DISPL EXPORT COMPLIANCE POLICY

1. It is the DISPL EXPORT COMPLIANCE POLICY (the “Policy”) of DISPLAYFORCE GLOBAL LIMITED, a company governed and construed under the laws of the Republic of Cyprus, having its registered office at 1 Iapetou Str, 4101 Agios Athanasios, Limassol, Cyprus, registered in the register of the Ministry of Energy, Commerce and Industry Department of Registrar of Companies and Intellectual Property under the number HE433772 (hereinafter called “DISPL”) to fully comply with all laws and regulations governing the export of both, products, services, software and technical data as contracted by DISPL with its suppliers, and its own products, services, software and technical data. Each employee must be dedicated to ensure such compliance. All sales, service, shipping, accounting and other personnel that may be involved in export shall be familiar with and review regularly:
   – EU trade policy web site: https://www.consilium.europa.eu/en/policies/trade-policy/ ,
   – U.S. Bureau of Industry and Security’s website at: http://www.bis.doc.gov/, and
   – Websites of national export control authorities
   to ensure compliance with regulations. Particular attention should be taken when releasing technical information to foreign nationals, whether abroad or not, in electronic transmission of data/software and when hand carrying exports.
   Under no circumstances shall DISPL personnel sell or ship any product contrary to applicable export laws or shall these laws be compromised for personal gain. Neither sales nor shipments are to be made to any individual and/or firm appearing in the Denied Parties Lists of the U.S., and/or in EU sanctions database, and/or in any applicable export controls and regulations and/or to any firms owned by or associated with the individuals of firms therein listed. Moreover, no orders or shipments are to be made to any country subject to economic or trade sanctions imposed by the U.S. and/or EU unless otherwise authorized by applicable laws. Failure to comply with these regulations may result in the imposition of criminal and/or civil fines and penalties, including imposition of huge penalties on DISPL.
   In addition, regulations are in effect that place emphasis on the end-use and/or end-user of exported items (see United States 15 CFR 744.1 General Prohibition 4). As a result, DISPL need to be vigilant in screening our customers and transactions. It is, therefore, more important than ever that the “Know Your Customer” principals are understood and implemented in order that DISPL can meet the required “know” standard.
   In particular, no transaction can be made when dealing with individuals, companies and countries involved with the proliferation of nuclear missile and chemical/biological related processes and/or weapons without a license from the U.S. Department of Commerce and/or applicable EU authority.
   This policy shall be brought to attention of every employee related to export (PLMs, PLSM, sales, service, logistics, accounting, etc.) and made available to any employee of the company by placing it at the announcement board, incorporating into the staff manual or by other means at the discretion of the GMs. On a regular basis all such personnel shall be trained on the scope and application of export control compliance.
   Non-compliance or possible non-compliance with any of the export laws and regulations that becomes known to any DISPL employee shall be immediately reported to CEO of DISPL.

2. Information on the U.S. regulations:

   – for short overview of the U.S. export control compliance please referrer to “Introduction to Commerce Department Export Controls” in “Export Control Basics” section at: https://www.bis.doc.gov/index.php.  
   – also please see (a) the U.S. Export Administration Regulations; (b) the U.S. International Traffic in Arms Regulations (ITAR); (c) applicable U.S. sanctions and embargoes administered by the U.S. Department of the Treasury (https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programsand-information).
   – Commerce Control List (CCL): The Bureau of Industry and Security (BIS) maintains the Commerce Control List (CCL) within the Export Administration Regulations (EAR), which includes items (i.e., commodities, software, and technology) subject to the export licensing authority of BIS. The CCL does not include those items exclusively controlled for export or reexport by another department or agency of the U.S. Government. In instances where agencies other than the Department of Commerce administer controls over related items, entries in the CCL contain a reference to these controls. The CCL is contained in Supplement No. 1 to part 774 of the EAR. Supplement No. 2 to part 774 of the EAR contains the General Technology and Software Notes relevant to entries contained in the CCL. For details, please consult EAR database at: http://www.bis.doc.gov
   – Commerce Country Chart: BIS also maintains the Commerce Country Chart. The Commerce Country Chart, located in Supplement No. 1 to part 738, contains licensing requirements based on destination and Reason for Control. In combination with the CCL, the Commerce Country Chart allows you to determine whether a license is required for items on the CCL to any country in the world. For details please consult EAR database at: http://www.bis.doc.gov.
   – License Exception: The License Exception is located in part 740 of the EAR. The Supplement No. 1 to part 740 contains the list of Country Groups A, B, C, D and E. A “License Exception” is an authorization contained in this part that allows the company to export or reexport under stated conditions, items subject to the Export Administration Regulations (EAR) that would otherwise require a license under General Prohibition One, Two, Three, or Eight as indicated under one or more of the Export Control Classification Numbers (ECCNs) in the Commerce Control List (CCL) in Supplement No. 1 to part 774 of the EAR and items subject to the EAR that would require a license based on the embargo policies described in part 746 of the EAR. In the Supplement No. 1 to part 740 the following countries CUBA, IRAN, NORTH KOREA, SUDAN and SYRIA are included into Country Group E:1 of Terrorist Supporting Countries where any export or re export is prohibited. For details please consult EAR database at: http://www.bis.doc.gov.

3. Lists To Check: The following lists may be relevant to your export or reexport transaction.

   – Denied Persons List: A list of individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order is prohibited. For details please check at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/denied-persons-list.
   – Unverified List: A list of parties where BIS has been unable to verify the end use in prior transactions. The presence of a party on this list in a transaction is a “red flag” that should be resolved before proceeding with the transaction. For details, please check at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/unverified-list.
   – Entity List: A list of parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations. The list specifies the license requirements that apply to each listed party. These license requirements are in addition to any license requirements imposed on the transaction by other provisions of the Export Administration Regulations. For details, please check at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list.
   – Specially Designated Nationals List: A list compiled by the Treasury Department, Office of Foreign Assets Control (OFAC). OFAC’s regulations may prohibit a transaction if a party on this list is involved. In addition, the Export Administration Regulations require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes "SDGT". "SDT", "FTO" or "IRAQ2". For details please check at https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
   – Debarred List: A list compiled by the State Department of parties who are barred by §127.7 of the International Traffic in Arms Regulations (ITAR) (22 CFR §127.7) from participating directly or indirectly in the export of defense articles, including technical data or in the furnishing of defense services for which a license or approval is required by the ITAR. For details please check at http://www.pmddtc.state.gov/compliance/debar.html.
   – Nonproliferation Sanctions: Several lists compiled by the State Department of parties that have been sanctioned under various statutes. The Federal Register notice imposing sanctions on a party states the sanctions that apply to that party. Some of these sanctioned parties are subject to BIS’s license application denial policy described in §744.19 of the EAR (15 CFR §744.19).
   – General Order 3 to Part 736 (page 9): General Order No. 3 was removed from the EAR in a final rule published on September 22, 2008 (73 FR 54499).
   For details, please consult “Lists to Check” section at: http://www.bis.doc.gov.

4. EU regulations relative to Russia and Crimea:

   – Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine with the latest amendment,
   – Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine with the latest amendments;
   – Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine with the latest amendments;
   – Council Decision 2012/642/CFSP of 15 October 2012 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine with the latest amendments; Based on Notice to economic operators, importers and exporters (2022/C 145 I/01) of European Commission.
   DISPL may update this Policy from time to time for legal or regulatory reasons or to allow the proper operation of DISPL site and services. Any changes will be notified via a suitable announcement on DISPL website.
   
   Updated on April, 2023