Export Control & Compliance Policy

Effective Date: 1st December 2023

Mentor Distribution Group Limited and its subsidiaries (known as "Mentor Distribution") are committed to complying with all applicable laws and regulations, including those related to export controls and sanctions. The purpose of this policy is to ensure that transactions between Purchaser and Mentor Distribution comply with applicable export control regulations. This policy applies to the products and technology provided by Mentor Distribution.

Policy Requirements: The products, software, and/or technology to be provided by Mentor Distribution (collectively "Products") may be subject to U.S. export control laws and will not be resold, reexported, or retransferred, directly or indirectly, to any person or entity in violation of the U.S. Export Administration Regulations ("EAR," 15 C.F.R. Part 730, et. seq.) or the sanctions and embargo laws and regulations promulgated and enforced by the U.S. Department of Treasury’s Office of Foreign Asset Controls ("OFAC" regulations found at Chapter V to 31 C.F.R., et. seq.). Purchaser certifies compliance with the above-mentioned regulations for the Products provided by Mentor Distribution.

Export Control Laws:

1. The Products will not be exported, reexported, or transferred (in-country) without a license in violation for a destination, end use, or type of end user described in Section 744.23 of the EAR.

2. The Products will not be resold, re-exported, rented, leased, transferred, diverted, or otherwise disposed of, directly or indirectly, to any person or entity on any U.S. Government restricted party lists, including but not limited to, the Specially Designated Nationals ("SDN") List, the Entity List, the Sectoral Sanctions List ("SSI"), the Unverified List, or the Russia-related CAPTA and Entities Directives in violation of U.S. export controls and sanctions laws, or any other applicable countries’ laws and regulations. (The U.S. restricted party lists can be accessed at: https://trade.gov/consolidated-screening-list

3. The Products will not be licensed, resold, re-exported, rented, leased, transferred, diverted, transshipped through or otherwise disposed of in any country or territory sanctioned under U.S. laws (which includes the Crimea region of Ukraine, the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”) regions of Ukraine, North Korea, Cuba, Iran and Syria without prior authorization from the U.S. or any other applicable government. For a complete list of restricted destinations, please see: https://ofac.treasury.gov/sanctions-programs-and-country-information

Prohibited End Uses: The Products will not be used in the design, development, fabrication, maintenance, operation, testing, or stockpiling of the following:

• Nuclear weapons or materials
• Explosive devices
• Rocket or missile systems
• Unmanned air vehicle systems
• Chemical, biological, or radiological weapons or delivery systems
• Cluster munitions
• Anti-personnel mines
• Microprocessors for military use

Additional Restrictions: The Products will not be licensed, resold, re-exported, rented, leased, transferred, diverted, or otherwise disposed of (directly or indirectly) to any person or entity that is a military end-user, or for a military end-use, in China, Russia, Belarus, Venezuela, Cambodia, Burma (Myanmar)] without prior authorization from the U.S. or any other applicable government. Additionally, the Products will not be transferred to any person or entity that is a military intelligence end-user or for a military intelligence end-use in the aforementioned countries without prior authorization from the U.S. or any other applicable government.

Foreign Direct Product (FDP) Rules: Purchaser has reviewed the criteria for the Foreign Direct Product (FDP) Rules under Section 734.9 of the EAR. Purchaser attests that non-U.S.-made items that are subject to the EAR under these FDP Rules, and that are designed, developed, fabricated, or produced by or with the Products provided by Mentor Distribution, will not be exported or reexported to, or transferred in-country, in violation of the EAR.

Ownership Certification: Purchaser and the end user (if different from Purchaser) do not include any person or entity that is a blocked person on the SDN List, Entity List, SSI List, or Russia-related CAPTA and Entities Directives, directly or indirectly owning 50 percent or more in the aggregate of Purchaser or the end user, as applicable.

Truthfulness and Notification: Purchaser certifies that all information supplied to Mentor Distribution is true and correct to the best of its knowledge and belief and will promptly notify Mentor Distribution if any statement in this policy becomes untrue, inaccurate, or incomplete, or if it becomes aware of any breach of any obligation set forth in this policy.

Consequences of Non-Compliance: Purchaser acknowledges that providing false statements or concealing material facts may result in a breach of any agreement or contract between Purchaser and Mentor Distribution.

Mentor Distribution reserves the right to terminate any agreement, purchase order, or contract with immediate effect and without any penalty or liability of any kind, by sending written notice of termination to Purchaser. Mentor Distribution also reserves the right to refuse to conduct business with parties who fail to adhere to this policy document or who certify false information.

Additionally, by continuing to purchase from Mentor Distribution, you explicitly acknowledge our Export Control and Compliance Policy as an addendum to our standard terms and conditions. Mentor Distribution may require the Owner/Managing Director or other executive of purchasing entities to sign and return a copy of this policy, acknowledging the legal requirements and promising to adhere to our export control and compliance policy. This step helps ensure that all responsible parties within purchasing entities are fully aware of and committed to compliance with our export control regulations and obligations.

For further information about this policy, please contact us via admin@mentordistributiongroup.com