Skip to Content
English (US)

EXPORT CONTROL AND COMPLIANCE POLICY

Last updated: 8 October 2026 · Version 1.0

MABAYCO Endüstriyel Ürünler Ltd. Şti. ("MABAYCO") supplies chemicals and technical materials to aerospace, defence and industrial customers. A large share of the products we sell are of U.S. origin or contain U.S.-origin content, and they remain subject to U.S. export control regulations when resold in Türkiye or any other country. This policy explains the rules we apply to prevent our products from reaching sanctioned persons, entities, countries or regions, or prohibited end uses, directly or indirectly.

1. Purpose and scope

This policy applies to all products and all sales channels: direct sales, our website and B2B portal, sales through distributors, drop shipments from suppliers and samples. Commercial pressure is never a reason to bypass these rules.

2. Applicable regulations

  • Export control and sanctions laws of the Republic of Türkiye
  • United Nations Security Council sanctions
  • European Union sanctions and export control regulations, including Council Regulation (EU) No 833/2014
  • United Kingdom sanctions
  • U.S. Export Administration Regulations (EAR) and sanctions administered by OFAC
  • Export control and sanctions requirements of our suppliers

3. Restricted countries and regions

We do not sell to, and do not allow our products to be exported, re-exported or transferred to or used in: Cuba, Iran, North Korea, Russia, Belarus; Crimea, the so-called Donetsk and Luhansk regions and other occupied regions of Ukraine.

Quotations and orders involving other high-risk countries and regions are subject to additional review and management approval, and we may request further information and documents. We review our country list regularly and after every major sanctions announcement.

4. Prohibited end uses

Our products may not be used, directly or indirectly:

  • for nuclear, chemical or biological weapons, or missiles or unmanned aerial vehicles capable of delivering them;
  • for any military end use or by any military end user where this is prohibited or requires a licence under applicable law, unless all required authorisations have been obtained and MABAYCO has given prior written consent;
  • for the maintenance, repair or servicing of any aircraft subject to a U.S. Temporary Denial Order or identified by the U.S. Bureau of Industry and Security as operated in apparent violation of the EAR in connection with Russia or Belarus.

Customers declaring a defence end use will be asked for additional information.

5. Restricted party screening

We screen every new customer before its first order is accepted against the U.S. Consolidated Screening List (including OFAC SDN and BIS lists), EU sanctions lists and the UK Sanctions List, and where needed the UN Security Council Consolidated List. Existing customers are re-screened periodically and whenever an order involves a new delivery country, address or end user.

We do not do business with listed persons or entities, or with entities owned 50% or more, or controlled, directly or indirectly, by them.

6. Customer information and end-user statements

We ask new customers for their full legal name, registered address, delivery address, business activity, and whether they will use the products in their own operations or resell them.

  • Website and B2B portal: accepting the Trade Compliance Declaration on this page is mandatory for B2B registration and for every order.
  • Resellers, distributors and traders outside Türkiye: before the first order is accepted, we require an End-Use and End-User Statement signed by a person authorised to bind the company, with proof of authority. The Statement is valid for one year and must be renewed when end users, destinations or end uses change. The website declaration does not replace this Statement.
  • Trading customers in Türkiye: the same Statement is required if the products will be exported or delivered abroad or to a free zone.

7. Resale and transfer

Customers who resell our products must contractually pass these obligations on to their own customers (including the prohibition on re-export to Russia and Belarus), obtain equivalent end-use commitments from them and screen them against the lists in section 5.

8. Suspicious transactions; refusal, suspension and cancellation

We will put a transaction on hold and ask for a written explanation if, for example, the customer avoids giving end-user or end-use information; the order is out of proportion to the customer's business; the delivery country differs from the customer's country or changes at the last minute; removal of labels or certificates is requested; payment comes from a third party or another country; or the customer declines to sign an end-user statement.

Where there is reasonable suspicion that a transaction may breach applicable law or this policy, we may refuse, suspend or cancel any quotation, order, delivery or payment without liability. Where required by law, we share information with our suppliers and the competent authorities.

9. Records

Screening results, end-user statements and the date and version of each Trade Compliance Declaration given on our website are retained for at least 10 years. For information on how we process personal data, see our Personal Data Protection Notice.

10. Contact and notifications

Questions about this policy, changes to the information in your declaration, or any suspected diversion of our products can be reported in writing to: hello@mabayco.com

TRADE COMPLIANCE DECLARATION

Version 1.0 · 8 October 2026

This declaration is accepted during B2B registration and with every order placed on our website. The date of acceptance and the declaration version are stored in the customer account and on the order.

As the buyer, and where I act for an organisation on behalf of that organisation, I declare and undertake the following with respect to all products, technology and documents received from MABAYCO:

  1. Compliance. I will comply with the export control and sanctions laws of Türkiye, the UN, the EU, the United Kingdom and the United States (including the EAR and OFAC regulations), and of my own country.
  2. Prohibited destinations. I will not, directly or indirectly, export, re-export, sell or transfer the products, in their original form or incorporated into other items, to the countries and regions listed in section 3 of this policy or to any other country or region under comprehensive sanctions or embargo, nor allow their use there.
  3. Restricted parties. I will not sell or transfer the products to, or for the benefit of, any person or entity on U.S., EU, UK or UN sanctions lists, or any entity owned 50% or more, or controlled, by them.
  4. Prohibited end uses. The products will not be used for any of the purposes listed in section 4 of this policy.
  5. Resale. If I resell the products, I will pass these obligations on to my customers; if I resell outside Türkiye, I will sign MABAYCO's End-Use and End-User Statement before my first order.
  6. Accurate information and notification. The information I have provided is accurate. I will notify MABAYCO in writing without delay if it changes, or if I suspect that products have been diverted.
  7. Information and cooperation. On request, I will provide information and documents on the end use, end users and final destination of the products. I agree that MABAYCO may share this declaration with its suppliers and the competent authorities.
  8. Refusal and cancellation. I accept that MABAYCO may refuse, suspend or cancel any order or delivery without liability where there is reasonable suspicion of a breach of applicable law or of this declaration, and that a breach of this declaration is a material breach of the commercial relationship.
  9. Authority. Where I act for an organisation, I am authorised to give this declaration on its behalf.
​