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Defence Export Controls Policy

Effective Date: 17 July 2025

Purpose

Materia Scientia LLC is committed to full compliance with Australian laws and international obligations relating to the export, supply, brokering, and publication of defence and strategic goods, software, and technology. This Defence Export Controls Policy sets out our responsibilities and expectations in ensuring all controlled activities are conducted lawfully, transparently, and with due regard to national security.

Scope

This policy applies to all Materia Scientia LLC employees, contractors, suppliers, and
business partners involved in:

  • Export of defence and dual-use goods listed under the Defence and Strategic Goods
    List (DSGL).
  • Supply of DSGL technology to non-Australian persons, whether in Australia or
    overseas.
  • Brokering of DSGL goods and services between two non-Australian entities.
  • Publication of controlled technical information.

Compliance Obligations

  • Materia Scientia LLC will comply with the Defence Trade Controls Act 2012 (Cth), the
    Customs (Prohibited Exports) Regulations 1958, and other applicable legislation.
  • No export, supply, or brokering of DSGL items will occur without the required
    permits or approvals from the Australian Government Defence Export Controls
    (DEC) office.
  • Employees must not engage in controlled activities without prior authorisation from
    management and confirmation of approvals.
  • Accurate record-keeping will be maintained for all controlled transactions, including
    permits, end-user certificates, and shipping documentation.

Due Diligence & Risk Management

  • Thorough due diligence will be conducted on all customers, suppliers, and
    intermediaries involved in controlled transactions.
  • Materia Scientia LLC will apply “know your customer” principles to verify legitimacy
    and prevent diversion to unauthorised end-users or applications.
  • All contracts relating to controlled goods will include compliance clauses requiring
    counterparties to adhere to applicable export control laws.

Training & Awareness

  • Employees and contractors engaged in relevant activities will receive training on
    export controls and their responsibilities.
  • Regular updates will be provided as legislation, regulation, or company procedures change.

Confidentiality & Information Security

  • Technical data, drawings, software, and related documentation will be protected
    against unauthorised access, sharing, or publication.
  • Secure communication channels will be used when transmitting sensitive information.

Penalties & Consequences

  • Legal Consequences: Breaches of Australian export control laws may result in significant penalties, including fines in the millions of dollars and imprisonment for
    individuals.
  • Company Consequences: Non-compliance may lead to suspension or termination of employment, cancellation of supplier contracts, and termination of partnerships.
  • Reputational Risk: Violations may harm Materia Scientia LLC’s reputation, damage
    customer trust, and affect future business opportunities.
  • Regulatory Reporting: Serious breaches will be reported to relevant Australian authorities and may result in blacklisting or restrictions on future trade.

Monitoring & Enforcement

  • Materia Scientia LLC will conduct regular internal reviews to ensure compliance with
    export controls.
  • Any suspected breach must be reported immediately to the Compliance Officer.
  • Non-compliance will be investigated promptly, with corrective actions enforced as
    required.

Reporting Concerns

Employees, suppliers, and partners may report export control concerns or suspected violations in confidence to:
info@materiascientia.com

Commitment

By adhering to this Defence Export Controls Policy, Materia Scientia LLC reinforces its
responsibility to support national security, international peace, and the lawful trade of
strategic goods and services.