EXPORT COMPLIANCE

Comtech, including its subsidiaries (collectively the “Company” or “Comtech”) takes its position as a market leader and corporate citizen with the utmost seriousness. As a leading global provider of next-generation 911 emergency systems and secure wireless communications technologies to commercial and government customers around the world, good citizenship, protection of U.S. government confidential information, and compliance with U.S. and other applicable countries’ laws are priorities for the company.

International Trade
The Company must comply fully with all applicable trade control laws and regulations governing sanctions and export and import controls in the U.S. and other countries in which we do business. These include, but are not limited to, the laws and regulations administered by:
• the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”),
• the U.S. Department of State, Directorate of Defense Trade Controls,
• the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and Census Bureau,
• the U.S. Office of Antiboycott within the BIS and the U.S. Department of the Treasury’s Internal Revenue Service, as well as
• similar laws and regulations in other jurisdictions, such as Canada, China, India, Russia, Singapore, and the UK.

In order to comply with such laws, some Comtech products, technology or services may not be exported to certain:
• Entities, groups, or organizations
• Destinations
• Persons from certain countries

without first obtaining an export license or other export authorization from the appropriate government authorities. Where a license or authorization must be obtained, Comtech will either obtain such authorization, or if it cannot be obtained, not proceed with the transaction.

Penalties and punishment for violations of export laws can be severe, including:
• Monetary fines
• Loss of export privileges
• Denial of export licenses and authorizations
• Blacklisting by government regulators
• Embarrassment and negative publicity
• Imprisonment

Anti-Corruption
The Foreign Corrupt Practices Act (“FCPA”) and similar anti-corruption and anti-bribery laws in other countries generally prohibit making, promising, or offering payments or gifts to government officials to obtain or retain business or to secure any improper business advantage. In connection with the performance of any purchase order or agreement with Comtech, no party working directly or indirectly with or for Comtech shall offer or make any payments or provide anything of value to a government official to influence an official action that awards business, retains business or secures an improper business advantage in connection with Comtech’s products. In the event of an alleged breach of the anti-corruption regulations, the party or parties involved shall cooperate in good faith with Comtech to determine whether an alleged breach occurred. In such case, the party agrees to furnish Comtech all information requested to establish compliance with the party’s anti-corruption obligations.

For more information about Comtech’s ethical practices, please visit our Standards of Business Conduct.