Sustainability Report - FY 2023

Corporate culture and business conduct policies Export Controls

8.4

Export Controls

As an international Company and taking into account the nature of the goods and services it markets (see Chapter 2 of the 2023 Universal Registration Document), the Exclusive Networks group implements all necessary measures to comply with applicable laws and regulations relating to:  export controls on Dual-use goods and technology; and  trade restriction measures against certain countries subject to sanctions or embargoes, decided by the United Nations Security Council, the United States via OFAC (Office of Foreign Assets Control), or the European Union in the context of foreign and security policy decisions (CFSP). Given the nature of the products and solutions on the market, which are considered Dual-use because they incorporate encryption technology, the cybersecurity sector is sensitive and subject to these regulations and controls. The Exclusive Networks group operates globally in compliance with these laws, which are often extra territorial in scope, cumulative, and regularly evolving. Their objectives are to preserve global geopolitical balances, international, national or regional security,

and to combat the diversion and proliferation of certain materials. Export control compliance is therefore an important issue for the Group. The Group applies these control regimes in all the countries in which it operates, and more specifically:  in the European Union, in accordance with EU regulation No. 821/2021 of 20 May 2021 establishing the Union regime for the control of exports, brokering, technical assistance, transit and transfer of Dual-use items;  in the United States, in accordance with the AEOI – Export Control regulations 15 CFR § 730 et seq. ; and  in Singapore or the United Kingdom, in accordance with applicable local regulations. Since the export or re-export of certain equipment is subject to the prior obtaining of an export licence or an exemption granted by the authorities of the exporting countries, the Group is informed at all times by suppliers of restrictions on the goods and services supplied. To do this, they have a dedicated organisation, which allows them to exercise strict control over their manufacturing and sales processes, in order to comply with these same obligations.

Export Control Organisation in the Exclusive Networks group To meet these challenges in a context of strong international expansion, the Group has maintained its organisation as represented below. In addition, the Internal Compliance Programme (ICP) is applied and is continuously adapted to reduce and control these risks.

CHIEF EXECUTIVE OFFICER

GROUP LEVEL

LOCAL LEVEL: COUNTRY

AMERICAS (1)

Group General Counsel and compliance officer

APAC (2)

Regional Senior Vice-President

Group Chief Financial Officer *

EMEA (3)

Internal Audit Director

Group Chief Operations Officer

Country Managers **

Export control champions (Operations, Finance or Sales Managers)

Head of Group Export Control

Function in charge of export control reporting to the Chief Executive Officer. Other stakeholders in the Group export control organisation. * Function with legal responsibility for export control by delegation from the Chief Executive Officer. ** Function with legal responsibility for export control of local entity. Local operational entities: (1) AMERICAS: Canada, USA.

(2) APAC: Australia, Hong Kong, India, Indonesia, Malaysia, New Zealand & Pacific Islands, Philippines, Singapore, Thailand, Vietnam. (3) EMEA: Austria, Belgium, Bosnia, Bulgaria, Croatia, Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Israel, Italy, Kenya, Mauritius, Norway.

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Exclusive Networks SA

2023 Sustainability Report

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