IT Globals Trade Compliance Policy

Effective Date: 1st March 2023

Purpose

This Trade Compliance Policy aims to ensure that IT Global and its employees comply with all applicable laws and regulations related to international trade, including but not limited to export controls, economic sanctions, and import regulations. Compliance with these laws is critical to maintaining the integrity of our business operations, protecting our reputation, and mitigating legal and financial risks.

Scope

This policy applies to all IT Global employees, contractors, agents, and representatives who engage in international trade activities, including exporting, importing, re-exporting, or transferring goods, services, software, or technology across international borders.

Compliance Responsibilities

3.1. Management Commitment: Senior management at IT Global is committed to upholding trade compliance and ensuring that adequate resources are allocated for its implementation. Management will actively support and promote a culture of compliance throughout the organization.

3.2. Designated Compliance Officer: A qualified individual will be designated as the Trade Compliance Officer, responsible for overseeing and managing trade compliance efforts, monitoring regulatory changes, providing guidance to employees, and conducting internal assessments and audits.

3.3. Employee Responsibility: All employees must familiarize themselves with the applicable laws and regulations pertaining to international trade that are relevant to their job responsibilities. Employees are required to comply with this policy, seek guidance when needed, and promptly report any potential violations or concerns to the Trade Compliance Officer.

Export Controls

4.1. Classification and Screening: All exports, re-exports, and transfers of goods, software, technology, or services must be classified and screened in accordance with applicable export control laws. Employees must ensure that the export items are properly classified and screened against relevant export control lists, including but not limited to the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

4.2. Licensing: Employees must obtain the necessary export licenses, authorizations, or exemptions before engaging in any export activities that require such permissions under applicable laws and regulations.

4.3. Denied Parties Screening: Employees must screen all parties involved in export transactions against relevant denied party lists, such as the U.S. Bureau of Industry and Security's Denied Persons List, Entity List, and Unverified List, as well as other relevant international lists. Transactions involving denied parties are strictly prohibited.

Economic Sanctions

5.1. Prohibited Parties: IT Global will not engage in any transactions or business activities with individuals, entities, or countries subject to economic sanctions imposed by relevant government authorities, including but not limited to the U.S. Office of Foreign Assets Control (OFAC) sanctions programs.

5.2. Screening: To ensure compliance, employees must screen all parties involved in transactions against applicable sanctions lists. Transactions involving sanctioned parties are strictly prohibited unless specifically authorized under applicable laws and regulations.

Import Compliance

6.1. Customs Compliance: All imports must comply with applicable customs laws, regulations, and requirements, including but not limited to proper documentation, valuation, classification, and origin determinations. Employees involved in import activities must ensure accurate and timely submission of customs declarations and provide necessary information to customs authorities.

6.2. Trade Agreements and Preferences: Employees must comply with the rules and regulations associated with trade agreements and preferential tariff programs to maximize benefits and ensure compliance with relevant requirements.

7. Training and Awareness

IT Global will provide regular training and awareness programs to employees, contractors, agents, and representatives to ensure understanding and compliance with trade compliance laws, regulations, and internal policies. Training programs will cover topics such as export controls, economic sanctions, customs compliance, and the consequences of non-compliance.

8. Adhere to both U.S and global trade laws

- Screen end users against restricted US party list:

- Comply with anti boycott lawas effective in jurisdictions where Dell does business

- Ensure business is not carries out by individuals, entities, countries or territories sanctioned by the US (including, North Korea, Cuba, Iran, Sudan, Syria, Crimea, Russia, Belarus, Donetsk & Luhansk in Ukraine)

9. Monitoring, Auditing, and Reporting

IT Global will establish procedures for ongoing monitoring, internal auditing, and reporting to identify and address any trade compliance violations or potential risks. Employees are encouraged to report any concerns, potential violations, or suspicious activities to the Trade Compliance Officer or through an anonymous reporting mechanism.

10. Consequences of Non-Compliance

Failure to comply with this Trade Compliance Policy or applicable trade laws and regulations may result in disciplinary action, up to and including termination of employment. Non-compliance may also expose [Company Name] to legal and financial penalties, damage its reputation, and disrupt its business operations.

11. Policy Review and Updates

This Trade Compliance Policy will be periodically reviewed and updated as necessary to reflect changes in applicable laws, regulations, or business practices. Employees will be notified of any updates, and appropriate training and awareness programs will be conducted.