Compliance

Compliance

MANAGEMENT STATEMENT OF POLICY AND COMMITMENT


Responsible business conduct International trade
Responsible trade.
Trusted operations.

At AIA, responsible business conduct and compliance with applicable international trade laws are fundamental to how we operate.

Export controls help prevent military goods, dual-use items, technology, and services from reaching unauthorized recipients or being used for prohibited purposes.

Compliance protects security and trust

Compliance protects national and international security, supports our continued participation in domestic and international programs, and safeguards the trust placed in AIA. Every person working for or on behalf of AIA is expected to understand and uphold the responsibilities relevant to their role.

Our policy

It is the policy of A.I. Armaments and its subsidiaries and affiliates, collectively referred to as “AIA,” to comply with all export-control, sanctions, customs, and international trade laws applicable to our activities.

These requirements include Dutch and European Union regulations and, where applicable, United States export controls.

AIA will not participate in any transaction prohibited by applicable law or for which a required license, authorization, or approval has not been obtained.

Scope of our responsibilities

AIA conducts its international trade activities in a manner intended to satisfy all applicable legal and regulatory obligations. These activities may include:

Sales and procurement
Import, export, transit, and shipment of controlled items
Brokering and other regulated services
Transfers, retransfers, and re-exports
Software, technical data, and controlled-technology transfers
Technical assistance and defense services
Demonstrations, repairs, maintenance, and training
Disposal or changes in ownership or use of controlled items

Assessment before proceeding

Before proceeding with a transaction, AIA seeks to understand the classification and regulatory status of the products, technology, software, and services involved. We also assess the countries, end users, intermediaries, and intended end uses connected with the transaction.

Transaction screeningReviewing countries, customers, end users, intermediaries, and other parties against applicable restrictions and sanctions.
Product classificationDetermining treatment of products, software, technology, and services under applicable export-control regimes.
Licensing and authorizationObtaining required licenses, permits, approvals, and other authorizations before controlled activities take place.
Partner due diligenceConducting appropriate checks on suppliers, agents, distributors, customers, and other business partners.
Training and awarenessProviding personnel with training and resources appropriate to their responsibilities, including military and dual-use requirements.
RecordkeepingMaintaining accurate and complete transaction and compliance records for periods required by applicable law.
Internal controlsEstablishing procedures, responsibilities, and designated compliance contacts to support effective decision-making.
Monitoring and corrective actionReviewing performance, investigating concerns, addressing weaknesses, and taking appropriate corrective measures.
Regulatory reportingMaking disclosures to competent authorities when required by applicable law.

A shared responsibility

Trade compliance is a shared responsibility. Employees are expected to:

Complete all required compliance training
Follow established procedures and internal controls
Seek guidance when a requirement is unclear
Pause a transaction when its legitimacy is uncertain
Promptly report suspected violations, errors, or compliance risks

We also expect suppliers, agents, distributors, customers, and other business partners to conduct business ethically and comply with all laws and contractual requirements applicable to their activities.

Speaking up and non-retaliation

AIA encourages employees and business partners to report suspected violations, compliance risks, or mistakes promptly and in good faith.

AIA does not tolerate retaliation against anyone who raises a concern or participates in a compliance review in good faith. Knowingly or intentionally violating applicable trade laws, export-control requirements, or company policies may result in disciplinary action, up to and including termination of employment or a business relationship, subject to applicable law.

Contact our Export Compliance Officer

Contact us with questions about AIA’s Export Compliance Program, uncertainty regarding a proposed transaction, or a potential violation.

compliance@ai-armaments.com

Questions about AIA’s Compliance Program?

Contact our Compliance Director at: compliance@ai-armaments.com

MANAGEMENT STATEMENT OF POLICY AND COMMITMENT

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