Export Control Policy

1. Export Control Policy Overview

This export control policy outlines how Sucatec Pte Ltd ensures compliance with applicable export regulations, sanctions compliance policy requirements and international trade compliance obligations.

Sucatec Pte Ltd is committed to full compliance with all applicable export control laws, trade regulations and economic sanctions. This policy defines the responsibilities and controls applied to ensure that goods and services are supplied in accordance with international legal requirements.

2. Scope

This policy applies to all products, services, transactions and business activities conducted by Sucatec Pte Ltd, including:

• Transfers of technical data and documentation
• Direct and indirect exports
• Re-exports and transhipments
• Sales to distributors, resellers and end users

This export control policy applies to all transactions and must be considered in all international trade activities. This policy should be considered alongside compliance policy and related regulatory requirements. This export control policy should be read in conjunction with our Compliance Policy.

3. Regulatory Compliance

Sucatec Pte Ltd operates in compliance with applicable export control and sanctions regulations as part of its export regulations policy, including but not limited to:

• Singapore export control regulations
• European Union sanctions and export controls
• United States export control laws, including EAR and OFAC sanctions where applicable

Where multiple jurisdictions apply, the most restrictive requirements shall be followed. This includes alignment with broader supply chain requirements such as our Conflict Minerals Policy.

4. Restricted Parties and End Use

Sucatec Pte Ltd will not supply goods or services to:

• Individuals or entities listed on applicable sanctions or restricted party lists
• Parties involved in unlawful or prohibited activities
• Transactions where the end use is unclear, misrepresented or suspected to be restricted

Customers and suppliers may be subject to restricted party screening against applicable sanctions lists.

5. Customer and Supplier Responsibilities

Customers and suppliers must:

• Comply with all applicable export control and sanctions laws
• Provide accurate and complete information regarding end use and destination
• Not divert products to restricted countries, entities or uses
• Notify Sucatec Pte Ltd of any changes affecting compliance

Failure to comply may result in refusal or termination of supply. Sucatec supports compliant supply through structured programmes including vendor-managed inventory (VMI).

6. End-Use Restrictions

Products supplied by Sucatec Pte Ltd must not be used in connection with:

• Military applications where prohibited
• Weapons, nuclear, chemical or biological programmes
• Any activity restricted under applicable export control laws

Where required, end-use statements or declarations may be requested. These controls should also be considered alongside ESD and cleanroom consumables where applicable.

7. Risk-Based Compliance Approach

Sucatec Pte Ltd applies a risk-based approach to export control policy implementation, focusing on identifying and managing compliance risks across products, customers and jurisdictions.

This includes:

• Assessment of product classification where applicable
• Review of customer location and business activity
• Evaluation of end-use and destination risks
• Application of restricted party screening procedures

This approach supports effective international trade compliance while maintaining operational efficiency.

8. Documentation and Record Keeping

Sucatec Pte Ltd maintains appropriate records to support compliance with export control requirements, including:

• Compliance declarations where applicable
• Transaction records
• Customer and supplier information

9. Right to Refuse or Suspend Supply

Sucatec Pte Ltd reserves the right to:

• Refuse, suspend or cancel any transaction
• Request additional documentation or verification
• Terminate business relationships where compliance concerns arise

No liability shall arise from actions taken to ensure regulatory compliance.

10. Monitoring and Review

This policy is:

• Supported by internal controls and compliance checks
• Reviewed periodically to reflect regulatory changes
• Communicated internally and, where appropriate, externally

11. Contact Information

For further information regarding export control, sanctions compliance or international trade compliance, please contact:
Sucatec Pte Ltd
Email: [email protected]

This Export Control Policy is reviewed periodically and updated to reflect current regulations, standards and company practices.

Last updated April 2026