End-Use Policy

Traduction française à venir. La version anglaise fait foi ; le texte ci-dessous sera remplacé par la traduction française dès qu’elle sera disponible.

Issuer: Incutec BV Effective: Date of incorporation, mid-May 2026 Review: Annual; or upon material change to product scope, regulatory environment, or distribution channels.

1. Scope

This policy governs the sale, supply, and distribution of all goods designed, manufactured, or resold by Incutec BV, including but not limited to the OpenDrone product line.

2. Permitted End-Use

Incutec BV designs and supplies civilian hobby and commercial electronics. Goods are intended for use in:

consumer hobby and recreational applications;
educational, research, and maker contexts;
non-defence commercial applications, including industrial control, robotics, and prototyping.

3. Excluded End-Use

Incutec BV does not knowingly sell, supply, or distribute goods for use in:

armed conflict zones in which civilian unmanned aerial vehicle components are demonstrably used in kinetic, loitering, or intelligence-surveillance-reconnaissance roles;
weaponized unmanned aerial systems, including those carrying lethal or sub-lethal payloads;
military procurement programmes, defence ministries, defence prime contractors, or their direct subcontractors where the contract end-use is military;
paramilitary, mercenary, or private military company end-users;
any end-use that contravenes EU Regulation 2021/821 (dual-use), EU Regulation 833/2014 (Russia restrictive measures), EU Regulation 765/2006 (Belarus restrictive measures), or any successor instruments.

4. Operational Implementation

4.1 Geographic restrictions

The webshop applies country-level restrictions corresponding to (a) destinations subject to EU and UN restrictive measures, and (b) destinations on the Active-Conflict Block list maintained in compliance/export-sanctions/sanctions-screening.md. The Active-Conflict Block list is reviewed quarterly against the Armed Conflict Location & Event Data Project (ACLED) and the Uppsala Conflict Data Program (UCDP).

4.2 Customer screening

Direct-to-consumer orders are screened against EU consolidated sanctions lists. Business-to-business orders are additionally subject to end-use review and, where applicable, the no-re-export-to-Russia clause required by Article 12g of EU Regulation 833/2014.

4.3 Acceptable end-use clause

Order placement on the Incutec webshop constitutes acceptance of the Acceptable End-Use clause set out in the General Terms and Conditions (compliance/webshop/algemene-voorwaarden.md).

4.4 Downstream resale

This policy applies to direct sales by Incutec BV. Resale by commercial customers established in the European Union is governed by the contractual no-re-export clause referenced in §4.2 and is not subject to additional audit obligations imposed by Incutec.

5. Limitations

This policy:

does not classify any party to a conflict; the geographic restrictions in §4.1 apply uniformly to active-conflict territories regardless of the political status of the parties involved;
does not restrict purchases by individuals who are employed by defence-related entities and who purchase goods in a private capacity for non-military use;
does not constitute a representation that goods supplied by Incutec BV will not, through means outside the control of Incutec BV, reach restricted end-uses;
does not preclude employees, contractors, or shareholders of Incutec BV from supporting humanitarian or civil-society causes in their personal capacity.

6. References

EU Regulation 2021/821 (dual-use): https://eur-lex.europa.eu/eli/reg/2021/821/oj/eng
EU Regulation 833/2014 (Russia): https://eur-lex.europa.eu/eli/reg/2014/833/oj
EU Regulation 765/2006 (Belarus): https://eur-lex.europa.eu/eli/reg/2006/765/oj
ACLED: https://acleddata.com/
UCDP: https://ucdp.uu.se/
compliance/export-sanctions/export-control-memo.md
compliance/export-sanctions/sanctions-screening.md
compliance/webshop/algemene-voorwaarden.md

Signed for Incutec BV: Stan Coene, Bestuurder

Politique d’Usage Final