy