Export controls & trade compliance

1. Purpose

This policy ensures that HLD Group complies with export control laws governing the transfer of goods, software, technology, and technical data across borders and to foreign persons. Breaches of export control law carry severe criminal and civil penalties and can result in loss of export privileges.

2. Scope

This policy applies to all exports, re-exports, and transfers of controlled items, software, and technology by HLD Group, including electronic transfers and deemed exports to foreign persons, and to all personnel involved in such activities.

3. Definitions

• Export — sending or taking a controlled item, software, or technology out of a country, including electronically
• Re-export — transfer of a controlled item from one foreign country to another
• Deemed export — release of controlled technology or technical data to a foreign person, including within one country
• Foreign person — an individual or entity that is not a national or permanent resident of the relevant country
• Dual-use item — an item with both civilian and military or proliferation applications

4. Legal framework

• International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120–130, for defence articles, services, and technical data
• Export Administration Regulations (EAR), 15 CFR Parts 730–774, for dual-use and commercial items
• US Office of Foreign Assets Control sanctions programs, which intersect with export controls
• Defence Trade Controls Act 2012 (Cth) and the Customs Act 1901 (Cth) for Australian export controls
• The Wassenaar Arrangement and other multilateral export control regimes as implemented in national law

5. Classification and licensing

Items, software, and technology are classified to determine their export control status before export. Where an export requires a licence or authorisation, it is obtained before the transfer occurs. Exports to embargoed destinations or prohibited end users are not made, and end-use and end-user screening is performed.

6. Deemed exports and technology control

Access by foreign persons to controlled technology or technical data — including access by employees, contractors, and visitors within a single location — is a deemed export and is controlled accordingly. Technology control plans and access segregation are applied where required, and personnel handling controlled technology are screened.

7. Screening and record-keeping

• Parties to transactions are screened against restricted and denied party lists
• Export classifications, licences, and screening results are documented and retained
• Records are kept for the period required by the applicable regulation (generally at least five years)

8. Reporting violations

Suspected export control violations are reported immediately to the compliance function, which assesses voluntary self-disclosure obligations. Reporting is protected under the Whistleblower and Speak-Up Policy.

9. Roles, enforcement, and review

The compliance function, with legal counsel, owns this policy. Controls required by law cannot be waived internally. Breach may result in disciplinary action, personal liability, and referral to authorities. This policy is reviewed at least annually and on any change to applicable controls.