Export Control & Trade Compliance Policy

1. Purpose

This Export Control & Trade Compliance Policy (“Policy”) defines the principles, responsibilities, and procedures by which KV material s.r.o., including its affiliates (“KV material”), ensures compliance with applicable export control, sanctions, and trade laws.

KV material is committed to conducting its business in full compliance with all applicable international, European Union, and national export control and trade regulations.

2. Scope

This Policy applies to:

• All employees, officers, and directors of KV material
• All sales, procurement, engineering, logistics, and service activities
• All exports, transfers, and disclosures of goods, software, technology, and technical information

This Policy covers both physical shipments and intangible transfers, including electronic transmissions.

3. Applicable Laws and Regulations

• European Union export control regulations
• EU and UN sanctions regimes
• National export control laws of EU Member States
• Applicable foreign trade laws, where required by international obligations

In case of conflict between regulations, the more restrictive requirement shall apply.

4. Controlled Items

• Dual-use items
• Military or defense-related items
• Embedded software and technical documentation

KV material classifies its products and determines applicable export control classifications prior to export.

5. Restricted Countries, Parties, and End Uses

• Countries subject to comprehensive sanctions
• Restricted or denied persons or entities
• Prohibited or unauthorized end uses, including military, nuclear, chemical, or biological applications

All transactions are subject to screening against applicable sanctions and restricted-party lists.

6. Licensing and Authorizations

Where required, KV material shall obtain all necessary export licenses, permits, or governmental authorizations prior to shipment or transfer.

No export or transfer shall take place without the required approvals.

7. Customer and Partner Responsibilities

• Provide accurate and complete end-use and end-user information
• Comply with all applicable export control laws
• Not divert, re-export, or transfer KV material products in violation of applicable regulations

KV material reserves the right to suspend or terminate transactions where compliance cannot be ensured.

8. Recordkeeping and Documentation

• Classification documents
• Licenses and authorizations
• Shipping and customs documentation
• End-user statements

KV material maintains export-related records in accordance with applicable legal requirements.

9. Training and Awareness

KV material provides export control and trade compliance training to relevant employees.

Employees are required to understand and comply with this Policy and applicable procedures relevant to their roles.

10. Reporting and Escalation

Any suspected or actual export control violation must be reported immediately to KV material management or the designated compliance function.

Reports may be made without fear of retaliation.

11. Audits and Monitoring

KV material may conduct internal or external audits to verify compliance with this Policy.

Corrective actions shall be implemented promptly where deficiencies are identified.

12. Violations and Consequences

• Severe civil or criminal penalties
• Contractual liability
• Disciplinary action, up to and including termination of employment or business relationships

13. Governing Law

This Policy shall be governed by and interpreted in accordance with the laws of the Czech republic.

14. Policy Updates

KV material reserves the right to amend this Policy at any time to reflect changes in applicable laws or business practices.

The most current version shall be made available on KV material’s official website.