Export Control and Economic Sanctions Compliance Statement

Export Control and Economic Sanctions Compliance Statement

One basic policy of GigaDevice Semiconductor Inc. ("GigaDevice") is to strictly implement the relevant international laws and regulations on export control and economic sanctions of the United Nations and other multilateral treaty mechanisms, earnestly fulfill its responsibilities and obligations on export control and economic sanctions, and build a good image of integrity and responsibility internationally, in order to win the trust of cooperative partners and clients. At the same time, GigaDevice firmly believes that consciously executing the relevant laws and regulations on export control and economic sanctions could enable GigaDevice to effectively avoid and reduce trade compliance risks, continuously enhance GigaDevice's competitiveness in international market, and provide an effective guarantee for the long-term development of GigaDevice.

In view of the above understanding of GigaDevice on the laws and regulations on export control and economic sanctions, GigaDevice commits to: comply with all laws and regulations on export control and economic sanctions of Chinese government and others related to GigaDevice's operations including those of the United States and the European Union, support the international commitments of the Chinese government, including any international obligations taken by the Chinese government to implement the relevant resolutions of the United Nations Security Council. At the meantime, GigaDevice adopts responsible attitude and measures on the area of export control and economic sanctions, seriously consider the globalization requirements related to GigaDevice's operations, and fulfills its responsibilities.

GigaDevice guides the establishment and implementation of internal trade compliance system based on the principle of overall control, and puts GigaDevice's trade compliance obligations above its commercial interests. If GigaDevice believes that any tangible or intangible products, technologies and services to be exported may be used by clients or end users for developing or manufacturing weapons of mass destruction and their means of delivery or unauthorized conventional military equipment which is detrimental to the peace and stability of the receiving countries and regions, or fall into the hands of terrorist organizations, GigaDevice will  implement strict export control measures in accordance with the principle of overall control and refuse the export of the relevant products, technologies and  services. Based on the principle of "deemed export" control, GigaDevice would also conduct internal monitoring and regulation so that the employees have no  access to certain individuals or organizations which may maliciously utilize any sensitive technologies or information.

GigaDevice would also verify intermediary agents that may be used in the course of business operations to avoid potential proliferation transfers and risks of breaching economic sanctions. GigaDevice refuses to do business with companies or individuals that violate the law. GigaDevice is aware that in regard to the practical measures to identify sensitive clients, in accordance with governmental requirements and to distinguish product codes and product end-use in accordance with the international and national standards, GigaDevice needs to further establish and maintain close contact with the relevant Chinese government authorities, the relevant non-governmental organizations and export control experts in order to obtain the relevant technical information and seek professional guidance and authoritative advice.

In order to ensure the effective implementation of GigaDevice's trade compliance system, in the aspect of organizational structure, GigaDevice has set up a Compliance Committee under the General Manager's Office, whose members are composed of the top responsible persons in charge of each department of the Company and the subsidiaries. The Compliance Committee is fully responsible for organizing, coordinating, and guiding the Company's trade compliance management, and reviewing, supervising and inspecting the compliance of the operation management and business behavior of each department. At the same time, the Compliance and Legal Department is the specific executive department that is responsible for the work of trade compliance management. Furthermore, GigaDevice has appointed at least one  trade compliance management person in the departments related to trade compliance operations, who is responsible for organizing and coordinating the internal trade compliance management within such departments, and aligning with the Compliance and Legal Department regarding the work of trade compliance management.

In the aspect of system establishment, GigaDevice has formulated internal control systems on trade compliance, publicized and organized training on trade compliance laws and regulations, strengthened internal audits, and allocated the responsibilities of each department involved in trade compliance.

All employees of GigaDevice are committed to making efforts to realize trade compliance, and strictly implementing GigaDevice's relevant trade compliance policies. Failure to comply with these provisions may result in criminal fines and/or civil fines and penalties, including  imprisonment and fines, and employees will be subject to disciplinary punishments and/or suspension in the meantime. GigaDevice rewards employees who actively participate in trade compliance work, and bulletins and severely punishes employees who violate GigaDevice's trade compliance policies. Employees who violate laws and regulations will bear corresponding legal responsibilities in accordance with the laws.

This Statement applies to all departments, subsidiaries, branches and employees of GigaDevice.

GigaDevice Semiconductor Inc.