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Export Controls
Compliance with Export and Economic Sanctions Laws
Jan.2026

Compliance with Export and Economic Sanctions Laws


Jan. 2026


Lumissil Microsystems International Limited and its affiliates(collectively “LMSL” or “Company”)are committed to comp lying with the applicable exp ort controls and economic sanctions laws and regulations. This is an update of LMSL’s company export control policy based on the applicable exp ort, re-exp ort, and trade and economic sanctions laws and regulations, including the Exp ort Administration Regulations (15 C.F.R. Parts 730-774) (“EAR”) issued by the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”), and the trade and economic sanctions regulations (31 C.F.R. Parts 500-599administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (collectively “Export and Economic Sanctions Laws”). LMSL hereby reminds you of the compliance with all the Export and Economic Sanction Laws and our policy, including the policy you’ve signed before which will be reinstated here and up dated based on the current laws and practice:


1. Distributor shall comply with all applicable laws and LMSL policy when performing the LMSL relevant business.


2. Distributor shall not disclose, sell, release, supply, exp ort, re-exp ort or otherwise transfer (hereinafter collective activities referred to as “sell”), either directly or indirectly, any LMSL’s Products, technology or information (collectively “LMSL Products”) to: (i) any countries or territories subject to comprehensive U.S. sanctions (or nationals of those countries, wherever located); these countries currently include Russia, Belarus, Cuba, Iran, North Korea, Syria, and the Covered Regions of Ukraine (Donetsk, Luhansk and Crimea); or (ii) any person, including entities, listed on or covered by any U.S. or U.N. list of sanctioned persons or other applicable list of sanctioned persons, including the BIS List of Denied Persons, BIS Entity List and OFAC’s List of Specially Designated Nationals and Blocked Persons, military-end-use list, and etc. without first obtaining the required authorization, which may include obtaining an exp ort license from the ap propriate governmental agency. Specifically, Distributor shall not be an agent, distributor, or otherwise engaging in any Confidential2transactions involving LMSL Products on the behalf of, or for the benefit of, any entity on the Entity List with a footnote designation (“FN Entity”), including footnote 1 (FN1), footnote 3 (FN3), footnote 4 (FN4) or footnote 5 (FN5)without first obtaining the required authorization, which may include obtaining an exp ort license from the ap propriate governmental agency. Further, this restriction covers any non-listed entity that is owned fifty percent (50%) or more owned, either directly or indirectly, individually or in the aggregate, by one or more entities on the BIS Entity List when one of those owners is a FN Entity per Part 744 of the EAR.


3. Distributor shall not sell any LMSL Products to any person that Distributor has reason to believe intends to, directly or indirectly, use or sell any LMSL Product that will used in the development, production, use, operation, installation, maintenance, rep air, overhaul, or refurbishing of a “supercomputer”, or incorporation into, or for the development or production of, any part, component, or equipment for a “supercomputer” located in or destined to Macau, China or a country in Group D:5. “Supercomputer” is defined as the following: “[a] computing ‘‘system’’ having a collective maximum theoretical compute capacity of 100 or more double-precision (64-bit) petaflops or 200 or more single precision (32-bit) petaflops within a 41,600 ft3 or smaller envelope.”


4. Distributor shall not sell, directly or indirectly, any LMSL Products to any person that the Distributor has reason to believe intends to, directly or indirectly, use or sell LMSL Products for any space, satellite or “supercomputer” applications, including without limitation to imaging, propulsion systems, or navigation.


5. Distributor shall not sell, directly or indirectly, any LMSL Products to any person that the Distributor has reason to believe intends to, directly or indirectly, use or sell LMSL Products for any weapons or proliferation related end-use, including without limitation, nuclear, missile, chemical, or biological weapons proliferation.


6. Unless otherwise ap proved, Distributor shall not sell, directly or indirectly, any LMSL Products to any person that Distributor has reason to believe intends to, directly or indirectly, sell any LMSL Products to a military or military intelligence end-user or military or military intelligence end-use. Specifically, this prohibition includes, but is not limited, to sales to military entities, third persons acting on behalf or for the benefit of a military entity, and any sale that would result in an LMSL Products being used to support or contribute to the operation, installation, maintenance, rep air, overhaul, refurbishing, development, or production of a military item.


Key definitions are below.


• A military end-user includes any of the following: national armed services (army, navy, marine, air force, or coast guard), national guard, national police, government intelligence or reconnaissance organizations, or any person or entity whose actions or functions are intended to support ‘military end uses.

•A military end-use includes any of the following: incorp oration into a military item, or a sale that will be used to support or contribute to the operation, installation, maintenance, rep air, overhaul, refurbishing, development, or production of a military item.

• A military item generally includes but is not limited to weapons, ammunition, military aircraft, military vessel, military electronics, gas turbine engines, surveillance equipment and associated technology; submersible vessels, military training equipment, armor, fire control, range finder, op tical and guidance and control equipment; and military detection protection equipment; as well as test, inspection and production equipment specially designed for any of the items; p arts, components, accessories, and attachments specially designed for any of the designated items; and software and technology for the development, production, and use of these items.

• 'Military-intelligence end use' means the “development,” “production,” operation, installation (including on-site installation), maintenance (checking), rep air, overhaul, or refurbishing of, or incorp oration into, defense articles/items which are intended to support the actions or functions of a 'military-intelligence end user', as defined in this section.

• 'Military-intelligence end user' means any intelligence or reconnaissance organization of the armed services (army, navy, marine, air force, or coast guard); or national guard.


7. Distributor certifies that itis not subject to any sanctions or exp ort controls restrictions imposed by the U.S., including but not limited to the OFAC’s List of Specially Designated Nationals and Blocked Persons or Entity List, or any other applicable jurisdiction.


8. Distributor certifies that it will cooperate with LMSL to assist LMSL with any internal compliance requirements related to the exp ort, re-exp ort or transfer of LMSL Products. It further certifies that all information it provides to LMSL is and will be true, complete and accurate.


9. If Distributor becomes aware they, or Distributors’ customers, may have violated the terms of the Distributor Agreement or the policy stated herein, Distributor shall notify LMSL promptly in writing of the potential breach. Distributor recognizes that a breach of the aforementioned agreement and policy may result in substantial harm to LMSL and will constitute a material breach to the Agreement. Distributor shall compensate LMSL for any harm or loss, including attorney fees, that LMSL incurs due to the breach.


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