Legal
Annex C — Export Control, Sanctions and Compliance
Version 2.0 · As of: June 2026 · Annex to the AEB
Working English translation — provided for convenience only and not yet legally reviewed. The legally binding version is the German original; a final reviewed English version will follow.
§ 1 Purpose and Scope
1. This Annex C governs supplementary requirements regarding export control, customs, sanctions, embargoes, origin, preference and compliance for deliveries and services to DubbeDynamics.
2. It applies to goods, software, technology, technical support, documentation, spare parts, components, engineering and service performances, insofar as these may be relevant across borders or have export-control, customs or sanctions-law implications.
3. The Contractor remains responsible for compliance with the regulations applicable to it, its performance and its supply chain.
§ 2 Export-Control and Sanctions Obligations
1. The Contractor warrants compliance with all applicable export-control, customs, embargo, sanctions and foreign-trade regulations, including regulations of the European Union, Germany, the USA and other relevant jurisdictions, to the extent applicable.
2. The Contractor may not provide, forward, procure or make available any services if this would breach applicable sanctions, embargoes, export bans, re-export bans or authorisation requirements.
3. The Contractor must establish appropriate review processes to identify sanctions- and export-control risks regarding its own organisation, subcontractors, sub-suppliers, goods, software, technology and end use.
§ 3 Information and Notification Obligations
1. The Contractor must inform DubbeDynamics in writing, at the latest upon acceptance of the order, whether the deliveries or services are subject to export restrictions, authorisation requirements, dual-use regulations, re-export restrictions, US-origin content or other foreign-trade restrictions.
2. Required details include in particular the customs tariff number, goods description, country of origin, preferential origin, supplier declaration, export-control classification, ECCN, export-list number, dual-use relevance and other details required for import, export, re-export and transfer.
3. If export-control, customs or sanctions-relevant details change after acceptance of the order, the Contractor must inform DubbeDynamics without undue delay.
§ 4 End Use, End User and Sanctions
1. The Contractor must inform DubbeDynamics without undue delay if it becomes aware of indications that deliveries or services may be intended for an impermissible end use, a sanctioned end user, an embargoed country or another legally problematic use.
2. The Contractor warrants that, to its knowledge, it, its legal representatives, beneficial owners and significant participating subcontractors are not listed on relevant sanctions lists, insofar as this check is legally permissible and reasonable.
3. DubbeDynamics is entitled to suspend orders, reject deliveries, withhold payments, request information or rescind the contract insofar as legal or factual sanctions or export-control risks exist.
§ 5 Customs, Origin and Preference
1. The Contractor must provide correct and complete customs- and origin-relevant details. These include in particular the HS code, country of origin, preferential origin, supplier declarations, long-term supplier declarations and other proof of origin.
2. Incorrect or incomplete customs, origin or preference details give rise to an obligation of the Contractor to compensate for resulting duties, taxes, charges, fines, delays, storage costs, legal costs and other damages.
3. The Contractor must reasonably support DubbeDynamics in customs, origin or export-control reviews and in inquiries from authorities, customers or inspection organisations.
§ 6 Compliance, Anti-corruption and Business Ethics
1. The Contractor undertakes to act lawfully, with integrity and ethically. It must comply in particular with anti-corruption, antitrust, anti-money-laundering, tax, foreign-trade, labour, social, environmental and human-rights regulations.
2. Undue advantages, bribes, active and passive corruption, kickbacks, hidden commissions or other unlawful benefits are prohibited.
3. In the case of concrete indications of compliance violations in connection with performance, the Contractor must inform DubbeDynamics without undue delay and initiate appropriate remedial measures.
§ 7 Indemnification and Legal Consequences
1. The Contractor indemnifies DubbeDynamics against all claims, damages, fines, costs, delays and other disadvantages arising from a breach by the Contractor of this Annex or applicable export-control, customs, sanctions or compliance regulations.
2. DubbeDynamics is entitled to terminate or rescind contracts for good cause if performance would breach applicable regulations or the Contractor fails to provide required information.
3. Further statutory and contractual rights of DubbeDynamics remain unaffected.
Appendix C.1 — Minimum Supplier Information
HS code: customs tariff number per item — at the latest with the order confirmation.
Country of origin: non-preferential origin — at the latest with delivery.
Preference: supplier declaration if applicable — before invoice release / if agreed.
Export classification: ECCN/export-list/dual-use information — at the latest with the order confirmation.
Sanctions risk: notification of hits/concerns — without undue delay.