One of the fundamental policies adopted by xFusion Digital Technologies Co., Ltd (hereinafter referred to as "xFusion") is to abide by international export control laws and regulations including those of China, the US, and any other countries; to fulfill the export control obligations and responsibilities; and to sustain xFusion's corporate commitment to being an honest and responsible enterprise deserving of trust from its partners and customers. xFusion also believes that compliance with applicable export control laws and regulations enables xFusion to avoid and mitigate trade compliance risks, to enhance its competitiveness in international markets, and to protect xFusion's continued success.
Regarding for its awareness of export control laws and regulations, xFusion promises to abide by all export control laws and regulations related to corporate operation issued by the Chinese government, and international export control laws and regulations, including that of the US; and to support the international commitment of the Chinese government, including international obligations assumed by the Chinese government to execute related decisions in the UN Security Council; as an international company, xFusion adopts responsible attitude and measures toward export control, takes globalization requirements related to the company operations into consideration, and fulfills its responsibilities.
xFusion establishes and implementes its internal compliance program (ICP) based on a "catch-all" control regime, and prioritizes export control obligations above commercial profit.
If xFusion believes that the products, technologies, and services to be exported (physical or intangible) may be used for developing or manufacturing weapons of mass destruction, weapon delivery systems, or unauthorized conventional military equipment by customers or end customers, jeopardizing the national or regional peace or stability or falling into the hands of terrorist organizations, xFusion will, based on the principle of "catch-all" control, implement strict export control measures and refuse to export such products, technologies, and services. xFusion, based on the principle of deemed export control, conducts internal monitoring and implements regulations to prevent employees from being exposed to sensitive technologies and information that could be maliciously used by some individuals or organizations.
xFusion verifies agencies involved in business operations, including customs brokers, freight forwarders or consignors, to avoid potential risk of spreading and transfer. xFusion will not conduct business with companies or individuals with aforementioned risks.
To ensure effective implementation of the self-regulating mechanism, xFusion has set up a trade compliance working group comprised of leaders and representatives in each domain, which is in charge of incorporating trade compliance into end-to-end business activities and processes.
In terms of corporate system, the company has developed a corporate export control management system, established standard procedures for export inspection, saved relevant documents and information, conducted the publicity and training on export control laws and regulations, strengthened internal audits, and implemented the responsibility of each department involved in export control.
The entire staff of xFusion are required to work toward meeting xFusion's export control requirements and carrying out related corporate policies. Employees who violate xFusion's export control polices will be given an internal notice and be penalized seriously. Employees who violate national laws and regulations will be held legally accountable.
This statement applies to all departments, branches and subsidiaries of xFusion Digital Technologies Co., Ltd.
To comply with new rules concerning export control laws and regulations made by the Chinese government and other countries including the US and corresponding international commitments, xFusion will review this statement every year and revise it according to relevant laws and regulations.
xFusion Digital Technologies Co., Ltd.