Basic Policy on Security Export Control

In order to contribute to the maintenance of international peace and security, it is the Company's basic policy to comply with Japan's Foreign Exchange and Foreign Trade Act (外為法, hereinafter the "FEFTA") and other export-related laws and regulations, as well as sanctions measures against Russia implemented by the Government of Japan, and never to engage in any transaction that could contribute to the development of weapons of mass destruction or conventional weapons, or any transaction that could lead to the circumvention of sanctions.

In exports from Japan based on orders from the Company, the exporter under the FEFTA is the Japanese entity designated by us. As the importer, the Company acts to cooperate with the export control conducted by the exporter. Set forth below are the measures implemented directly by the Company.

1. Management Structure

With the General Director (CEO) serving as the Chief Export Control Officer under this Policy and the COO serving as the Operational Compliance Officer, we conduct transaction-by-transaction screening. The results of our verifications are shared with the Japanese entity designated by us, which is the exporter under the FEFTA.

2. Item Screening

Prior to placing an order, we verify the HS code and unit price for each SKU and confirm that the item does not fall under export prohibitions destined for Russia under the Export Trade Control Order (輸出貿易管理令)—such as luxury goods or goods contributing to the strengthening of industrial capacities—or under list controls. We do not order any item that may fall under such restrictions.

3. Transaction Screening (Verification of End-Use and End-User)

We verify the end-use and end-user (corporate client) and screen them against the Ministry of Finance's economic sanctions lists and the Ministry of Economy, Trade and Industry's Foreign End User List and lists of entities subject to export prohibitions. We do not engage in any transaction where a concern is identified.

4. Prevention of Diversion / Circumvention

Exports are conducted under export declarations that accurately state Russia as the destination, and we do not conduct exports via third countries. We require our corporate clients not to resell products to sanctioned parties.

5. Submission of Written Undertakings

Prior to commencing transactions, we submit to our suppliers a written undertaking specifying the end-use and pledging not to resell products to sanctioned parties.

6. Response to Regulatory Changes

We continuously monitor amendments to relevant laws and regulations, and immediately suspend ordering and shipment of any items that become subject to restrictions.

7. Record Keeping

We retain verification records and related documents for five (5) years and provide them upon request from our suppliers, except for information whose disclosure is restricted by law.

8. Training

We inform all officers and employees of relevant laws and regulations and the contents of this Policy, and provide necessary training.

9. Response to Potential Violations

If we become aware of any circumstance that may constitute a violation of laws or regulations, we will immediately suspend the relevant transaction, report the matter to the exporter and the supplier, and consult with the relevant authorities as necessary.

10. Review

We review and update this Policy and our verification procedures in response to amendments to laws and regulations and changes in the international situation.

Enacted: November 2026
Sergey Khryapin, General Director, JDM Company LLC