Our Company attaches great importance to international trade compliance and export control obligations.
Certain fiber optic gyroscopes (FOGs), inertial measurement units (IMUs), inertial navigation systems (INS), and related products developed, manufactured, and supplied by our Company, as well as associated technologies, software, and technical documentation, may be subject to export controls, dual-use item regulations, and other applicable trade control laws and regulations in China and other relevant jurisdictions, depending on factors including product specifications, technical performance, intended applications, end use, and end user.
For transactions involving controlled products, technologies, software, or technical data, our Company conducts compliance reviews in accordance with applicable laws, regulations, and export control requirements. Such reviews may include, but are not limited to, product classification, technical specifications, end-user screening, end-use verification, destination assessment, and transaction-party screening. Where required by applicable law, the Company will obtain the necessary licenses, approvals, permits, or other required documentation prior to conducting the relevant transaction.
Certain foreign laws and regulatory regimes may impose export controls on inertial navigation systems, navigation equipment, and aerospace-related equipment. For example, under the applicable U.S. regulatory framework, certain inertial navigation and navigation equipment may be subject to the Export Administration Regulations (EAR) and the Commerce Control List (CCL). Where a product, technology, or service falls within the jurisdiction of the International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML), the applicable ITAR requirements shall also be observed.
Accordingly, no customer, business partner, or other relevant party may, without the necessary compliance review and authorization, use, transfer, re-export, or otherwise dispose of the Company's products, technologies, software, or related technical information for restricted end uses, restricted end users, or restricted destinations, or take any action intended to circumvent applicable export control or trade restrictions.
The Company reserves the right, in accordance with applicable laws, regulations, regulatory requirements, and the specific circumstances of a product or transaction, to review, restrict, suspend, or refuse any transaction.
This statement sets forth the Company's general principles regarding trade compliance and does not constitute legal advice or a legal determination with respect to any specific product, transaction, end user, end use, or destination. The applicable export control classification and licensing requirements for a particular product or transaction shall be determined in accordance with applicable laws and regulations and, where applicable, the final determination of the competent regulatory authorities.