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Ipswitch

Export Compliance

It is the policy of Ipswitch, Inc. to fully comply with all laws and regulations governing the export of its products, services, software and technical data. Each employee must be dedicated to ensure such compliance. All Ipswitch personnel and partners shall be familiar with and review regularly the Ipswitch, Inc. Export Management System (EMS) to ensure compliance with government regulations. Particular attention is taken when releasing technical information to foreign nationals, whether abroad or in the United States, in electronic transmission of data/software and when hand carrying exports.

Under no circumstances shall Ipswitch, Inc. personnel or partners sell or ship any product contrary to United States export laws or shall these laws be compromised for personal gain. Neither sales nor shipments are to be made to any individual or firm appearing in the consolidated U.S. government screening lists or to any firms owned by or associated with the individuals of firms therein listed. No orders or shipments are to be made to any country subject to economic or trade sanctions imposed by the U.S. unless otherwise authorized by U.S. law. In addition, Ipswitch will not export our software to a third party or to an affiliate that is located in a country that is engaged in boycotting activities not sanctioned by the US and shall not make any sale that is prohibited under the Anti-boycotting Act (50 USCA 2407, Part 760). Failure to comply with these regulations may result in the imposition of criminal and/or civil fines and penalties, including incarceration for individuals and suspension of export privileges for Ipswitch, Inc.

All questions concerning whether a proposed sale, shipment or other transaction, domestic or international, complies with the export laws shall be immediately referred to Chuck Pollak ([email protected]), who manages the export compliance program at Ipswitch.

Non-compliance or possible non-compliance with any of the export laws and regulations that becomes known to any Ipswitch, Inc. employee shall be immediately reported to the Export Compliance manager.

Ipswitch, Inc.'s EMS summarizes and refers to the applicable laws and regulations (which will be updated as appropriate) that are excerpted from the U.S. Export Administration Regulations. The Export Compliance Manager has a complete set of the foregoing regulations.

For more information on the Export Control Classification Number (ECCN), Licensing Authority, and Commodity Classification Automated Tracking System (CCATS) for Ipswitch products, please consult the Product Classification Matrix.