Export Compliance Policy

Blackwell Group Inc. (BGI)
Effective Date: 01-06-2026

1. PURPOSE

This Export Compliance Policy (“Policy”) establishes the requirements governing the export, re-export, transfer, resale, and use of products sold or distributed by Blackwell Group Inc. (“BGI,” “Company,” “we,” “our,” or “us”).

BGI is committed to strict compliance with all applicable United States export control laws, regulations, and economic sanctions programs.

2. APPLICABLE LAWS & REGULATIONS

BGI operations are subject to, and conducted in accordance with, applicable U.S. laws and regulations, including but not limited to:

Export Administration Regulations (EAR) administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)
U.S. economic and trade sanctions programs administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
U.S. embargoes, restricted party regulations, and related federal statutes

Customers and purchasing entities are solely responsible for compliance with all applicable export and import laws.

3. NO WARRANTY OF EXPORT ELIGIBILITY

BGI makes no representations or warranties, express or implied, regarding:

Export eligibility of any product
Licensing requirements
Applicability of export classifications

All products are sold with the understanding that the purchaser is solely responsible for determining export eligibility and compliance obligations.

4. RESTRICTED DESTINATIONS

BGI does not ship, export, or facilitate transactions involving:

Countries or regions subject to U.S. embargoes or sanctions
Jurisdictions restricted under applicable U.S. law

Unless expressly authorized by law or license, such transactions will be:

Denied
Canceled
Subject to enhanced compliance review

5. PROHIBITED END USERS

BGI does not conduct business with:

Individuals or entities listed on U.S. government restricted or denied party lists
Specially Designated Nationals (SDNs) or blocked persons
Parties acting on behalf of restricted entities
Individuals or organizations engaged in unlawful or prohibited activities

BGI reserves the right to:

Screen all transactions and customers against applicable government lists
Deny or terminate transactions based on compliance findings

6. PROHIBITED END USES

Products sold by BGI may not be used for:

Any unlawful purpose
Military, paramilitary, or restricted defense applications where prohibited
Activities involving weapons proliferation or prohibited surveillance
Any use in violation of U.S. export control laws

Purchasers are solely responsible for ensuring lawful end use.

7. CUSTOMER CERTIFICATION

By purchasing from BGI, you certify that:

You will comply with all applicable export control and sanctions laws
You are not located in, or acting on behalf of, a restricted country, entity, or individual
You will not export, re-export, transfer, or resell products in violation of applicable laws
You will not use products for prohibited end uses

BGI reserves the right to rely on this certification and take action if it is found to be false or misleading.

8. RE-EXPORT, TRANSFER & RESALE RESTRICTIONS

Customers are prohibited from:

Re-exporting or transferring products without compliance with applicable laws
Selling or distributing products to restricted parties or jurisdictions
Diverting products from intended lawful use

All downstream distribution must comply with applicable export control regulations.

9. INTERNATIONAL ORDERS

BGI may, at its sole discretion, accept or decline international orders.

For approved international transactions:

Customers are responsible for all duties, taxes, and import fees
Customers must ensure compliance with destination country laws
Shipments may be subject to inspection, delay, or seizure by authorities

BGI is not responsible for:

Customs delays or seizures
Import compliance failures
Regulatory restrictions imposed by foreign governments

10. ORDER REVIEW & COMPLIANCE SCREENING

BGI reserves the right to:

Review and screen all transactions for export compliance
Request additional documentation or certification
Delay, hold, or cancel orders pending compliance verification

Orders that raise compliance concerns may be refused without further obligation.

11. REGULATORY CHANGES

Export laws and regulations may change at any time.

BGI is not responsible for:

Changes in export requirements after purchase
Licensing or regulatory obligations imposed after sale
Customer inability to export or use products due to legal changes

12. LIMITATION OF LIABILITY

To the fullest extent permitted by law, BGI shall not be liable for:

Delays, denials, or cancellations due to export compliance requirements
Seizure, restriction, or forfeiture of products by government authorities
Customer failure to comply with applicable laws
Indirect, incidental, or consequential damages

All products are sold subject to applicable export laws and restrictions.

13. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless BGI, its officers, employees, and affiliates from any claims, liabilities, damages, or expenses arising from: