Dual-use & export control policy

Terravek sells for civil applications only. This is a constraint we apply and enforce, not a statement of preference, and we have lost revenue to it.

What we will not do

• Supply products or services for military, intelligence or targeting purposes.
• Accept acquisition requests whose purpose is the surveillance of individuals, groups or their movements.
• Supply to any party subject to EU, Dutch, UK or US sanctions, or to an end user we assess as likely to transfer to one.
• Build capability whose primary application we assess as harmful, even where a civil use exists. Our research ethics review has deferred two projects and declined one on this basis.

How requests are screened

1. Automated screening of every new customer and every tasking request against sanctions and denied-party lists at onboarding and continuously thereafter.
2. End-use declaration for all new contracts, stating the intended application.
3. Referral of anything ambiguous to the dual-use review, chaired jointly by the General Counsel (Owen Radcliffe) and the Chief Scientific Officer (Dr. Élodie Marchand). The two chairs are deliberately shared with the research ethics review, so that a capability declined in research does not arrive later as a customer request.
4. Escalation to the Executive Board where the review cannot reach a conclusion, and to the Supervisory Board where the decision is material.

Grey areas we have thought about

Public safety. We supply the Colorado Wildfire Resilience Office and similar civil protection bodies. Disaster response and civil protection are civil applications and we support them actively.

Critical national infrastructure. We supply utilities and rail infrastructure managers, including where those are state-owned. Maintaining infrastructure is a civil application; hardening it against attack as part of a defence programme is not, and we have declined on that boundary.

Border and coastal monitoring. We supply coastal monitoring for flood risk and navigation safety. We do not supply for the detection or interception of people, and we have declined two tenders on this basis — one in 2021 and one in 2024.

Dual-use by publication. Terravek Labs publishes openly, and published methods can be applied by anyone. We accept this and consider open publication the correct default; the ethics review may defer publication where the assessment differs, and has done so twice.

Export control

Terravek's software and imagery products are, in our assessment, not controlled under EU Regulation 2021/821 in their standard configuration. Certain FIELDKIT and Photonwerk optical components are controlled, and their export is licensed accordingly. Customers are responsible for compliance with their own jurisdiction's rules on re-export.

Raising a concern

If you believe a Terravek product is being used contrary to this policy, tell us. Write to ethics@terravek.com or legal@terravek.com, or use the whistleblowing channel if you would rather be anonymous. Reports from outside the company are treated the same as reports from inside it.