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Compliance

Trade Compliance & Export Control Policy

Effective 7 June 2026

Nexma is committed to the lawful and responsible movement of its technology across borders. This policy sets out how we comply with the export control, economic sanctions, and import laws that apply to our software, services, and the spatial intelligence outputs they produce.

1. Scope and Application

This Trade Compliance and Export Control Policy applies to Nexma, its subsidiaries and affiliates, and all directors, officers, employees, contractors, and agents acting on its behalf (collectively, "Nexma Personnel"). It also informs the obligations of customers, resellers, and partners who receive, access, or deploy Nexma software, services, technical data, and any analytical outputs derived from them (together, the "Nexma Technology").

Nexma develops general-purpose spatial intelligence software. Because such technology may have civil, governmental, and dual-use applications, Nexma is committed to conducting its business in full compliance with all applicable export control, economic sanctions, and import laws of the jurisdictions in which it operates and to which the Nexma Technology is subject.

2. Applicable Legal Frameworks

Nexma maintains a trade compliance program designed to meet the requirements of, among others:

  • United States — the Export Administration Regulations (EAR, 15 C.F.R. Parts 730–774) administered by the Bureau of Industry and Security (BIS); the International Traffic in Arms Regulations (ITAR, 22 C.F.R. Parts 120–130) administered by the Directorate of Defense Trade Controls (DDTC); and economic sanctions programs administered by the Office of Foreign Assets Control (OFAC).
  • European Union — Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit, and transfer of dual-use items, together with applicable EU restrictive measures (sanctions).
  • United Kingdom — the Export Control Act 2002, the Export Control Order 2008, and the UK's strategic export control and sanctions regimes administered by the Export Control Joint Unit (ECJU) and the Office of Financial Sanctions Implementation (OFSI).
  • Any other export, sanctions, or import laws applicable to a given transaction, including local laws of the jurisdiction from which an export originates.

Where the laws of more than one jurisdiction apply to a transaction, Nexma observes the most restrictive applicable requirement.

3. Classification of the Nexma Technology

Nexma classifies its software, technical data, and services under the applicable control lists to determine the licensing requirements that apply to their export, re-export, or transfer. Nexma's commercial platform is designed and offered as general-purpose, commercially available software and is not developed for military end use.

Classification is reviewed when material changes are made to product capabilities and is provided to customers and partners on request to support their own compliance determinations. Customers remain responsible for confirming the classification applicable to their specific configuration and use.

4. Restricted-Party and Sanctions Screening

Before entering into a transaction, Nexma screens counterparties — including customers, partners, suppliers, and their relevant beneficial owners — against applicable government restricted-, denied-, and debarred-party lists and sanctions designations. Nexma does not knowingly transact with parties that are the target of applicable sanctions or that appear on such lists, absent a valid license or authorization.

Nexma does not provide its technology for use in, or for the benefit of, comprehensively sanctioned or embargoed countries, regions, or governments, except where expressly authorized by the relevant competent authority.

5. Prohibited and Controlled End Uses and End Users

Nexma will not knowingly support transactions or end uses prohibited by applicable export control law. This includes, without limitation, end uses connected to the development, production, or deployment of weapons of mass destruction, or other prohibited military or proliferation activities, where a license is required and has not been obtained.

Where the Nexma Technology may be used in defense, intelligence, or other sensitive contexts, such engagements are subject to additional internal review, including assessment of the end user, the stated end use, and the destination, and are conducted only under appropriate authorizations and contractual safeguards.

6. Deemed Exports and Technology Transfers

Nexma recognizes that the release of controlled technology or source code to a foreign person, including within a single country, may constitute a "deemed export" requiring authorization. Nexma manages access to controlled technical information accordingly and trains relevant personnel on the handling of such information.

7. Customer and Partner Obligations

As a condition of accessing the Nexma Technology, customers, resellers, and partners agree that they will:

  • Comply with all applicable export control, sanctions, and import laws in their use, deployment, resale, and onward transfer of the Nexma Technology;
  • Not export, re-export, or transfer the Nexma Technology to any prohibited destination, end user, or end use without required authorization;
  • Not use the Nexma Technology for any purpose prohibited by applicable law, including prohibited military, intelligence, surveillance, or proliferation activities; and
  • Conduct their own restricted-party screening and end-use diligence appropriate to their circumstances.

These obligations supplement, and do not replace, the export-control terms in the applicable customer or partner agreement.

8. Governance, Training, and Recordkeeping

Nexma's trade compliance program is overseen by designated personnel responsible for maintaining policies, conducting risk assessments, delivering training, and keeping the records required by applicable law. Nexma cooperates with competent authorities and conducts internal reviews to confirm the program remains effective as the business and regulatory landscape evolve.

9. Reporting Concerns

Anyone who becomes aware of a potential violation of this policy or of applicable trade laws is encouraged to report it promptly. Nexma investigates reports in good faith and prohibits retaliation against anyone who raises a concern honestly. Questions and reports may be directed to the contact below.

Questions about this policy? Contact compliance@nexma.ai.