42GEARS POLICY

42Gears Global Trade Compliance (GTC) is responsible for import and export oversight, guidance, and enforcement to enable worldwide trade compliant business processes across 42Gears, in order to uphold and protect 42Gears's global trade privileges and ensure the success of 42Gears' business. GTC manages 42Gears' global trade compliance portfolio, and is responsible for global trade regulatory interpretation and coordination of policy advocacy. We have an internal corporate Global Trade Compliance Policy in place which explains in detail about import and export controls applicable to Employee(s), Client(s), Partner(s), Vendor(s) and all Third Party Vendor(s).
Any person or entity exporting or re-exporting 42Gears products directly or indirectly and via any means, including electronic transfer, is wholly responsible for doing so in accordance with the applicable export control and economic sanctions laws and regulations, including, but not limited to, the laws and regulations of the United States, United Kingdom, and the European Union.

Embargoed Jurisdictions Please direct any questions concerning export controls or this policy to the legal@42gears.com

EXPORT REGULATIONS

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.

PRODUCT CLASSIFICATION

Each commodity or software product has a respective Export Control Classification Number (ECCN) (per the United States Department of Commerce Export Administration Regulations), a Commodity Code (per the United States Census Bureau's Schedule B). For more information on the EAR please visit the Bureau of Industry and Security (BIS) website or contact their offices directly.

http://www.bis.doc.gov/ Bureau of Industry and Security, Washington, D.C. (202) 482-4811

In conformity with the applicable law, 42Gears has also obtained ECCN for a few of its products.

Product Name	ECCN
SureMDM	5D992 (C)
SureLock	Pending

ENC/RESTRICTED GOVERNMENT END USERS

Export or re-export of ENC/Restricted products to government entities in many countries requires specific authorization from the US government. However, government entities located in the following countries do not require a specific authorization to receive ENC/Restricted products: Austria, Australia, Belgium, Bulgaria, Canada, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, United Kingdom, and the United States.

RESTRICTIONS

In accordance with the United States and applicable export control and economic sanctions laws and regulations, all 42Gears products and services are prohibited for export/reexport/transfer (includes in-country transfer) to or access by (includes cloud access) the following:

Prohibited and/or Restricted Person Lists

42Gears product(s) may not be sold, exported, or re-exported to any person or entity designated as prohibited or restricted by the United States, United Kingdom, or European Union (including, but not limited to the U.S. Treasury Department’s list of Specially Designated Nationals or the U.S. Department of Commerce Denied Persons List or Entity List).

Prohibited Uses

42Gears product(s) may not be used for:

(i) military purposes, or 

(ii) use in connection with the development, production, handling, operation, maintenance, storage, detection, identification or dissemination of chemical, biological or nuclear weapons, or other nuclear explosive devices, or the development, production, maintenance or storage of missiles capable of delivering such weapons.

LEGAL DISCLAIMER

This information is provided as a general guidance to our customers and partners and each exporter is responsible for their own compliance with the applicable export laws and regulations.
42Gears expressly disclaims any liability whatsoever, including but not limited to, direct, indirect, incidental, special, or consequential damages in connection with or arising out of any information provided herein.

*42Gears make no representation or warranty as to its accuracy or reliability.