Export Controls & Trade Compliance Policy

1. Purpose

Accurate Performance Machining, Inc., ("the Company") manufactures precision-machined components, some of which are used in aerospace, defense, and related applications. Because of the nature of this work, certain products, technical data, and services provided by the Company may be subject to U.S. export control laws, including but not limited to:

• The International Traffic in Arms Regulations (ITAR), administered by the U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
• The Export Administration Regulations (EAR), administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)
• Regulations administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

This policy describes the Company's general commitment to compliance with these laws. It is intended for informational purposes for customers, suppliers, visitors, and members of the public, and does not disclose any controlled technical data, drawings, specifications, or program-specific information.

2. Scope

This policy applies to all Company employees, contractors, officers, and representatives, and to all products, technical data, software, and services provided by the Company, regardless of where the recipient is located.

3. Our Compliance Commitment

The Company is committed to:

• Complying with all applicable U.S. export control and trade sanctions laws in the conduct of its business
• Classifying its products and technical data appropriately under the United States Munitions List (USML) or the Commerce Control List (CCL), as applicable
• Obtaining any required export licenses, agreements, or authorizations from DDTC or BIS prior to exporting or disclosing controlled items or technical data
• Screening customers, suppliers, and other business partners against U.S. government restricted, denied, and debarred parties lists
• Restricting access to export-controlled technical data and hardware to authorized U.S. persons and properly licensed foreign persons only
• Training employees on their export compliance responsibilities
• Maintaining internal procedures for identifying and reporting suspected violations

4. No Public Disclosure of Controlled Information

Consistent with export control requirements, the Company does not publish, post, or otherwise make available on this website, or in any other public or unrestricted forum:

• Technical data, drawings, specifications, or engineering information related to ITAR-controlled defense articles
• Details of specific government or defense programs the Company supports
• Software or source code subject to export restrictions
• Any information that would constitute a "deemed export" to a foreign person absent a license or applicable exemption

Any technical exchanges with customers or suppliers regarding controlled items are handled through controlled, non-public channels subject to appropriate screening and, where required, licensing.

5. Restricted and Foreign Persons

Certain positions, facility areas, and information at the Company may be restricted to U.S. Persons, as defined under ITAR (22 CFR § 120.62), which generally includes U.S. citizens, lawful permanent residents, and certain protected individuals.

Where the Company employs, hosts, or contracts with foreign persons, access to export-controlled technical data or hardware is granted only where:

• A license or license exemption applies, or
• No export-controlled information or access is involved

This applies to physical plant visits, employment, internships, and vendor/subcontractor relationships.

6. Restricted Party Screening

Before engaging in transactions, the Company screens customers, distributors, freight forwarders, and other counterparties against applicable U.S. government lists, including the BIS Entity List and Denied Persons List, the DDTC Debarred List, and OFAC's Specially Designated Nationals (SDN) List. The Company does not conduct business with parties identified on these lists in violation of U.S. law, or with entities located in countries subject to U.S. arms embargoes or comprehensive sanctions, absent proper authorization.

7. Recordkeeping

The Company maintains export-related records (including license applications, classifications, and screening results) in accordance with ITAR and EAR recordkeeping requirements.

8. Reporting Concerns or Violations

Any employee, customer, supplier, or member of the public who becomes aware of a potential export control violation, or who has questions about this policy, is encouraged to contact the Company's designated compliance contact below. Reports may be made confidentially.

Export Compliance Contact:
Andrew Palowitch / CEO - apalowitch@accurateperformancemachining.com - 714-434-7811

The Company will not retaliate against any individual who reports a good-faith concern regarding export compliance.

9. Disclaimer

This policy is provided for general informational purposes only and does not constitute legal advice, nor does it disclose all internal compliance procedures. It does not create any rights, obligations, or expectations for third parties beyond what is required by applicable law. The Company reserves the right to update this policy at any time without prior notice.