Export Control

DoppleSys Export Control Policy

Effective Date: January 1, 2025

1. Purpose

The purpose of this Export Control Policy is to ensure that DoppleSys ("the Company") complies with all applicable export control laws and regulations, including but not limited to the United States Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and the regulations administered by the Office of Foreign Assets Control (OFAC). The policy also applies to export control laws in other jurisdictions where the Company conducts business.

2. Scope

This policy applies to all employees, contractors, consultants, agents, and any other representatives of the Company. It covers all Company activities, including but not limited to the design, manufacture, marketing, sale, and shipment of products, software, and technology that are subject to export controls.

3. Policy Statement

It is the policy of the Company to:

1. Comply with all applicable export control laws and regulations in the countries where it operates.

2. Restrict the export of controlled items, software, and technology to prohibited destinations, end-users, or for prohibited uses.

3. Implement a robust export compliance program to identify, manage, and mitigate export risks.

4. Ensure that all employees involved in export-related activities are adequately trained and understand their responsibilities under this policy.

4. Definitions

1. Export: Any shipment, transmission, or transfer of controlled items, software, technology, or services to a foreign person or destination, including oral, visual, or electronic disclosures.

2. Deemed Export: The release of controlled technology or software to a foreign person in the United States, which is considered an export to the person’s home country.

3. Controlled Items: Items, technology, or software listed on applicable export control lists, including the Commerce Control List (CCL) and the United States Munitions List (USML).

4. Restricted Parties: Individuals, entities, or organizations identified on government-maintained lists (e.g., Denied Persons List, Entity List, SDN List) as being restricted or prohibited from receiving exports.

5. Responsibilities

1. Export Compliance Officer (ECO):

   • Oversee the Company’s export compliance program.

   • Maintain current knowledge of export control regulations.

   • Conduct periodic audits of export-related activities.

2. Managers and Supervisors:

   • Ensure that their teams comply with this policy.

   • Report any potential violations to the ECO.

3. Employees:

   • Understand and follow the procedures outlined in this policy.

   • Attend mandatory export compliance training.

   • Report any suspicious activity or potential violations to their supervisor or the ECO.

6. Compliance Requirements

1. Export Classification:

   • All products, software, and technology must be classified under the applicable export control list (e.g., EAR’s ECCN or ITAR’s USML).

   • Maintain documentation of classification determinations.

2. Restricted Party Screening:

   • Screen all customers, partners, and transactions against applicable restricted party lists using authorized tools.

3. Licensing:

   • Obtain required export licenses or other government authorizations prior to exporting controlled items, technology, or software.

   • Ensure licenses are properly documented and tracked.

4. Recordkeeping:

   • Maintain accurate records of export transactions for at least five (5) years or as required by applicable regulations.

5. Prohibited Activities:

   • Do not engage in transactions with embargoed countries or restricted parties without proper authorization.

   • Do not participate in unauthorized re-export or transfer of controlled items.

7. Training and Awareness

1. The Company will provide mandatory export compliance training to all employees involved in export-related activities.

2. Specialized training will be provided for employees handling controlled items or working with restricted technologies.

8. Violations and Reporting

1. Reporting Violations:

   • Any employee who suspects a violation of export control laws or this policy must report it immediately to their supervisor or the ECO. 

   • Third-parties who suspect a violation of export control laws or this policy are requested to please report it to the company's legal team via email to legal@dopplesys.com.

2. Consequences of Violations:

   • Violations of export control laws can result in severe penalties, including fines, imprisonment, and loss of export privileges.

   • Employees who violate this policy may be subject to disciplinary action, up to and including termination.

9. Audits and Monitoring

The ECO will conduct periodic audits of export-related activities to ensure compliance with this policy. Findings will be documented, and corrective actions will be implemented promptly.

10. Policy Updates

This policy will be reviewed and updated as necessary to reflect changes in export control laws and regulations. Employees will be notified of any significant updates.

11. Contact Information

For questions or concerns about this policy or export compliance:

• Email: legal@dopplesys.com 

Acknowledgment

All employees are required to acknowledge their understanding and compliance with this policy by signing the Export Control Policy Acknowledgment Form.