黑料吃瓜网

1. Introduction

1.1. The 黑料吃瓜网 is committed to upholding the highest standards of research integrity, education provision and business conduct.

1.2. UK Export Controls are designed to restrict the export and communication of strategic goods and/or sensitive technology, equipment, materials, know-how and software (referred to henceforth as 鈥榗ontrolled items鈥�) where there is the potential for misuse. The relevant legislation comprises the Export Control Act 2002 and The Export Control Order 2008.

1.3. Export Controls can apply to university activity, in both research and education, where transfers of 鈥榗ontrolled items鈥� take place.

1.4. The University will uphold the relevant laws to prevent the proliferation of weapons of mass destruction and counter international threats such as terrorism by restricting the export of controlled items from the UK to a destination or destinations outside of the UK

1.5. The Export Control Policy provides the internal control environment relating to research and/or education activities where UK export controls may apply.

2. Aims

The aims of this policy are to guide research staff and students on:

2.1. how, 鈥檆ontrolled items鈥� owned, generated, and processed by the University can potentially be misused and therefore within the scope of export control law

2.2. what their obligations are in law, and what is expected of them by the University, and

2.3. how they can comply with those obligations and meet those expectations, including by providing a summary of the University support and tools available, and signposting to further relevant resources.

This policy applies to research activities only. A separate policy will be developed for matters pertaining to education.

3. Definitions

N.B. The definitions below include those extracted from Department for International Trade

Academic freedom

Academic freedom means the freedom of academic colleagues within the law to question and test received wisdom, and to put forward new ideas and controversial or unpopular opinions, without placing themselves at risk of being adversely affected by loss of their jobs or privileges, or a reduction in the likelihood of their securing promotion or different jobs within the 黑料吃瓜网.(Code of Practice on Freedom of Speech and Academic Freedom, 黑料吃瓜网).

Academic Technology Approval Scheme (ATAS)

The ATAS is a visa requirement that applies to certain foreign students and researchers who want to study or conduct research in specific sensitive technology-related fields in the UK. The Foreign, Commonwealth & Development Office (FCDO) administers the scheme and issues ATAS certificates.

Basic scientific research

Basic scientific research means experimental or theoretical work undertaken principally to acquire new knowledge of the fundamental principles of phenomena or observable facts and not primarily directed towards a specific practical aim or objective.

Controlled Items

In the context of export controls, 鈥榗ontrolled items鈥� refers to those things that can be exported and to which export control regulations can apply. Items encompass both goods and 鈥渢echnology鈥�. It refers to any tangible or intangible items including physical products as well as the knowledge and information necessary for the development, production, or use of those products.

Development

Development means all stages prior to production (for example. design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into goods or software, configuration design, integration design, layouts).

Dual-use

Dual-use Items are goods, software or technology (documents, diagrams etc) which can be used for both civil and military applications. They can range from raw materials to components to complete systems, e.g., aluminium alloys, bearings, or lasers. They could also be items used in the production or development of military goods or chemical, biological or nuclear weapons, (e.g., machine tools, chemical/manufacturing equipment and computers).

Education

In this policy 鈥榚ducation鈥� refers to teaching, training or academic support delivered by teaching staff, either in-person or online to students based outside of the UK. This includes activities such as students accessing course materials online whilst based overseas.

ECJU

Export Control Joint Unit - The Government team within the Department for Business and Trade who are responsible for administering the UK鈥檚 system of export controls and licensing for military and dual-use items.

End-Use Controls

End-use controls focus on regulating the purpose for which exported goods or technology will be used, ensuring they are not diverted to unauthorized or sensitive applications. Unlike control list classifications, which categorise items based on their inherent characteristics, end-use controls can apply dependent on the intended final destinations and applications of exported items to mitigate potential risks such as proliferation or misuse.

Export

Export refers to the transfer of controlled items from the United Kingdom to a destination outside the UK. This includes physical shipments, electronic transmissions (e.g., via email or cloud services), and oral communications of controlled information to individuals located abroad.

Export Control

Export controls are the legislation the UK Government uses to restrict the export of sensitive technology and strategic goods. The aim is to prevent transfers that can lead to developing or producing weapons or goods which: (i) Could be used against the UK and allied forces and/or (ii) Cause national security concerns. Export controls apply to physical goods or the transfer of software, data, technology, or know-how which could have a military application.

Export Control Director (Education)

The member of staff who has overall responsibility for ensuring compliance with this policy in relation to Education activities.

Export Control Director (Research)

The member of staff who has overall responsibility for ensuring compliance with this policy in relation to Research activities.

Export Control Manager (Education)

The member of staff who is responsible for leading operational compliance with export control regulations in relation to Education activities.

Export Control Manager (Research)

The member of staff who is responsible for leading operational compliance with export control regulations in relation to Research activities.

Goods

Goods refer to physical items or products including materials, equipment, components, and finished products. These could range from machinery and electronics to chemicals and firearms.

鈥业苍蹿辞谤尘补迟颈辞苍鈥�

鈥业苍蹿辞谤尘补迟颈辞苍鈥� may take forms including, not limited to: blueprints, plans, diagrams, models, formulae, tables, 鈥榮ource code鈥�, engineering designs and specifications, manuals and instructions written or recorded on other media or devices (for example disk, tape, read-only memories).

In the public domain

In the public domain means available without restriction upon further dissemination (no account being taken of restrictions arising solely from copyright).

Open General Export Licences (OGELs)

Pre-approved licences that allow the export of specified controlled items to designated low-risk destinations without the need to apply for a licence for each shipment, provided the exporter registers and complies with the licence鈥檚 terms and conditions.

Production

Production means all production stages (for example as product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance).

Research

In this policy 鈥榬esearch鈥� refers to research activities undertaken by research staff and students. This includes activities such as staff research projects, research collaborations, Postgraduate Research, Taught or Undergraduate student research projects.

Researchers

In this policy 鈥榬esearchers鈥� refers to staff and students engaged in 鈥榬esearch鈥� activities as defined above.

Required

Required as applied to technology, it refers only to that portion of technology which is peculiarly responsible for achieving or extending the controlled performance levels, characteristics or functions. Such required technology may be shared by different goods.

鈥楽ource code鈥�

鈥楽ource code鈥� (or source language) is a convenient expression of one or more processes which may be turned by a programming system into equipment executable form.

Staff

Refers to all individuals employed by the University, encompassing both academic staff; to include teaching and research staff and professional services staff, who provide administrative, technical and operational support across all education and research activities.

Standard Individual Export Licences (SIELS)

Licences granted for a specific exporter, recipient, and set of controlled items, allowing a specified number of exports of controlled items to a particular end-user and destination, following a detailed application and assessment process.

Students

Students are individuals formally registered at the University and , including Undergraduate, Postgraduate Taught and Postgraduate Research degrees, as well as those participating in short courses or exchange programmes for example, regardless of mode of study.

Technology

鈥楾echnology鈥� is a defined term within export control legislation. Quotation marks denote this and other defined terms in the export control lists. Technology means specific 鈥榠nformation鈥� necessary for the development, production or use of goods or software. Please see the definition of 鈥榠nformation鈥� above.

Transfer

Transfer, in relation to software or technology, means transfer by electronic or non-electronic means (or any combination of electronic and non-electronic means) from a person or place within the United Kingdom to a person or place outside the United Kingdom.

Transfer by electronic means

Transfer by electronic means, in relation to software or technology, means transmission by facsimile, telephone, cloud services based outside of the UK or other electronic media (except that oral transmission of technology by telephone is included only where the technology is contained in a document the relevant part of which is read out over the telephone, or is described over the telephone in such a way as to achieve substantially the same result as if it had been so read).

Transfer by non-electronic means

Transfer by non-electronic means, in relation to software or technology, means disclosure of technology by any means (or combination of means), including oral communication, other than as the export of goods or the transfer by electronic means.

Use

Use means operation, installation (for example on-site installation), maintenance, checking, repair, overhaul and refurbishing.

Voluntary Disclosure

There are instances where it might become apparent that export of goods or transfer of controlled technology may have occurred without an appropriate export licence in place. It is also possible that such irregularity might have been identified by a compliance inspector from ECJU. If this happens, it is very important to report the irregularity to HMRC (sometimes known as 鈥榲oluntary disclosure鈥�) as soon as possible. If the irregularity is found by audit, the compliance inspector will have informed HMRC and the exporter is strongly advised to do the same.

Weapons of Mass Destruction

A nuclear, biological, or chemical weapon able to cause widespread devastation and loss of life.

Weapons of Mass Destruction Purposes (WMD Purposes)

鈥榃MD purposes鈥� means use in connection with the development, production, handling, operation, maintenance, storage, detection, identification or dissemination of chemical, biological or nuclear weapons or other nuclear explosive devices, or the development, production, maintenance or storage of missiles capable of delivering such weapons.

4. Scope

4.1. This policy applies to all members of University staff and students intending to transfer:

• Items on the
• Items to
• Items where "End Use controls" apply

4.2. Activities in scope for export control may include (but are not limited to):

• Physical exports, permanent or temporary, of controlled items, for example components, materials, samples, or software or technology stored in a physical format
• Research activities (including research for PGT dissertations) in 鈥榟igh risk鈥� subject areas (see 6.2)
• International research collaborations (with overseas institutions or researchers)
• Sending unpublished research for peer review outside of the UK
• Hosting visiting researchers from countries subject to sanctions or export control restrictions
• Providing consultancy to overseas clients or collaborators
• Presenting at international conferences (in person and online)
• Travelling overseas with a controlled item (for example, data on a laptop or a controlled piece of research equipment)
• Travelling overseas and accessing controlled technology or software through cloud servers
• Delivering teaching in person outside of the UK (as a visiting lecturer or as part of an academic exchange / partnership agreement with an overseas institution)
• Delivering teaching online through distance-learning courses for taught students based outside of the UK.
• Supervision of taught students鈥� dissertation and/or other research-related project materials who are based overseas
• Students based overseas accessing information on cloud servers
• Sharing information for 鈥淲MD Purposes鈥� (Weapons of Mass Destruction) inside or outside of the UK (note, export controls apply to transfers within the UK where they relate to WMD).

4.3. Breach of this policy may constitute a disciplinary offence for staff and students and will be subject to investigation under the University鈥檚 misconduct and/or disciplinary procedures. These procedures include the university research misconduct procedure.

4.4. Breaching export controls is a criminal offence. Penalties can vary depending on the nature of the offence. They include:

• Revocation of licences
• Seizure of items
• Issuing of a compound penalty fine
• Imprisonment for up to 10 years

5. Roles and responsibilities

5.1. The University Council has overall responsibility for the implementation, monitoring and review of this Policy. In doing so they are supported by the Vice-Chancellor鈥檚 Office and the Executive Board.

5.2. The Export Control Manager for Research is the Trusted Research Manager, and the Export Control Manager for Education is the Assistant Registrar (Education Compliance). Each is responsible for leading operational compliance with export control regulations within their respective domains.

5.3. Responsibilities for the Export Control Manager for Research include, but are not limited to:

• Raising awareness of Export Control Laws and responsibilities under this policy as they relate to research.
• Delivering training to staff and students.
• Establishing robust processes to support and embed export control compliance for all research-related activity.
• Carrying out compliance checks on research proposals identified within the Ethics@黑料吃瓜网 application process to ensure compliance with export control law.
• Working with staff or students to identify whether an export licence is required and what type of licence to apply for.
• Submitting applications for export licences for research activity.
• Maintaining records of live research activity which requires export licences including through addition to the 鈥楾rusted Research Risk Register鈥�.
• Supporting staff and students operating under export licences to undertake the required record keeping.
• In relation to the management of breaches or potential breaches in export control law relating to research activities, establishing whether a breach has occurred and coordinating appropriate response, including voluntary disclosure to HMRC if applicable.
• Coordinating ECJU Inspection Visits.

5.4. Responsibilities for the Export Control Manager for Education include, but are not limited to:

• Raising awareness of Export Control Laws and the responsibilities under this policy as they relate to teaching and education.
• Establishing robust processes to embed export control compliance for both staff and students for education-related activity.
• Submitting applications for export licences for education activity.
• Maintaining records of education activity which require an export licence including through addition to Education risk register.
• Supporting staff and students operating under export licences to undertake the required record keeping.
• In relation to the management of breaches or potential breaches in export control law relating to education activities, establishing whether a breach has occurred and coordinating appropriate response, including voluntary disclosure to HMRC if applicable.

5.5. The Export Control Director for Research is the Director of Research Policy, Governance, and Integrity who has overall responsibility for ensuring compliance with this policy in relation to Research activities.

5.6. The Export Control Directors for Education are the Pro-Vice-Chancellor (Education) and the Pro-Vice-Chancellor (Global Engagement) who have overall responsibility for ensuring compliance with this policy in relation to Education and Transnational Education (TNE) activities respectively.

5.7. Each Export Control Director is responsible for:

• Overseeing internal self-audit processes within their respective domains. This entails receiving periodic assurance from the relevant Export Control Manager that that the institution is meeting its export control obligations.
• Approving (or delegating responsibility for approving) export licence applications relevant to their area of oversight.

5.8. Heads of Departments are responsible for:

• Promoting awareness and understanding of the Export Control Policy,
• Identifying areas at higher risk of export controls and ensuring that staff and students engage with the requirements of this policy to ensure compliance,
• Facilitating and supporting the delivery of training by the Export Control Managers,
• Ensuring compliance with export controls from course design through to delivery of education and/or training. (This policy should be read in conjunction with the Quality Assurance Code of Practice statements QA3 Approval of New Programmes of Study and QA4 Amendments to Programmes of Study and Units and Approval of New Units,
• Ensuring all departmental international travel complies with export control regulations,
• Management of departmental Risk Register to ensure that export control is appropriately recorded.
• Oversight of 鈥楥orrective and Preventative Action鈥� (CAPA) Plans, including signing these as required

5.9. Line managers are responsible for ensuring that their staff are aware of and understand the policy.

5.10. Members of staff are responsible for:

• Familiarising themselves with this policy,
• Completing all relevant training as provided or recommended by the University,
• Complying with export controls for research and/or education activities,
• Submitting research for ethics review via the Ethics@黑料吃瓜网 platform, and providing sufficient details to facilitate the export control compliance checks conducted in parallel with the ethics review.
• Providing the necessary advice and guidance to the students they supervise or teach (where applicable),
• Seeking advice and requesting that licences are applied for as necessary, via the relevant Export Control Manager, and
• Informing their Line Manager when international travel is planned.

5.11. Students are responsible for:

• Familiarising themselves with this policy,
• Completing all relevant training as provided or recommended by the University,
• Undertaking the research ethics review via the Ethics@黑料吃瓜网 platform, and providing sufficient detail to facilitate the export control compliance checks conducted in parallel with the ethics review,
• Informing their supervisor in advance of travel outside of the UK so that export control requirements can be identified, and
• Seeking advice and/or requesting that licences are applied for as necessary, with support from a member of staff, including their supervisor, as required.

5.12. Procurement and other staff supporting researchers are responsible for ensuring that the policy is discharged to staff and students where appropriate.

5.13. The International Relations Office, and other staff supporting transnational research and education activities, are responsible for ensuring all international partnership contracts include the appropriate Export Control provisions to comply with Export Control Laws and international partners uphold the University鈥檚 Export Control policy where applicable.

6. Policy

6.1. Any member of staff or student looking to transfer controlled items outside of the UK should use the checklist in Annex I to confirm whether export controls apply to their work.

6.2. Subject areas most likely to be in scope (but not exhaustive) include:

• Additive manufacturing
• Aeronautical and space technology
• Applied chemistry, biochemistry and chemical engineering
• Applied physics
• Automation and control including drones and other technology
• Biological sciences relating to viruses, pathogens and vaccines
• Biotechnology
• Chemical or toxic properties
• Cryptography
• Electrical and mechanical engineering
• High specification electronics and computers
• High strength materials
• Instrumentation and sensors
• Lasers, sonar and optics
• Materials technology
• Navigation and avionics
• Nuclear sciences, technologies or engineering
• Production and process technology
• Quantum computing
• Submersible equipment
• Telecommunications and information technology

6.3. Postgraduate Taught and Undergraduate Master鈥檚 courses (level 7 and above) in the subject areas listed above are more likely to be in scope for export controls, and particularly for courses where an Academic Technology Approval Scheme (ATAS) certificate is needed for overseas students seeking to study in the UK.

6.4. ATAS clearance does not remove the requirement for an Export Control Licence.

6.5. Taught courses at level 6 (and below) are less likely to be in scope for export controls. Most of the information and technical data used in teaching is in the public domain and therefore exempt. Independent research relating to final year projects may fall into scope.

6.6. The must be used to determine:

• If the items are listed on the
• The appropriate control entry reference in the control list
• If an appropriate exists

6.7. If the items are listed under a control list (鈥榬ating鈥�) entry, or if risks relating to sanctioned locations or 鈥榚nd use鈥� controls are identified, contact the relevant Export Control Manager, as per Section 5 to seek advice and start the application as an export licence from the Export Control Joint Unit (ECJU) is needed.

6.8. Licences can be applied through , or depending on the licence type. These are the UK government鈥檚 online export licensing platforms.

6.9. All licence applications or registrations must be submitted by the relevant Export Control Manager and approved by the relevant Export Control Director (or delegate) on behalf of the University.

6.10 Export Licences:

6.11. An export control licence is an official authorisation granted by the UK government that permits the export, transfer, or disclosure of controlled items to overseas destinations where such activities would otherwise be restricted under export control regulations.

6.12. University activity is expected to primarily fall under 2 categories of licences that are available:

• Open General Export Licences (OGELs) Pre-approved licences that allow the export of specified controlled items to designated low-risk destinations without the need to apply for a licence for each shipment, provided the exporter registers and complies with the licence鈥檚 terms and conditions.
• Standard Individual Export Licences (SIELS) Licences granted for a specific exporter, recipient, and set of controlled items, allowing a specified number of exports of controlled items to a particular end-user and destination, following a detailed application and assessment process.

6.13. The UK government provide an , which is a search tool designed to find a suitable standard OGEL licence. If no OGEL is available, a SIEL will be required in order to export the item.

6.14. Once an export licence has been obtained, the relevant Export Control Manager will provide guidance on how to comply with the specific Terms and Conditions of the licence, to include compliance with ECJU record keeping requirements.

6.15 Exceptions and Exemptions

6.16. There is no automatic exemption from export controls for university research or education activities.

6.17. The legislation allows for exemptions should any of the conditions listed below apply. Exemptions should be considered in consultation with the relevant Export Control Manager and, if deemed exempt, a record of the justification should be maintained in the appropriate records.

• Basic scientific research: experimental or theoretical work undertaken principally to acquire knowledge of fundamental principles or phenomena or observable facts . To qualify for the 鈥榖asic scientific research鈥� exemption any technology generated by the research must be below a level 3 Technology Readiness level (TRL). The following conditions should also apply:
• Be solely to add to the sum of human knowledge
• Not be aimed at a specific (short-term) practical aim

• Not address a specific technical problem

• Information in the public domain: information that is freely available without restriction

• The minimum technical information required to support a patent application for a non-nuclear dual use 鈥榯echnology鈥�

6.18. The above exemptions are unlikely to apply to all aspects of research-focused advanced postgraduate degrees such as MPhil or PhD where these are exploring areas of controlled technology. By definition, these degrees will include technology not covered by the 鈥榩ublic domain鈥�, and often address specific practical aims.

7. Declaring irregularities

7.1. In instances where a member of staff discovers that they, a colleague or a student, have (or may have) exported controlled items without an appropriate export licence, or have otherwise failed to comply with export control requirements, it is very important to notify the relevant Export Control Manager.

7.2. The Export Control Manager must take steps to establish whether a breach has occurred; this can include seeking advice from the Export Control Joint Unit (ECJU).

7.3. In cases where a breach has been identified, this must be reported to the relevant Export Control Director and reported to the HM Revenue and Customs (HMRC) as a 鈥榲oluntary disclosure鈥� as soon as possible.

7.4. Compliance inspections from the ECJU may also identify an irregularity during a compliance audit. Members of staff are also encouraged to proceed with a 鈥榲oluntary disclosure鈥� when informed of an irregularity via an auditor.

7.5. 鈥榁oluntary disclosures鈥� need to be submitted in writing to HM Revenue & Customs. Copies of disclosures should be sent to: Strategic Exports and Sanctions Enforcement Policy Customs Debt, Enforcement & Law, Customs & Border Design, HMRC, 14 Westfield Avenue London E20 1HZ, Email: exports.strategic@hmrc.gov.uk

7.6. Voluntary disclosure reports must include:

• Details of the export, including dates
• Any relevant documents, such as export documentation and commercial invoices
• Details of how the breach was discovered, why it occurred and what steps have been put in place to ensure it does not happen again.

7.7. When a breach or a 鈥榥ear miss鈥�, is discovered, the relevant activity lead (e.g., Principal Investigator or Course Lead) must complete a 鈥楥orrective and Preventative Action鈥� Plan (CAPA). This document must be signed by themselves, their Head of Department, and the relevant Export Control Manager.

7.8. The CAPA process is intended to maintain a clear internal record and to ensure that all proper considerations are made to ensure that voluntary disclosure is done properly and with the necessary support.

7.9. If a person feels that they are not able to submit a voluntary disclosure as described in 7.5 and 7.6, they can request that the relevant Export Control Manager does so on their behalf

8. Import Controls

8.1. Technology imported into the UK is also subject to import controls.

8.2. Further information about import controls can be found on the government鈥檚 website:

8.3. U.S. Export Controls:

8.4. Items, technology, software, and technical data of U.S. origin may remain subject to U.S. export controls even when located outside the United States.

8.5. This extraterritorial application includes items governed by the and the

8.6. Staff and students working with U.S. origin items (whether equipment, software, technology, or technical data) must ensure compliance with all relevant U.S. export control requirements in addition to UK regulations.

8.7. When sourcing or receiving items from the United States, staff and students must consult Procurement at the earliest opportunity to ensure all U.S. and UK compliance obligations are identified and met. This includes adhering to any licence conditions, access restrictions, or other requirements identified during the procurement or due diligence process.

9. Academic Freedom

9.1. The University has a longstanding commitment to Freedom of Speech and Academic Freedom to advance learning and knowledge through teaching and research.

9.2. As expressed in the University鈥檚 Code of Practice on Freedom of Speech and Academic Freedom, Academic Freedom is not an unqualified right, and researchers remain bound by ethical, legal, and professional limitations. In relation to export control laws, Academic Freedom does not permit researchers to contravene applicable legislative requirements.

9.3. As per certain protections are enshrined within export control legislation, including the prescription that the Secretary of State may not make a control order which has the effect of prohibiting or regulating the communication of information in the ordinary course of scientific research or where the information is in the public domain.

9.4. Further advice on academic freedom should be obtained from the legal team in the first instance.

10. Training and Information

10.1. University Training:

10.2. The University is responsible for providing training and support to members of staff and students where required.

10.3. The Export Control Manager (Research) can deliver bespoke training on demand. Please contact Research-Governance@黑料吃瓜网.ac.uk to request training.

10.4. Open House Style-Training session recordings are available via the Sessions include:

10.5. The University鈥檚 Mandatory Research Integrity Training, developed by the UK Research Integrity Office (UKRIO), includes an optional module on 鈥楻esearch Security鈥�.

10.6. External Training:

10.7. The Export Control Joint Unit (ECJU) provides training and webinars on strategic export control licences and on how to be compliant with UK export control laws which can be accessed via their website:

10.8. Other Sources of Information:

10.9. on export controls and the ATAS student vetting scheme

10.10. Coventry University Case Studies

10.11. 黑料吃瓜网 guidance on ATAS can be found here: 鈥楢pplying to the Academic Technology Approval Scheme (ATAS)鈥�.

10.12. Case studies scenarios showing when an export licence may be needed in university teaching and research environments have been published by the

10.13.

10.14. The UK publishes a 5-minute Case Study video titled

10.15. The NPSA

10.16. Please contact the relevant Export Control Manager if you require support on any aspect of Export Control compliance. If external advice is required, they will facilitate this.

11. Related policies and procedures

111.1. Risk Management Strategy

11.2. Procedure for Enquiring into Allegations of Research Misconduct

11.3. Public Interest Disclosure Procedure (whistleblowing)

11.4 Code of Practice on Freedom of Speech and Academic Freedom

11.5 Regulation 18: Freedom of Expression

12. References

12.1.

12.2.

12.3.

12.4.

13. Annexes

13.1. Annex I - Export Control Checklist

14. Document Information