Trade Compliance Policy

• «National Security & Communications» strictly adheres to all international trade regulations, including export controls, economic sanctions and customs requirements. It is subject to global trade controls and economic sanctions that prohibit it from doing business with certain countries, organizations and individuals. The Company also complies with applicable customs requirements when importing and exporting goods.

• Key trade compliance obligations include complying with applicable customs requirements when importing and exporting goods, complying with State Sponsor of Terrorism (SST) policies that require government approval to proceed with a transaction, and using only the services of customs agents approved by the company. «National Security&Communication». Customers are expected to understand and comply with U.S. export control laws and regulations, obtain necessary licenses or other government approvals to use, transfer, import, export or re-export National Security & Communications products, software, technology or services, and comply with applicable laws and regulations of other countries on import and export controls. National Security & Communications also complies with the Export Administration Regulations, which govern the export, re-export and distribution of many commercial items.

• Customers are expected to understand and comply with U.S. export control laws and regulations, obtain necessary licenses or other government approvals to use, transfer, import, export or re-export National Security & Communications products, software, technology or services, and comply applicable import and export control laws and regulations of other countries.

• The Export Administration Regulations, which are contained in 15 C.F.R. § 730 et seq., are administered by the Bureau of Industry and Security, part of the U.S. Department of Commerce. These rules govern the export, re-export and sale of many commercial items, including goods, technology and software that may be specified in a commercial agreement.

• Economic sanctions laws are enforced by the Office of Foreign Assets Control, US Department of the Treasury, with a review of OFAC sanctions. Under U.S. export laws, products and services may not be sold directly or indirectly through third parties into prohibited countries or into the territory of a prohibited country at an Embassy or Consulate without a U.S. Government license or other official authorization.

• When selling products or services, it is necessary to check the partner, the final recipient in the SDN list https://sanctionssearch.ofac.treas.gov/, which includes specially designated citizens and blocked persons, as well as individuals and legal entities included in other government lists USA for example:
• List of legal entities
• List of legal entities with the participation of blocked persons
• List of legal entities, the final beneficiary is on the SDN lists
• Terrorists
• Drug dealers
• Proliferators of weapons of mass destruction
• Criminal organizations
• Prohibited end uses of nuclear technology
• Missile technology includes space exploration activities and activities using unmanned detailed vehicles
• Chemical or biological weapons
• Marine nuclear propulsion system
• Military end users
• Weapons of mass destruction
• Certain activities related to oil and gas exploration and production
• Follow all your business unit procedures regarding the import of goods.
• Provide accurate, complete and timely information to your enterprise's customs authorities for import transactions, including the classification of goods.
• Ensure full compliance with the special program requirements before claiming reduced customs duty rates. Export control
• Conduct a classification assessment of exported products to identify goods, technology or software that require export authorization.
• Follow policy to ensure that no parties are on watch lists.
• Do not conduct business with State Sponsors of Terrorism (SST) and/or sanctioned countries without authorization.

• «National Security & Communication» complies with contractual obligations and has the legal right to terminate the relationship and suspend the fulfillment of contractual obligations in the event of a violation of the law by the Partner. The company may limit or close access to receiving products or services specified in the agreement for an indefinite period of validity. Violations of the laws or terms set forth in this policy may be subject to U.S. civil penalties which may exceed US$1 million per export or shipment and criminal penalties of US$1 million per export or shipment and imprisonment. up to 20 (twenty) years. US authorities could also ban companies suspected of violating these laws, which restrict access to US goods and technology, US banks and US financial markets, and block travel to and from the United States.

• It is recommended that each exporter, re-exporter or other party to a cross-border transaction develop an Export Compliance Program. The Export Compliance Program ensures compliance with export control and sanctions laws, including EAR and OFAC sanctions, as well as applicable local laws. The developed program will help manage exports and comply with licensing conditions, avoiding potential fines in case of unintentional violation.

• «National Security&Communication» and «National Security&Communication» customers are expected to conduct due diligence on their clients or end users to identify any red flags or potential limiting circumstances. A red flag is any circumstance in a transaction indicating that the sale or export may be for a limited end use, end user, or limited purpose: Place, purpose, product and people. The Consolidated Control List (CSL) is a list of shipments that are subject to U.S. government restrictions on certain exports, reexports, or transfers of goods. It includes the Commerce, State, and Treasury Departments' export screening lists and can be used to assist industry in conducting electronic screening of potential participants in regulated transactions. Companies headquartered in a prohibited country or branches located overseas in a non-prohibited country may be red flags. Delivery times are vague, delivery routes are tortuous, the final destination is a traditional transshipment point, may also be red flags. The customer is using a PO Box or UPS store as the delivery address, or a freight forwarder is listed as the item's final destination, or the customer has indicated that they will use a freight forwarder, could also be red flags.

• Certain products require export or import licenses, such as products with advanced encryption capabilities or products specifically designed or modified for aerospace/defense end uses.

• The item ordered is not compatible with the technical level of the country it is being shipped to, for example, semiconductor manufacturing equipment being shipped to a country that does not have a semiconductor industry could also be a red flag.

•  Important principles and recommendations:

• Compliance with all applicable export control and sanctions laws is mandatory for both us and our contracting partners.
• Comply with US prohibitions on doing business in or with sanctioned countries (including Cuba, Iran, North Korea, Syria and Crimea, Belarus, Russian Federation) and with sanctioned individuals and entities.
• End users, product use, and final destination must be monitored in accordance with export control laws.
• Partners must take all necessary measures to comply with laws.

• Failure to comply with legal compliance obligations may result in termination of the partnership with «National Security & Communications» and other actions, including civil and criminal penalties.

Entry date: 04/03/2024