EXPORT COMPLIANCE Corporate Commitment to Export Compliance GB Software is committed to complying with all U.S. export/re-export laws and regulations (and foreign law where applicable). GB develops and implements policies and procedures to ensure compliance with all export laws and regulations. Every GB employee is responsible for adhering to all policies and procedures. If you are exporting or re-exporting GB software, U.S. export control applies to you, and you are required to ascertain your compliance obligations. Please contact the GB Software Legal Department with any questions regarding export compliance. Policy Statement Legal Laws and Regulations Export Control Classification Numbers Country Information Export Restrictions Export Compliance Resources Policy Statement As one of the leading providers of IT solutions to entities all over the world, GB Advisors, Inc ("GB") is committed to shipping its partner products in accordance with the export control laws and regulations of the United States and other countries. It is GB's policy to comply fully with United States and local export/re-export laws and regulations. It is the responsibility of all GB employees to ensure that under no circumstance should a transaction occur contrary to this policy. Violations of the export/re-export laws could subject GB to criminal penalties, civil penalties, including large fines, or the loss of export privileges. Non-compliance with the applicable rules by GB employees could also result in corporate discipline, including dismissal in appropriate cases. GB employees are expected to read the GB export guidelines and comply with all relevant policies and procedures. Please do not hesitate to seek clarification from the Legal Department if you have any questions concerning how the export laws and regulations apply to your role at GB. Sincerely, Alexander Guédez Barefield CEO / Founder Legal Laws and Regulations Export compliance entails the control of exports to protect U.S. national security and to uphold U.S. foreign policy interests. The U.S. Department of Commerce and the U.S. Department of the Treasury administer and enforce the following export compliance laws and regulations: Export Administration Regulations (EAR), 15.C.F.R. Parts 730 et seq., administered by the Department of Commerce Foreign Assets Control Regulations and other related sanctions programs regulations, 31C.F.R. Parts 500 et seq., administered by the Department of the Treasury At least one, if not both, of these regulations will apply to virtually all exports and re-exports made by GB. It is important to note that an export or re-export transaction need not necessarily involve a sale of product. Exports or re-exports can also include the shipment or electronic transmission of software or technology for beta, quality assurance, demonstration, or other purposes. The release of software source code or technology within the U.S. to a non-U.S. national or non-permanent resident alien is also an export. Violations of these laws are subject to criminal and civil penalties, including the loss of export privileges. Export Control Classification Numbers An Export Control Classification Number (ECCN) is a five-digit number, based upon a numbering system used by the U.S. Department of Commerce, and it is assigned to a particular product because of its technical or functional features. Country Information GB prohibits any export or re-export of partner software products to any destinations subject to U.S. embargoes or trade sanctions. The following countries are subject to U.S. embargo or restricted trade sanctions: Cuba Iran North Korea (Democratic Republic of Korea) Sudan Syria Please visit the Treasury Department Sanctions Program and Country Summaries to view more information on countries. Export Restrictions The U.S. Department of Commerce and the U.S. Department of Treasury administer and maintain U.S. government exclusion lists. GB Software does not ship products to any entity, whether in the U.S. or abroad, specified on these lists. They are prohibited end users. U.S. Department of Commerce Consolidated Screening List U.S. Treasury Department Specially Designated Nationals List Export Compliance Resources The U.S. Department of Commerce, Bureau of Industry and Security, is the government agency that administers and enforces export compliance law and regulation. The Department of Treasury, Office of Foreign Asset Control (OFAC), administers the laws and regulations pertaining to country trade sanctions and prohibited foreign nationals.