This trade compliance policy reflects our commitment to operate in accordance with our code of ethics and business conducts. It also recognizes that failure to meet trade compliance requirements can have serious consequences for us, including damage to the company’s reputation, monetary penalties, and suspension/revocation of the company’s exporting or importing privileges with a resulting negative impact to our suppliers and customers. Thus, we are committed to the implementation, maintenance and continuous improvement of a robust trade compliance policy which integrates compliance activities into our business processes.

A. Export Compliance
• All exports are to be accurately declared to the relevant officials of the export country, if applicable, under the laws of the export country;
• Shipping documentation shall accurately describe item(s) being shipped as well as the applicable export classification and authorization; and
• We shall have proper authorization to export or re-export items or technology controlled by government regulations, including the International Trade in Arms Regulations (a/k/a the ITAR) and the Export Administration Regulations (a/k/a the EAR) in the United States. Such exports or re-exports may include intra-company and/or intra-country technology transfers to foreign persons – even if they are our employees.

B. Import Compliance
• All imports are to be accurately described to the relevant officials of the import country, if applicable, under the laws of the import country;
• All Customs entries shall accurately state all required information, including the importer of record’s name and address, importer number, quantity, value, classification, duty preference eligibility, and country of origin for the imported items; and
• We shall have proper authorization to import items or technology controlled by government regulations.

C. Sanctions Compliance
We shall not participate in transactions in which the destination, end-use, or end-user is subject to a sanctions program, including, but not limited to, those programs maintained by United States’ Office of Foreign Assets Control (a/k/a OFAC).

D. Anti-Boycott Compliance
• Any requests received by anyone to support a trade boycott of any country are to be reported to the Managing Director of the company in accordance with the Reporting and Investigation policy; and
• The Managing Director shall assess whether any such requests to participate in a boycott could violate applicable anti-boycott regulations or otherwise could negatively impact the company.
• We shall not participate in any trade boycott without the prior written approval of the Managing Director.

All employees are responsible for supporting the principles contained in this policy and working with contractors to monitor the company’s trade compliance.