Restricted Use Policy

Restricted End-Use, Export Control and Sanctions Policy

Last updated: 2 July 2026

1. Introduction

This Restricted End-Use, Export Control and Sanctions Policy (“Policy”) applies to all products, components, equipment, accessories, software, technology, technical information and related services supplied by Holybro (“Holybro”, “we”, “us” or the “Seller”).

In this Policy:

  • “Customer”, “Buyer” or “you” means the person or organisation purchasing, receiving, possessing or using a Product;
  • “Product” means any product, component, software, technology, documentation or service supplied by Holybro;
  • “End User” means the person or organisation that will ultimately possess, operate, use or benefit from a Product; and
  • “Applicable Trade Laws” means all export-control, import-control, sanctions, customs, anti-terrorism and trade-control laws that apply to the relevant transaction.

By placing an order, purchasing a Product, accepting delivery or accepting this Policy at checkout, the Customer confirms that it has read, understood and agreed to comply with this Policy.

This Policy forms part of Holybro’s Terms and Conditions of Sale.

2. Civilian Use Only

Unless Holybro expressly agrees otherwise in writing, all Products are supplied solely for lawful civilian purposes.

The Customer must not use, supply, resell, transfer, modify or incorporate a Product for any prohibited military, weapons-related or combat-related purpose described in this Policy.

The fact that a Product is commercially available, not specifically designed for military use or not listed as a controlled strategic commodity does not remove the restrictions imposed by this Policy.

3. Prohibited Weapons and Military End Uses

The Customer must not, directly or indirectly, use, develop, modify, configure, integrate, sell, supply, transfer, lease, loan, gift or otherwise make a Product available for:

3.1 Weapons and weapon systems

  • Firearms, guns, cannons, ammunition or other weapons;
  • Missiles, rockets, bombs, torpedoes, mines or explosive devices;
  • Chemical, biological, radiological or nuclear weapons;
  • Weapon launch, delivery, release or firing systems;
  • Armed or weaponised drones, aircraft, vehicles, vessels or robots; or
  • Any component, subsystem or accessory specifically intended for a weapon or weapon system.

3.2 Targeting and guidance systems

  • Identifying, detecting, locating, selecting, tracking or designating targets for weapons use;
  • Fire-control or combat-control systems;
  • Guidance, navigation or control of missiles, bombs, ammunition or other weapons;
  • Ballistic calculation or weapons-aiming systems;
  • Systems used to coordinate or automate an armed attack; or
  • Artificial intelligence, computer vision or autonomous technology intended to identify or engage targets for weapons use.

3.3 Military platforms and operations

  • Military drones or unmanned aerial vehicles;
  • Military unmanned ground or surface vehicles;
  • Military robots or autonomous combat systems;
  • Military aircraft, vessels, vehicles or command-and-control systems;
  • Combat, battlefield or military operational activities;
  • Military surveillance, reconnaissance or intelligence activities intended to support combat operations; or
  • Defence contracting involving a prohibited military or weapons-related application.

3.4 Armed groups

  • Training, recruitment, financing or logistical support for an armed group;
  • Supporting a militia, mercenary organisation, terrorist organisation or unlawful armed organisation;
  • Transporting weapons, ammunition or military personnel;
  • Operating or maintaining a prohibited military system; or
  • Facilitating armed conflict or violent activity.

These prohibitions apply whether the Product is used alone or incorporated into another product, platform, system or service.

4. Prohibited End Users

Products must not be sold, supplied, transferred or otherwise made available, directly or indirectly, to:

  • A person or organisation involved in a prohibited activity described in Section 3;
  • A sanctioned or designated person, organisation, vessel or entity;
  • A person or entity owned or controlled by, acting for, or acting on behalf of a restricted party;
  • A terrorist organisation, militia, mercenary organisation or unlawful armed group;
  • A person attempting to conceal the identity of the true purchaser, consignee or End User;
  • A person providing false, incomplete or misleading information regarding the intended use or destination; or
  • Any person where the transaction would breach Applicable Trade Laws.

The Customer must not proceed with a transaction where it knows, suspects or has reasonable grounds to believe that the recipient or End User is prohibited under this Section.

5. Holybro Restricted Destinations

As a matter of Holybro’s commercial policy, Holybro does not sell or authorise the supply of Products where the Customer, consignee, End User or final delivery destination is located in:

  • Iran;
  • North Korea;
  • Russia;
  • Belarus;
  • Cuba;
  • Syria;
  • Sudan; or
  • Any territory of Ukraine occupied or controlled by the Russian Federation.

This restriction applies even where a particular sale might not otherwise be expressly prohibited under Hong Kong law.

Products must not be routed through another country, intermediary, freight forwarder, reseller or third party for the purpose of avoiding this restriction.

Holybro may add, remove or amend restricted destinations to reflect changes in law, risk, supplier requirements or company policy. The version of this Policy in effect when an order is placed will apply to that order.

6. Sanctions Compliance

The Customer must comply with all sanctions and restrictions applicable to the transaction, including sanctions implemented in Hong Kong under the United Nations Sanctions Ordinance (Cap. 537) and its subsidiary legislation.

The Customer must not engage in a transaction involving:

  • A person, entity, vessel or organisation subject to applicable sanctions;
  • Property or economic resources owned or controlled by a sanctioned person;
  • A prohibited destination, industry, activity or End User;
  • The provision of prohibited financial, technical, transport or other assistance; or
  • An arrangement intended to avoid or circumvent applicable sanctions.

Other jurisdictions’ laws may apply because of the Product’s origin, destination, technology, currency, payment route, Customer, End User or other connection to the transaction. The Customer is responsible for identifying and complying with any such laws that apply to it or the transaction.

A reference to sanctions imposed by another jurisdiction does not mean that all sanctions imposed by that jurisdiction automatically apply under Hong Kong law.

7. Strategic Commodities and Export Controls

Certain Products, components, software or technologies may be classified as strategic commodities or otherwise be subject to import, export, re-export, transshipment, transit or transfer controls.

Where applicable, the Customer must comply with:

  • The Import and Export Ordinance (Cap. 60);
  • The Import and Export (Strategic Commodities) Regulations (Cap. 60G);
  • Applicable licence conditions;
  • Destination-country import requirements;
  • Re-export restrictions applicable to the Product; and
  • Other mandatory trade-control requirements applicable to the transaction.

The Customer must not export, re-export, transship, place in transit, transfer or deliver a controlled Product without all required licences, permits and approvals.

Each party is responsible for obtaining the licences, permits and approvals that it is legally required to obtain.

A Customer must not assume that a Product is uncontrolled merely because:

  • It is available for purchase online;
  • It is described as a civilian or commercial product;
  • Holybro has previously supplied a similar Product;
  • It is being exported temporarily;
  • It is being carried by hand or personal luggage; or
  • It is being shipped through Hong Kong rather than delivered in Hong Kong.

Where the classification or licensing status of a Product is uncertain, the Customer must not export, re-export or transfer it until the relevant requirements have been confirmed.

8. No Diversion or Circumvention

The Customer must not attempt to avoid this Policy or Applicable Trade Laws by:

  • Using a reseller, distributor, agent, broker or intermediary;
  • Providing a false billing, shipping or End User address;
  • Misdescribing a Product, its value, its intended use or its destination;
  • Splitting an order into smaller transactions;
  • Routing Products through an unrelated country or territory;
  • Using another person or organisation as the nominal purchaser;
  • Removing, altering or concealing labels, serial numbers or documentation;
  • Using a freight forwarder to conceal the final destination or End User; or
  • Taking any other action intended to disguise the true nature of a transaction.

Holybro may treat unusual routing, inconsistent documentation, unexplained third-party payments or reluctance to provide End User information as compliance concerns.

9. Customer Representations and Warranties

The Customer represents, warrants and undertakes that:

  • All information provided to Holybro is complete, accurate and not misleading.
  • The Customer has disclosed the true purchaser, consignee, End User, destination and intended use.
  • The Products will be used solely for lawful civilian purposes and not for a prohibited use described in this Policy.
  • Neither the Customer nor, to the Customer’s knowledge, the consignee or End User is a sanctioned or prohibited party.
  • The Products will not be delivered to a Holybro Restricted Destination.
  • The Customer will not resell, export, re-export or transfer the Products in breach of this Policy or Applicable Trade Laws.
  • The Customer will obtain all licences, permits, consents and approvals legally required of it.
  • The Customer is not purchasing on behalf of an undisclosed third party.
  • The Customer will not conceal or misrepresent the final destination or intended use.
  • The Customer will notify Holybro immediately if any information provided in connection with an order changes or becomes inaccurate.

These representations are repeated when the Customer places each order, accepts each delivery and subsequently resells or transfers a Product.

10. Resellers, Distributors and Other Transfers

A Customer that resells, distributes or transfers Products must:

  • Conduct reasonable due diligence concerning each purchaser, recipient, consignee and End User;
  • Verify the intended use and final destination;
  • Screen relevant parties against applicable sanctions and restricted-party lists;
  • Communicate restrictions equivalent to this Policy to the subsequent recipient;
  • Prohibit further transfer for weapons, military or other restricted uses;
  • Obtain any required export, import, transshipment or transfer licences;
  • Take reasonable steps to prevent diversion or circumvention;
  • Keep appropriate transaction and due-diligence records; and
  • Stop a transaction where a compliance concern cannot be reasonably resolved.

The Customer must not rely solely on a recipient’s verbal statement where the circumstances indicate a possible restricted use, End User or destination.

The Customer remains responsible for the conduct of its employees, agents, contractors, representatives, resellers and other persons acting on its behalf.

11. Due Diligence and Records

The Customer must conduct due diligence appropriate to the nature and risk of the transaction.

This may include checking:

  • The identity and ownership of the recipient;
  • The recipient’s business activities;
  • The final End User;
  • The intended civilian application;
  • The delivery destination;
  • The shipping route;
  • The source and method of payment;
  • Whether the quantity ordered is consistent with the stated use; and
  • Whether the Product is suitable for the stated civilian application.

Business Customers and Customers reselling Products must retain relevant compliance records for at least five years following the transaction, or longer where required by applicable law.

Records should include, where applicable:

  • Invoices and order records;
  • Shipping and delivery documents;
  • End-user or end-use statements;
  • Screening results;
  • Licences and permits;
  • Customer communications;
  • Technical descriptions; and
  • Records of any compliance concern and how it was resolved.

12. Information and Verification Requests

Holybro may request information and documentation before or after accepting an order, including:

  • Personal or business identification;
  • Company registration and ownership information;
  • The identity of the ultimate beneficial owner;
  • The name and address of the consignee and End User;
  • The final destination;
  • A description of the intended civilian use;
  • An End User or End Use Certificate;
  • Import or export licences;
  • Purchase orders or supply contracts;
  • Technical information concerning the proposed system;
  • Photographs or diagrams showing the proposed installation; and
  • Evidence of sanctions or restricted-party screening.

The Customer must respond promptly and provide complete and accurate information.

Holybro is not required to process or fulfil an order until it is satisfied that the transaction complies with this Policy and applicable law.

Providing information does not guarantee that an order will be accepted.

13. Right to Refuse, Suspend or Cancel

Holybro may refuse, suspend, place on hold or cancel an order where it knows, suspects or reasonably believes that:

  • A Product may be intended for a prohibited use;
  • The Customer, consignee or End User may be prohibited or sanctioned;
  • The destination may be restricted;
  • Required information has not been provided;
  • Information appears false, incomplete or inconsistent;
  • A required licence or approval has not been obtained;
  • The transaction presents an unacceptable diversion or compliance risk;
  • Processing the order may breach a supplier restriction;
  • Processing the order may expose Holybro to legal or regulatory risk; or
  • The transaction may otherwise breach this Policy.

Holybro may take these actions before or after accepting payment and before dispatch or delivery.

Where an order is cancelled, Holybro will return amounts paid for undelivered Products, except where:

  • A refund is prohibited or restricted by law;
  • Funds are frozen or otherwise legally restricted;
  • The Customer has engaged in fraud or unlawful conduct; or
  • Holybro is legally entitled to deduct reasonable, non-recoverable costs.

Holybro may decline to provide detailed reasons for its decision where disclosure may be prohibited by law or could compromise its compliance procedures.

14. Reporting and Cooperation with Authorities

Holybro may retain information, block a transaction or make a report to a government, regulatory, customs, law-enforcement or other competent authority where required or permitted by law.

The Customer agrees to cooperate with lawful compliance enquiries concerning a Product, transaction, destination or End User.

Nothing in this Policy requires Holybro to notify the Customer before making a legally required or permitted report.

15. Breach of This Policy

A breach of this Policy constitutes a material breach of the Customer’s contract with Holybro.

Following an actual or suspected breach, Holybro may:

  • Cancel or suspend pending orders;
  • Refuse future orders;
  • Suspend or close the Customer’s account;
  • Terminate the business relationship;
  • Stop further deliveries;
  • Require the return of undelivered Products where legally permitted;
  • Notify relevant suppliers, payment providers or authorities;
  • Seek an injunction or other court order; or
  • Pursue compensation for losses caused by the breach.

These remedies are cumulative and do not limit any other legal or contractual right available to Holybro.

16. Business Customer Indemnity

Where the Customer purchases Products in the course of a trade, business or profession, the Customer agrees, to the maximum extent permitted by law, to indemnify Holybro and its directors, officers, employees and agents against third-party claims, regulatory penalties, losses, damages and reasonable legal costs arising from:

  • The Customer’s breach of this Policy;
  • A false, inaccurate or misleading statement made by the Customer;
  • The Customer’s failure to obtain a required licence or approval;
  • A prohibited resale, export, re-export or transfer;
  • A prohibited End User, end use or destination; or
  • The conduct of a person acting on the Customer’s behalf.

This indemnity does not apply to the extent that a loss was caused by Holybro’s fraud, wilful misconduct or liability that cannot lawfully be excluded.

For Customers purchasing wholly or mainly for personal use, liability will be determined in accordance with applicable law and Holybro’s Terms and Conditions of Sale.

17. No Limitation of Mandatory Rights

Nothing in this Policy excludes, restricts or limits:

  • A right or remedy that cannot lawfully be excluded;
  • Holybro’s obligation to comply with applicable law;
  • The Customer’s mandatory consumer rights; or
  • Liability that cannot lawfully be limited.

18. Changes to This Policy

Holybro may update this Policy to reflect:

  • Changes in law or regulation;
  • Changes to sanctions or export controls;
  • Supplier or manufacturer requirements;
  • Changes in restricted destinations;
  • New compliance risks; or
  • Changes to Holybro’s business practices.

The Policy version accepted when an order is placed will apply to that order, unless a later change must apply by law.

An updated Policy will apply to orders placed after its stated effective date.

19. Relationship with Other Terms

This Policy forms part of Holybro’s Terms and Conditions of Sale.

Where there is a conflict:

  • Mandatory applicable law will take priority;
  • A valid export licence or governmental authorisation will apply only within its stated scope and will not override Holybro’s voluntary commercial restrictions unless Holybro agrees in writing; and
  • This Policy will take priority over inconsistent marketing materials, informal communications or product descriptions concerning restricted use.

Approval of one transaction does not constitute approval of a later transaction or a waiver of this Policy.

20. Severability and No Waiver

If any provision of this Policy is held to be invalid, unlawful or unenforceable, that provision will be applied or modified to the minimum extent necessary, and the remaining provisions will continue in effect.

Holybro’s failure or delay in enforcing a provision does not waive its right to enforce that provision later.

21. Governing Law

This Policy is governed by the same law and dispute-resolution provisions that apply under Holybro’s Terms and Conditions of Sale.

Where the Terms and Conditions of Sale do not specify a governing law, this Policy is governed by the laws of the Hong Kong Special Administrative Region.

Nothing in this Section overrides mandatory consumer-protection or other laws that must apply to a particular Customer or transaction.

22. Contact

Questions concerning an intended use, End User, destination, export classification or other compliance matter must be submitted to Holybro before an order is placed or a Product is transferred.

Customers should use the contact details published on Holybro’s Contact Us page.

A request for guidance does not constitute approval. Any approval must be expressly provided by an authorised representative of Holybro in writing.