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Syncrosis

Client Exclusion Policy

Effective Date: 08/09/2024

Introduction:

Syncrosis, in its capacity as a global provider in technology consulting and intelligence services, is committed to adhering strictly to all relevant UK legal frameworks, international treaties, and global best practices. This policy sets forth the criteria by which Syncrosis excludes individuals, entities, and nation states from potential business engagements, ensuring full compliance with the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), UK Bribery Act 2010, General Data Protection Regulation (GDPR), and other applicable laws.

This exclusion policy is binding for all employees, contractors, and affiliates of Syncrosis and will be regularly updated in response to changes in law or geopolitical conditions. Failure to comply with this policy will result in legal action, including the immediate cessation of any existing or prospective business relationships.


1. Sanctioned Countries and Entities

Syncrosis shall not engage in any business relationship, direct or indirect, with entities or individuals residing in or subject to the jurisdiction of countries or regions that are under sanctions imposed by the following authorities:

  • The United Nations Security Council (UNSC)
  • The European Union (EU) Council Regulations
  • The United Kingdom Office of Financial Sanctions Implementation (OFSI)
  • The United States Office of Foreign Assets Control (OFAC)
  • Any other relevant sanctioning bodies or regimes with which the UK Government maintains a cooperative agreement

Sanctioned Countries:
Syncrosis will not engage with entities from the following countries currently under comprehensive sanctions, including but not limited to:

  • Democratic People's Republic of Korea (North Korea)
  • Islamic Republic of Iran (Iran)
  • Syrian Arab Republic (Syria)
  • Republic of Belarus (Belarus)
  • Russian Federation (Russia)
  • Republic of Venezuela (Venezuela)
  • Republic of Cuba (Cuba)
  • South Sudan
  • Eritrea
  • Sudan

These restrictions extend to entities that are domiciled in, controlled by, or operating within the aforementioned jurisdictions, as well as any individuals or organisations appearing on sanctions lists such as:

  • The UK Consolidated List of Financial Sanctions Targets
  • OFAC's Specially Designated Nationals and Blocked Persons List (SDN List)
  • EU Consolidated Sanctions List

Syncrosis conducts enhanced due diligence to ensure full compliance with these sanctions, and any identified breaches will result in immediate termination of business relations, with potential for legal recourse.


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2. Strategic Adversaries of NATO

Syncrosis shall not engage with any entities or individuals domiciled in, aligned with, or associated with strategic adversaries of the North Atlantic Treaty Organisation (NATO), as determined by UK defence policies and NATO Strategic Concept. This includes:

  • The Russian Federation, as a result of ongoing hostilities with NATO-aligned states and annexation of foreign territories.
  • The Islamic Republic of Iran, due to its nuclear proliferation activities and aggressive military posture towards NATO allies.
  • The Syrian Arab Republic, for its continued violation of international humanitarian law and alignment with NATO adversaries.
  • Any other entities or states classified as adversarial under NATO’s defence strategy, such as those supporting terrorist organisations or actively undermining NATO’s geopolitical interests.

Syncrosis also refrains from any engagement with defence or intelligence contractors that operate in or provide services to these adversarial states. Additionally, entities aligned with the Collective Security Treaty Organisation (CSTO) are excluded.


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3. China and China-Aligned Entities

Syncrosis prohibits any engagement with the People’s Republic of China (PRC) and entities aligned with or controlled by the Chinese Communist Party (CCP). This exclusion extends to:

  • Businesses domiciled in or controlled by the PRC or any territories aligned with the CCP, including Hong Kong and Macau, if subject to PRC influence.
  • Entities complicit in human rights violations under the Uyghur Forced Labor Prevention Act (UFLPA) and those involved in the systematic exploitation of Uyghur Muslims in the Xinjiang region.
  • Organisations engaged in cyber espionage, intellectual property theft, or state-sponsored cyberattacks targeting the UK or allied interests, as covered under the UK National Security and Investment Act 2021.

Syncrosis also applies enhanced cybersecurity protocols to prevent the leakage of sensitive data or intellectual property to PRC-aligned actors, and actively monitors for state-sponsored intrusions into its supply chain and partner networks.


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4. Human Rights Violations and Ethical Standards

Syncrosis adheres to the highest standards of human rights protection and refuses to engage with entities that are complicit in, or benefit from, human rights violations. This includes:

  • Organisations involved in terrorism, pursuant to the UK Terrorism Act 2000 and Counter-Terrorism and Security Act 2015.
  • Entities engaged in crimes against humanity, including genocide, enslavement, torture, and enforced disappearances, as defined by the Rome Statute of the International Criminal Court (ICC).
  • Companies exploiting forced labour, child labour, or modern slavery, in violation of the UK Modern Slavery Act 2015 and ILO Forced Labour Conventions (No. 29).

Entities found to be on the Global Magnitsky Sanctions List, or those implicated in human rights abuses under the Uyghur Forced Labor Prevention Act, will not be considered for any business dealings. Syncrosis conducts ongoing due diligence on partners to ensure their supply chains are free from human rights abuses.


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5. Financial Crimes and Corporate Governance

In line with the UK Bribery Act 2010, Anti-Money Laundering (AML) Regulations 2017, and Proceeds of Crime Act 2002, Syncrosis will not engage with entities or individuals convicted of:

  • Money laundering, bribery, fraud, tax evasion, or embezzlement.
  • Entities or individuals under active investigation for financial crimes or those listed by the Financial Conduct Authority (FCA) or Financial Action Task Force (FATF).

All prospective partners must meet strict corporate governance standards as defined in the UK Companies Act 2006. Any company exhibiting corrupt practices, opaque financial reporting, or governance failures will be excluded from potential partnerships.


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6. Data Privacy Compliance

Syncrosis maintains full compliance with the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018. Syncrosis will not engage with any entities or individuals found to be in violation of:

  • GDPR, including unlawful data processing, failure to safeguard personal data, or involvement in significant data breaches.
  • The Computer Misuse Act 1990, specifically those engaged in cyber espionage, hacking, or other forms of cybercrime.

Syncrosis actively implements ISO/IEC 27001 Cybersecurity Standards and the Cybersecurity Maturity Model Certification (CMMC) for its partners, ensuring that all business engagements meet stringent cybersecurity standards.


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7. Supply Chain Integrity and Labour Practices

Syncrosis applies rigorous supply chain audits to ensure compliance with the UK Modern Slavery Act 2015 and International Labour Organization (ILO) conventions. Syncrosis prohibits engagement with any entities or individuals involved in:

  • Forced labour, child labour, or other forms of exploitative labour practices. This includes violations under the ILO Forced Labour Convention No. 29 and the ILO Worst Forms of Child Labour Convention No. 182.
  • Unethical supply chain management that does not comply with the UK Modern Slavery Act 2015 or standards imposed by international labour organisations, such as the Fair Labour Association (FLA) or the Ethical Trading Initiative (ETI).
  • Businesses or individuals listed on the US Department of Labor's List of Goods Produced by Child or Forced Labor, or any entities engaged in the illegal exploitation of workers in developing countries.

Syncrosis ensures that all partners and vendors adhere to ethical labour standards by conducting regular reviews of supply chains, including the enforcement of binding contracts that specify adherence to these standards. Any breach of this clause will result in immediate contract termination and may be reported to relevant regulatory bodies.


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8. Technological Compliance and Standards

Syncrosis strictly enforces technological compliance across its supply chain, ensuring adherence to internationally recognised cybersecurity standards. We will not engage with any organisation that:

  • Fails to meet security standards as defined by ISO/IEC 27001, ISO/IEC 27002, or other relevant frameworks, particularly in industries critical to national security or data protection.
  • Is involved in cyber espionage, intellectual property theft, or hacking, in violation of the Computer Misuse Act 1990.
  • Has been implicated in cybersecurity breaches that have exposed sensitive data, particularly in relation to critical infrastructure sectors, as outlined by the UK National Cyber Security Centre (NCSC).
  • Fails to comply with the Cybersecurity Maturity Model Certification (CMMC) or equivalent standards for securing sensitive information.

Syncrosis conducts periodic cybersecurity audits on all business partners to ensure full compliance with these standards. Any failure to meet these standards will result in exclusion from further engagements, as well as potential legal action if breaches result in harm to Syncrosis or its clients.


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Enforcement and Legal Compliance

This Client Exclusion Policy is enforced under UK, EU, and US law. Syncrosis undertakes regular due diligence and legal audits to ensure compliance with this policy. Failure to adhere to the exclusion criteria set forth in this document will result in:

  1. Immediate cessation of business relations with the non-compliant entity or individual.
  2. Potential legal action under applicable UK or international laws, including but not limited to sanctions, financial penalties, and civil litigation.

Syncrosis reserves the right to amend this policy in accordance with updates to UK, EU, and US legislation, international treaties, or other legal obligations. Amendments will be communicated to all relevant stakeholders and partners, and continued business engagements will be contingent on adherence to the revised policy.