University of Glasgow Export Control Compliance Statement
From: Chief Operating Officer and University Secretary, 13 November 2024
Export control and the academic community
The University of Glasgow is operating in an increasingly global capacity in respect of our international research collaborations and our interactions with global research funders and other organisations.
The University encourages and values international engagement in all its forms and our international profile, partnerships and relationships are crucial to our ability to carry out research that transforms lives and changes the world.
As a world-leading institution engaged in research and knowledge exchange with partners across the globe, we must, however, be alert to the possibility of our research and outputs being misused when exported.
It is therefore essential that we comply with all relevant national and international legislation and requirements relating to export control insofar as these relate to the activities of the University and its people (staff, students, visiting academics and contractors).
UK export control refers to a set of legal restrictions on the transfer of certain goods, equipment, materials, software and technology from the UK to a destination or destinations outside the UK with the aim of protecting national security and preventing conflict, human rights abuse, weapons of mass destruction (WMD) proliferation and terrorism. Other reasons for controls include foreign policy and international treaty commitments (e.g. trade sanctions or arms embargoes).
It is important to note that export control regulations don’t only apply to the transfer of physical items but also to the transfer of information (including software, data, designs, knowledge or knowhow) whether this be physically, electronically or verbally.
In the UK, exports of strategic goods and any licences required are administered by the Export Control Joint Unit (ECJU).
Some international staff and students need to be certified via the Academic Technology Approval Scheme (ATAS). This scheme applies to all international students and researchers (apart from exempt nationals) who are subject to UK immigration control and are intending to study or research at postgraduate level or above in a relevant subject area and is additional to export control regulations. All non-sponsored visiting academic researchers (other than exempt nationals) who are carrying out or taking part in research at postgraduate level or above in a relevant subject area are also required to hold an ATAS certificate before they begin any such research at the University.
University commitment to export control compliance
The University understands the importance of export control compliance and takes its responsibilities in respect of export control very seriously. The University is committed to ensuring its people comply with applicable national and international export control and sanctions legislation, regulations and procedures. As part of this commitment, we will ensure that:
- All individuals working in relevant disciplines are made aware of how the regulations may apply to their activities, through the provision of information, guidance, support, advice and training;
- Due diligence procedures are followed in respect of all relevant proposed activities, to establish whether they are subject to export control legislation;
- Proposed activity that is prohibited by sanctions does not proceed;
- Proposed activity that is subject to export control regulations will not proceed unless an appropriate licence is first obtained in relation to the activity and all necessary steps are taken to ensure that its conditions are fully implemented;
- Regular checks are conducted to ensure that these principles are strictly observed. If any issues are identified via these checks and/or via audits that are conducted by ECJU, we shall ensure that these are investigated promptly, urgent measures taken to prevent any recurrence, disciplinary action considered, and the relevant authorities notified.
To ensure that the University and our people are able to fulfil the legal obligations relating to export control, the University has put in place an Export Control Policy, webpages and training to support individuals to identify whether their activities are subject to export control regulations and to apply for the necessary licences, where needed.
The Chief Operating Officer and University Secretary has overall responsibility for the University’s compliance with legislation and requirements relating to export control and sanctions.
It is, however, the responsibility of individuals to be aware of and to comply with the University’s an Export Control Policy and export control and sanctions legislation as set out below.
In the UK, failure to comply with export control and sanctions legislation is a criminal offence and can result in very significant financial penalties for both the University and the individual, as well as reputational damage and prison sentences of up to 10 years.
The University is committed to ensuring that our research is carried out to the highest standards of research integrity and in accordance with our legal obligations. The University expects all individuals engaged in research to recognise that they are personally responsible for their own research practice and for ensuring that they comply with any export control and sanctions legislation and requirements which apply to their activities. Individuals (particularly those working in science and engineering disciplines) should therefore ensure that they:
- Have read and understood the University’s Export Controls Policy and Compliance Procedure and the associated guidance on the University website;
- Have awareness as to whether their research area/s may be subject to export control regulations;
- Do not engage in any activity for which an export control licence is required without confirming that a licence has been obtained for that activity; and
- Seek advice from the University’s Research Governance and Integrity Team (e-mail: email@example.com) if they suspect that export controls may apply to their work.