The Times Technology Group (TTG) adopts a strict corporate export control policy on products, technology and software. We exercise all due diligence to the best of our ability to comply fully with the Import and Export Ordinance (Cap. 60) of Hong Kong, all United States export control laws and regulations, including those implemented by the Department of Commerce through its Export Administration Regulations (EAR), the Department of State through its International Traffic in Arms Regulations (ITAR) and those imposed by the Treasury Department through its Office of Foreign Assets Control (OFAC), and the import and export control restrictions of all other countries with which we do business.

We understand the importance of an appropriate export compliance infrastructure in support of our established Export Compliance Manual. TTG is totally committed to ensuring that all employees receive the necessary training on applicable laws, regulations and policies to support our stringent export compliance. All TTG employees must take special care and attention to prevent transactions with persons and organizations involved with terrorism or development of weapons of mass destruction, with the proliferation of nuclear missile and chemical- and biological- related processes and/or weapons, with embargoed countries, with denied export privileges, and with those appearing in the Denied Parties Lists.

It is vital that all employees understand their obligations under the abovementioned laws and regulations and are vigilant in screening TTG’s end-use customers and their end-use applications. We make it the responsibility of our employees to ensure that absolutely no transaction contrary to this established export compliance policy is executed under any circumstances. Violations of the export and re-export laws and regulations could subject TTG to delayed or detained shipments, both civil and criminal monetary fines and penalties, including but not limited to the loss of corporate export privileges, or imprisonment. Any willful or non-willful non-compliance with the export compliance policy by TTG employees could result in strong corporate disciplinary action, including but not limited to immediate termination of employment without pay and/or compensation. All TTG employees are required to comply strictly with the policies and procedures outlined in the Export Compliance Manual with no deviations allowed. Any employee who has knowledge of facts or incidents that he or she believes may violate this policy or the export and re-export laws and regulations, whether intentional or accidental, is required to report the matter promptly to the Export Compliance Administrator or directly to the Chief Executive Officer.

Questions concerning the applicable export laws, regulations and restrictions, the individual export control responsibilities of any employee, or any other export-related matters should be directed to the immediate attention of the Export Compliance Administrator. This policy statement is supported and has been approved by the Board of Directors of the Times Technology Group.