EXPORT CONTROL POLICY

Sensitive items, commodities, products having dual use in nature or other than its military (conventional use) are subject to approval of national authority’s clearance under its export policy and Pakistan’s Export Control Act, 2004 on Goods, Technologies Materials and Equipment related to Nuclear Biological Weapons and their delivery system.
 

Export Policy

Effective Date: Jul 15, 2026
Last Updated: Jul 15, 2026

Global Industrial & Defence Solutions (Private) Limited (“GIDS,” “we,” “us,” or “our”) is committed to conducting its international business in full compliance with the export control laws of the Islamic Republic of Pakistan and with the international non-proliferation obligations to which Pakistan subscribes. This Export Policy sets out the principles that govern the marketing, licensing, transfer, and delivery of GIDS products, technology, technical data, and services outside Pakistan.

This Policy applies to all GIDS directors, officers, employees, contractors, agents, distributors, and business partners, and to every transaction involving GIDS products or controlled technology, regardless of value or destination.

1. Statement of Commitment

GIDS is fully committed to responsible defense exports. We recognise that the products and technologies we develop and supply may impact regional stability, non-proliferation objectives, and human rights. Accordingly, we support the Government of Pakistan’s strategic trade control regime and align our internal procedures with its policy objectives. Our commitment includes:

  • Zero tolerance for any transaction that violates applicable export control laws
  • Full cooperation with regulators, licensing authorities, and end-use verification bodies
  • Refusal of any business opportunity that raises legitimate proliferation, diversion, or human rights concerns
  • Continuous investment in compliance training, screening tools, and internal controls
2. Regulatory Framework

Our export activities are governed by, and conducted in accordance with, the following legal and regulatory instruments, as amended from time to time:

  • The Export Control Act, 2004 of the Islamic Republic of Pakistan
  • The Export Control (Licensing and Enforcement) Rules, 2009
  • The National Control Lists issued by the Strategic Export Control Division (SECDIV) of the Ministry of Foreign Affairs
  • Directives, notifications, and guidelines issued by SECDIV, the Ministry of Defence Production, and other competent authorities
  • Resolutions of the United Nations Security Council imposing sanctions or arms embargoes that are binding on Pakistan
  • Applicable Customs, foreign exchange, and anti-money-laundering laws of Pakistan
  • Contractual and confidentiality obligations arising from Government-to-Government arrangements

Where the requirements of an international customer’s jurisdiction impose additional obligations, GIDS will observe those requirements to the extent they are consistent with Pakistani law.

3. Governance & Responsibility

GIDS maintains an Internal Compliance Programme (ICP) that assigns clear responsibility for export control compliance. This includes:

  • Senior management oversight and accountability for the ICP
  • A designated Export Compliance Officer responsible for day-to-day administration
  • Documented procedures for classification, screening, licensing, and record-keeping
  • Periodic internal audits and management reviews
  • A clear escalation channel for reporting concerns or suspected violations

Every employee involved in international sales, marketing, engineering, logistics, or after-sales support is required to be familiar with, and adhere to, this Policy and the associated internal procedures.

4. Products & Technology Subject to Control

The majority of products, systems, sub-systems, components, technical data, and services offered by GIDS are considered controlled items under the National Control Lists. Controlled items include, without limitation:

  • Unmanned aerial systems, loitering munitions, and their payloads
  • Air-launched weapons, guided munitions, and precision guidance kits
  • Land systems, artillery systems, and fire control platforms
  • Naval platforms, sonar systems, and combat management systems
  • Anti-tank guided missiles, MANPADS, and related munitions
  • CBRN defense equipment and countermeasures
  • Command, control, communications, computers, and intelligence (C4I) systems
  • Cyber security systems, encryption equipment, and information assurance products
  • Technical data, drawings, software, training, and technical assistance related to any of the above

Every transaction involving a controlled item — including physical exports, re-exports, in-country transfers, brokering activities, and intangible transfers of technology — requires the appropriate export authorization from SECDIV or other competent authority before it may proceed.

5. Customer & End-User Due Diligence

GIDS conducts risk-based due diligence on every prospective customer, end-user, and intermediary. The scope and depth of due diligence is calibrated to the sensitivity of the item and the risk profile of the destination. Standard due diligence includes:

  • Verification of the legal identity, ownership, and standing of the requesting entity
  • Verification that the requesting representative is duly authorized to act on behalf of the end-user
  • Screening of the customer, end-user, consignee, intermediaries, and beneficial owners against United Nations sanctions lists and any other lists applicable under Pakistani law
  • Assessment of the stated end-use for consistency with the technical characteristics of the requested item
  • Assessment of the destination country’s security situation, diversion risk, and any applicable embargo
  • Collection of End-User Certificates, End-Use Statements, and Non-Re-Export Undertakings where required
  • Escalated review of any transaction that raises “red flags,” including refusal to provide end-use information, unusual routing, unusual payment terms, or requests inconsistent with the customer’s normal profile
6. Restricted & Prohibited Destinations

GIDS does not engage in any export, re-export, brokering, or transfer to:

  • Countries or territories subject to United Nations Security Council arms embargoes binding on Pakistan
  • Persons or entities designated on applicable United Nations sanctions lists
  • Any destination in respect of which SECDIV, the Ministry of Foreign Affairs, or the Ministry of Defence Production has issued a prohibition or denial
  • Non-state actors, unauthorized armed groups, or entities that cannot demonstrate legitimate governmental or institutional standing
  • Any end-use associated with weapons of mass destruction, their means of delivery, or activities inconsistent with Pakistan’s non-proliferation commitments

Where the risk profile of a proposed transaction cannot be adequately mitigated, GIDS will decline the transaction, irrespective of its commercial value.

7. Licensing & Authorizations

No controlled item, technical data, or service will be released for export until all required licenses, authorizations, and approvals have been obtained. This includes:

  • Export licenses issued by SECDIV
  • No Objection Certificates from the Ministry of Defence Production, where required
  • End-User Certification endorsed by the competent authority of the recipient state
  • Any additional clearances required for Government-to-Government transactions

License conditions, scope limitations, and reporting obligations are treated as binding operational requirements and are communicated to all personnel involved in the transaction.

8. Anti-Diversion & End-Use Monitoring

GIDS takes reasonable steps to reduce the risk that its products are diverted from their authorized end-user or end-use. These measures include:

  • Contractual non-diversion and non-re-export clauses in all export contracts
  • Requirement of prior written consent for any transfer of possession, ownership, or use
  • Delivery verification and, where appropriate, post-shipment verification arrangements
  • Cooperation with SECDIV and foreign licensing authorities on end-use monitoring
  • Immediate suspension of ongoing performance where credible evidence of diversion is identified
9. Intangible Transfers of Technology

Export controls apply not only to physical shipments but also to intangible transfers of controlled technology. Accordingly, GIDS applies the same authorization requirements to:

  • Electronic transmission of controlled technical data by email, cloud storage, or file transfer
  • Verbal disclosure of controlled technical information in meetings, calls, or presentations
  • Access to controlled technology by foreign national employees, visitors, or contractors
  • Technical assistance, training, and after-sales support that involves controlled know-how
  • Presentations and demonstrations at exhibitions, trade shows, and industry events
10. Third Parties, Agents & Distributors

Where GIDS engages agents, representatives, distributors, or logistics providers in connection with international business, we require them to:

  • Acknowledge and comply with this Export Policy and applicable Pakistani export control laws
  • Undergo appropriate due diligence and periodic re-screening
  • Provide truthful information about end-users, end-use, and intermediary parties
  • Cooperate with GIDS in any compliance review, audit, or investigation
  • Refrain from any action, payment, or arrangement that could be construed as a violation of export control, anti-corruption, or anti-money-laundering laws

GIDS reserves the right to terminate any third-party relationship where compliance concerns arise.

11. Government-to-Government Transactions

A significant portion of GIDS’s international business is conducted under Government-to-Government (G-to-G) arrangements. In such cases, transactions are structured in coordination with the Ministry of Defence Production, the Ministry of Foreign Affairs, and other authorized organs of the Government of Pakistan. G-to-G arrangements are subject to the same due-diligence, authorization, and end-use standards described in this Policy, together with any additional protocols agreed at the intergovernmental level.

12. Confidentiality of Controlled Information

Controlled technical data, drawings, specifications, and pricing information are treated as strictly confidential and are protected through:

  • Written non-disclosure agreements with all authorized recipients
  • Access controls limiting disclosure to personnel on a need-to-know basis
  • Secure storage, transmission, and destruction of controlled materials
  • Marking and handling procedures aligned with the sensitivity of the information

Controlled information will not be exchanged through public contact forms, unencrypted email, or informal channels.

13. Training & Awareness

GIDS provides regular training to relevant personnel on export control obligations, red-flag indicators, screening procedures, and reporting channels. Additional targeted training is provided to employees in sales, engineering, logistics, and after-sales support, and to any employee whose role gives rise to elevated compliance responsibilities.

14. Record Keeping

GIDS maintains complete and accurate records of all export transactions, including licensing correspondence, end-user documentation, screening results, shipment records, and internal approvals. Records are retained for the period required by Pakistani law and by applicable contractual and licensing conditions, and are made available to regulators upon lawful request.

15. Reporting Concerns & Suspected Violations

Any employee, business partner, customer, or other person who becomes aware of an actual or suspected violation of this Policy, of export control law, or of any UN sanction is encouraged to report it promptly. Reports may be made to the Export Compliance Officer through the contact channels listed at the end of this Policy. GIDS treats such reports confidentially and does not tolerate retaliation against any person who reports a concern in good faith.

Confirmed violations are subject to internal disciplinary action, contract termination, and, where required, reporting to the competent Pakistani authorities.

16. No Waiver by GIDS

Nothing in any commercial communication, quotation, or preliminary correspondence issued by GIDS shall be construed as a commitment to supply any controlled item, to obtain any export authorization, or to enter into any transaction. All commitments are subject to compliance clearance, licensing, and the execution of a definitive written agreement.

17. Changes to This Policy

GIDS may revise this Export Policy from time to time to reflect changes in the regulatory environment, in international obligations, or in the scope of our operations. The “Last Updated” date at the top of this Policy indicates when it was last revised. The most current version will always be available on the GIDS website.

18. Contact

For questions regarding this Export Policy, licensing status of a specific product, or export compliance matters, please contact the Export Compliance Officer:

Global Industrial & Defence Solutions
Export Compliance Office
GIDS, Complex II, Chaklala Garrison, Rawalpindi, Pakistan
Telephone: +92-51-9280061 / +92-51-9280062
Email: info@gids.com.pk