EXPORT COMPLIANCE

Comtech Mobile Datacom Corporation Export Compliance

As one of the leading manufacturers of satellite-based tracking and messaging solutions using state of the art transceivers, Comtech Mobile Datacom Corporation (“CMDC”) is committed to full compliance with all export control regulations administered by the U.S. Department of Commerce, the U.S. Department of State, and other U.S. regulatory agencies. CMDC has implemented a detailed export control policy and export compliance program to ensure that there is no illegal diversion of CMDC’s high technology commodities and technical data to military, terrorist, or nuclear/missile/chemical weapons proliferation activities through the export or re-export of CMDC’s products or technology in violation of any U.S. law. The export control policy and compliance program has the full support of CMDC’s senior management.

Export Control Statement
Each sales order acknowledgement and commercial invoice issued by CMDC contains the following statement:

CMDC DOMESTICALLY SHIPS AND/OR EXPORTS THESE COMMODITIES, TECHNOLOGY OR SOFTWARE FROM THE UNITED STATES IN ACCORDANCE WITH THE EXPORT ADMINISTRATION REGULATIONS. DIVERSION CONTRARY TO U.S. LAW IS PROHIBITED.

Jurisdiction
The US Department of Commerce (DOC) and US Department of State (DOS) are the principal U.S. Government organizations that review and classify CMDC products. Based on formal reviews completed to date by either appropriate authorities within these departments or our legal counsel, the determination is made that CMDC’s current products are primarily subject to the Export Administration Regulations (EAR) administered by the DOC’s Bureau of Industry and Security (BIS). The EAR is available at http://www.bis.doc.gov/

CMDC will continue to review new products to ensure their proper classifications and will consult with legal counsel or the U.S. Government to ensure that these product classifications are up-to-date and correct.

Questions regarding the applicable ECCN for a particular CMDC product may be referred to CMDC’s Export Control Group at exportcontrols@comtechmobile.com

CMDC makes no representation or warranty as to the accuracy or reliability of the above information. Any use or reliance on such classifications is at the user’s own risk and without recourse to CMDC. CMDC is in no way responsible for any damages, whether direct, consequential, incidental, or otherwise, suffered by the user due to use or reliance on such classifications, for any purpose whatsoever.

Prohibitions
Embargoed/Sanctioned Nations:
The U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) maintains the listing of nations under embargo or sanction. Please refer to the OFAC web address http://www.treas.gov/offices/eotffc/ofac/, for additional details.

CMDC products are prohibited from being shipped to the following countries:

• Cuba
• Iran
• North Korea
• Sudan
• Syria

CMDC’s products or technology may not be exported to any country listed by OFAC unless specifically permitted by the U. S. Government under an official export document.

Prohibited Parties Listings:
The U.S. government regularly publishes and updates lists of persons and companies that are denied access to U.S. exports. These lists are accessible through the DOC/BIS web address http://www.bis.doc.gov/, under Exporter Resources – Lists to Check:

If an individual or company appears on any of these lists, CMDC will not permit any of its products or technology to be exported by or to that individual or company, unless CMDC receives U.S. government authorization for export or re-export.

Limitations/Prohibitions:
The U.S. Government administers export controls on certain products to certain destinations for national security purposes. Exporters of such products may be required to obtain export licenses from the U.S. government prior to exportation. In addition, the Government places limitations on the export of products that could be used in some of the following activities:

• Missile technology
• Foreign military applications
• Nuclear proliferation
• Drug trafficking
• Terrorism

Please refer to EAR Part 736 for more details at web address http://www.access.gpo.gov/bis/ear/ear_data.html

Violations
CMDC’s Export Controls Group will report any known violations of U.S. export control regulations to the appropriate government agencies:

• Bureau of Industry and Security, Office of Export Enforcement (OEE),
• Department of Homeland Security, U.S. Customs and Border Protection (CBP), or
• U.S. Department of State. Directorate of Defense Trade Controls.

Customer Purchase Order Requirements
All customer purchase orders sent to CMDC must include the following:

• End User Name (Address if available)
• End Use Country
• Clear (Foreign) Ship To Address (if goods are for export)

Note: All Exports from the U.S. require a commercial invoice. CMDC will not release shipments to freight forwarders or carriers without a CMDC commercial invoice or drop ship document provided by the customer.

Questions/Contacts
CMDC’s Export Controls Group is available to respond to questions or concerns. Please address any correspondence or inquiries to the following empowered official:

David A. Ulanow, Director of Contracts
Phone: 240-686-3325
Fax: 240-686-3301
Email: david.ulanow@comtechmobile.com