This policy applies to all directors, officers, employees, representatives, and consultants (collectively, “Saxon
Personnel”) of Saxon Energy Services, its subsidiaries, and affiliates (collectively, “Saxon”).
Saxon Personnel shall strictly comply with all applicable import and export control laws and regulations in the
jurisdictions where Saxon does business.
Procedures shall be maintained to ensure every import, export, or re-export of goods, services, or technology
complies with applicable laws and regulations, and that all necessary Governmental approvals for such transactions
are obtained. Saxon’s Corporate Supply Chain Management (SCM) is responsible for developing and implementing
procedures that maintain compliance governing the import and export of Saxon’s goods, services, and technology
worldwide. Furthermore, SCM is responsible for advising on compliance with and changes in, laws and regulations
that may require modification to such procedures. Country Managers have primary responsibility for ensuring
compliance with established procedures and governing the import and export of Saxon’s goods, services, and
technology for the business jurisdictions they manage.
Saxon Personnel involved with import, export, or re-export of goods, services, or technology shall familiarize
themselves with such procedures, receive training proportionate to their job responsibilities, as well as obtain and
maintain a working knowledge of applicable trade and customs laws and regulations. In addition, Saxon Personnel
shall cooperate fully with all import and export control compliance activities, including internal/external audits and
reviews.
Violation of trade regulations can subject Saxon and Saxon Personnel to civil and criminal liability. Saxon personnel
who violate this policy may face disciplinary action including, without limitation, termination of his or her appointment,
employment, or contract without notice for cause.