ITAR & EAR Compliance Policy

Steele Industries Inc. complies with all United States export control laws, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). These regulations govern the export, reexport, transfer, and handling of certain US origin products, technology, and technical data to protect national security and support US foreign policy objectives.

Many of the products manufactured, sold, and distributed by Steele Industries Inc. are subject to ITAR or EAR control. These may include:

• Night vision devices and image intensifier tubes

• Thermal imaging systems and components

• Infrared aiming and illumination devices

• Optical assemblies, lenses, and related accessories

• Electronic modules and support equipment

As a customer, you share responsibility for ensuring that controlled items are purchased, used, stored, and transferred in accordance with applicable US export control laws.

Customer Responsibilities

By placing an order with Steele Industries Inc. you certify that:

• You are a US Person as defined under applicable US law, or you are purchasing strictly for use within the United States.

• You will not export, reexport, transfer, ship, or provide any controlled item or technical data to a foreign destination or foreign person without proper authorization from the US Government.

• You will not divert, misuse, or route controlled items in a way that violates US export control regulations.

Any attempt to export or transfer controlled items without a required license or other authorization can result in severe civil and criminal penalties. Steele Industries Inc. will not participate in or support any unlawful export activity.

What Is Considered an Export

For export control purposes, an “export” includes, but is not limited to:

• Sending or transporting a controlled item outside of the United States

• Hand carrying a controlled item outside of the United States while traveling

• Emailing, messaging, or otherwise transmitting controlled technical data to a foreign person

• Uploading or downloading controlled data to or from servers that can be accessed outside of the United States

• Allowing a foreign person inside the United States to access controlled items, software, or technical data (this is treated as a “deemed export”)

Temporary movement of controlled items outside the United States, even when not for sale, may still require export authorization.

Order Processing and Required Documentation

To ensure compliance with ITAR and EAR, Steele Industries Inc. requires all customers to complete our ITAR Compliance Form for applicable orders. This form is used to confirm:

• End user identity

• Intended end use

• Acknowledgment of export control responsibilities

Orders will not ship until all required information and documentation are received and verified. Failure to complete the required forms may result in order cancellation and may incur a 3% cancellation fee.

If you have questions about whether a particular product is controlled under ITAR or EAR, you may contact our team at sales@steeleindinc.com for assistance.

Regulatory Overview

International Traffic in Arms Regulations (ITAR)

ITAR is administered by the US Department of State, Directorate of Defense Trade Controls. ITAR regulates the export, reexport, temporary import, and transfer of:

• Defense articles

• Defense services

• Related technical data

Items that are specifically designed, developed, or modified for military application, and that appear on the United States Munitions List, generally fall under ITAR jurisdiction and may require a license before they can be exported.

Export Administration Regulations (EAR)

EAR is administered by the US Department of Commerce, Bureau of Industry and Security. EAR controls:

• Dual use items that have both commercial and potential military application

• Certain optical, electronic, imaging, and support components that are not listed on the United States Munitions List

Depending on the item’s export classification and destination, an export license may or may not be required.

Assistance and Contact Information

If you have questions about export classification, licensing requirements, or general compliance obligations related to purchases from Steele Industries Inc., please contact:

• Email: sales@steeleindinc.com

• Phone: 800-674-7302