Export Compliance Policy Statement

The United States has a statutory and regulatory system for controlling and monitoring the movement of certain goods, information and technologies. Among other things, the system is designed to minimize the risk of diverting such items to locations which are not in the best interests of the United States.

It is of the utmost importance to Wenzel Associates that we follow the laws and regulations governing the movement of these goods, information and technologies. This will allow Wenzel Associates to maintain its good corporate citizenship status, avoid inadvertent violations, costly errors, and the possible disruption of business.

Wenzel is committed to complying with all laws and regulations governing the export of its products, services, software and technical data, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).

Members of this company must understand these regulations in order to be compliant to them. Wenzel employees with export responsibilities are required to have a working knowledge of export control laws and regulations, especially those governing their specific job functions, as well as a working knowledge of company export control policies and procedures.

Each employee, therefore, must be dedicated to ensuring such compliance with government regulations. All sales, service, shipping, engineering, accounting and other personnel are required to be familiar with, and review regularly, the Wenzel Associates Export Management and Compliance Program. In addition, all sales representatives are required to be familiar with, and review, the Wenzel Associates Export Management and Compliance Program. Particular attention must be taken when releasing technical information to foreign nationals, electronic transmission of data and/or software, and the shipment of products outside the United States. Because Wenzel’s products are used in both commercial and military markets, we must be constantly diligent in determining where and to whom these products are being distributed. The technologies involved in creating these products, specifically the information necessary for the development, production or use of a product that can be disclosed to a foreign person: orally, visually, by e-mail or fax, must be considered.

No transactions are to be conducted by or on behalf of Wenzel Associates contrary to U.S. export control laws and regulations, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). Under no circumstances shall these laws and regulations be compromised for commercial gain. Neither sales nor shipments are to be made to any individual or firm appearing on any of the Denied Parties Lists, or to any firms owned by or associated with the individuals or firms therein listed.

Some of Wenzel’s products, information and technologies can be adapted or used for military purposes. Other products, information and technologies have both civilian and military applications. Many of these items are governed by U.S. export regulations. These regulations are in place to prevent the distribution of products, information and technologies that can compromise national security. In some cases, even the unauthorized transfer of low-level products, information or technology can potentially jeopardize national security or further the development of weapons of mass destruction.

The regulations are very precise, and compliance with them is mandatory, not voluntary. No employee or sales representative has the authority to act contrary to this program, nor direct, authorize, or condone violations of the program by any other employee or sales representative.

Export compliance is a daily exercise. Noncompliance is very costly. All Wenzel Associates employees or sales representatives are required to comply with the policies and procedures outlined in this Export Management and Compliance Program. Any employee or sales representative who has knowledge of facts or incidents which he or she believes may violate U.S. export regulations or this program, whether intentional or accidental, is required to report the matter promptly to the Export Compliance Officer.

Violations of U.S. export laws can subject Wenzel Associates, its employees and sales representatives individually to severe penalties, including fines, denial of export privileges, and even imprisonment. Any employee or sales representative, who violates such laws, or who knowingly permits a subordinate to violate such laws, will be subject to appropriate disciplinary action, up to and including termination.

It is important to recognize that terms like “classification” and “classified,” when used in conjunction with this program,
do not refer to military designations for Classified, Secret or Top Secret work. Instead, “classification” in this program is used to describe the process by which Wenzel Associates identifies the status of work being performed, relative to U.S. export regulations. Separate controls and precautions should be taken when handling Classified, Secret or Top Secret work.

All questions regarding export compliance and how it impacts your job, as well as any question concerning the legitimacy of any transaction, violation, or potential violation should be immediately referred to the Export Compliance Officer.

Elizabeth Ronchetti
President
Wenzel Associates
April 18, 2013

Note: This Export Compliance Policy Statement will be issued on an annual basis or as necessitated by personnel or company policy changes, changes in management, or regulatory changes. This statement will be disseminated throughout the organization, incorporated into appropriate training and presentations, and posted on the company’s intranet and/or website. New employees will receive export training including the reading of this policy statement and be given the opportunity to ask questions. In addition, this statement will be communicated to all contractors, consultants, interns, freight forwarders, distributors, sales representatives, joint venture partners or any other entities or persons doing business on the company’s behalf, as a condition of doing business with Wenzel Associates.