Trade Compliance Policy Statement

This trade compliance policy reflects our commitment to operate in accordance with our code of ethics and business conducts. It also recognizes that failure to meet trade compliance requirements can have serious consequences for us, including damage to the Company’s reputation, monetary penalties, and suspension/revocation of the company’s exporting or importing privileges with a resulting negative impact to our customers. Thus, we are committed to the implementation, maintenance and continuous improvement of a robust trade compliance policy which integrates compliance activities into our business processes.

1. Export Compliance

•       All exports are to be accurately declared and applicable under the laws of Singapore.

•       Shipping documentation shall accurately describe item(s) being shipped as well as the applicable export classification.

2. Import Compliance

•       All imports are to be accurately described and applicable under the laws of Singapore.

•       All Customs entries shall accurately state all required information, including the importer of record’s name and address, importer number, quantity, value, classification, duty preference eligibility, and country of origin for the imported items.

3. Sanctions Compliance

We shall not participate in transactions in which the destination, end-use, or end-user is subject to a sanctions program, including, but not limited to, those programs maintained by United States’ Office of Foreign Assets Control (a/k/a OFAC).

4. Anti-Boycott Compliance

•       Any requests received by anyone to support a trade boycott of any country are to be reported to the Board of Directors of the company in accordance with the Reporting and Investigation policy; and

•       The Board of Directors shall assess whether any such requests to participate in a boycott could violate applicable anti-boycott regulations or otherwise could negatively impact the company.

•       We shall not participate in any trade boycott without the prior written approval of the Board of Directors.

5. Compliance Responsibility

All employees are responsible for supporting the principles contained in this policy

This policy has been approved by our Board of Directors. It will be reviewed, and if necessary revised, annually to keep up to date. We welcome interested parties’ comments on the enforcement of the policy and the policy itself.

Rev 1.2018