CUSTOMER TRADE COMPLIANCE COMMITMENTS

It is the policy of N.F. Smith & Associates, L.P., Smith & Associates Far East Ltd., Smith & Associates Europe BV, Smith Global Services Pte Ltd, its subsidiaries and affiliated companies (collectively, “Smith”) to ensure compliance with applicable export/import control laws and regulations of the U.S., the EU, Hong Kong, and the country in which Smith is located. Because the products (the “Products”) you are purchasing (or may purchase in the future) from Smith may be exported from or transferred in country in the United States, Hong Kong, Singapore and/or the EU, you confirm and agree to the following on behalf of your company, its subsidiaries and affiliated companies:

END USE CERTIFICATIONS AND ASSURANCES

1. You will not sell, export, re-export, divert or otherwise transfer any Product or the components thereof (collectively, “Parts”) to any entity or country, including but not limited to Iran, North Korea, Syria, the Russian Federation (“Russia”), Belarus, the Crimea, Donetsk and Luhansk regions, and Cuba unless authorized by the U.S. Government. If not shipping from the US, this also applies to the applicable selling country’s respective debarred lists.

2. You will not directly or indirectly sell, transfer, export, or re-export, transmit or participate in any export transaction involving Parts with individuals or companies listed on the U.S. Treasury Department’s, Office of Foreign Assets Control, Specially Designated Nationals (SDN) list (or companies owned 50% or more by one or more SDNs), the U.S. Commerce Department’s Table of Denial Orders, the U.S. Department of State’s list of individuals debarred from receiving Munitions List items, and any other lists administered by the Department of State, Treasury or Commerce, the European Union, Hong Kong or other applicable lists, i.e., Entity Lists as well as Denied Person/Company list of the selling country. You certify that you are not an embassy, agency, or a subdivision of a non-U.S. government. Ownerships interests in your company are not held by a person(s) listed on the Office of Foreign Asset Controls Specially Designated Nationals List or by Executive Order. Any subsequent designation of owners or employees will be reported to Smith.

3. You acknowledge and agree that Huawei, Sugon, Hikvision and the Inspur Group, among others, are currently on the U.S. Department of Commerce, Bureau of Industry and Security’s (“BIS”) Entity List and/or identified as a Communist Chinese Military Company on the NDAA. As such, you will not export, re-export or transfer Parts to these companies without the applicable license from BIS.

4. Nonproliferation: You will not sell, export, re-export, or otherwise dispose of any Parts for:

(i) use in activities which involve the development, production, use or stockpiling of chemical, biological, nuclear weapons, rocket systems (including ballistic missile systems, space launch vehicles, and sounding rockets) or unmanned air vehicles capable of delivering the same, or in development, production, use or stockpiling of weapons of mass destruction; or

(ii) use in any facilities which are engaged in activities relating to such weapons or applications, without authorization from the U.S. Government if required by applicable law.

5. Military / Military Intelligence End Use: You will not sell, export, re-export, or otherwise dispose of any Parts to China, Hong Kong, Russia, Belarus, Venezuela, Burma/Myanmar or Cambodia, or Nicaragua: (i) for incorporation into a military item or for use that supports or contributes to the operation, installation, maintenance, repair, overhaul, refurbishing, “development,” or “production,” of military items and/or to the national armed services (army, navy, marine, air force, or coast guard), as well as the national guard and national police, government intelligence or reconnaissance organizations, or any person or entity whose actions or functions are intended to support “military end uses” as set forth in (i) in those countries, or (ii) to any “military intelligence end user” or for any “military intelligence end use” as such terms are defined in the EAR.

6. Supercomputers: You have reviewed the definition of “supercomputer” under 15 CFR §772.1 which sets forth the following:

A computing “system” having a collective maximum theoretical compute capacity of 100 or more double-precision (64-bit) petaflops or 200 or more single-precision (32-bit) petaflops within a 41,600 ft3 or smaller envelope.

Note 1 to “Supercomputer”: The 41,600 ft3 envelope corresponds, for example, to a 4x4x6.5 ft rack size and therefore 6,400 ft2 of floor space. The envelope may include empty floor space between racks as well as adjacent floors for multi-floor systems.

Note 2 to “Supercomputer”: Typically, a ‘supercomputer’ is a high-performance multi-rack system having thousands of closely coupled compute cores connected in parallel with networking technology and having a high peak power capacity requiring cooling elements. They are used for computationally intensive tasks including scientific and engineering work.

Supercomputers may include shared memory, distributed memory, or a combination of both.

You confirm that you will not use the Parts in the development, production, operation, installation (including on-site installation), maintenance (checking), repair, overhaul, or refurbishing of a supercomputer located in or destined to Country Group D:5i or Macau, or incorporate the Parts into or use the Parts in the development or production of any component or equipment that will be used in a supercomputer located in or destined to Country Group D:5 or Macau.

7. Advanced Node ICs: Except as otherwise permitted under the EAR and the applicable law, you will not export, re-export or transfer (in country) the Parts to a “facility” in Country Group D:5 or Macau if:

(A) the facility is a production facility of advanced-node integrated circuitsii (“Advanced Node ICs”) if you know that the facility produces Advanced Node ICs; or

(B) for Parts classified in product groups B, C, D, or E in Category 3 of the CCL, Parts will be used in the development or production of integrated circuits if you know that the facility produces or develops integrated circuits.

8. Semiconductor Manufacturing Equipment: You will not use the Parts to develop or produce integrated circuits production equipment, components, assemblies or accessories therefor, for a destination in Country Group D:5 or Macau, or for an entity headquartered in, or with an ultimate parent headquartered in, Macau or a destination specified in Country Group D:5.

9. Advanced Computing: You will not directly or indirectly, sell, transfer (in country), export or re-export any Parts classified as advanced computing items, i.e., classified under ECCN 3A090.a, 3A090.c, 4A090.a, and corresponding .z controls, as amended except as expressly authorized under the EAR and the applicable local law. Such restrictions include, but are not limited to the transfer (in country), export or re-export such Parts, to or for:

(i) any entity located in China, Macau, or any other country located in Country Groups D:1, D:4,iii or D:5; or

(ii) any entity, regardless of where it is located, if the entity is headquartered in, or its ultimate parent company is headquartered in a D:5 Country (e.g., a China headquartered cloud or data server provider located in Malaysia).

10. Russia / Belarus: You will comply with applicable US and EU trade restrictions, especially the restrictions targeting Russia, Belarus, the Crimea, Donetsk and Luhansk regions. Further:

(i) You shall not sell, export or re-export, directly or indirectly:

(a) to Russia or for use in Russia any Parts supplied by Smith or under your agreement with Smith that fall under the scope of Article 12g of Council Regulation (EU) No 833/2014, any other provision of the Council Regulation (EU) No 833/2014, or Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items (recast), or in the Council Common Position 2008/944/CFSP of 8 December 2008 defining common rules governing control of exports of military technology and equipment.

(b) to Belarus or for use in Belarus any Parts supplied by Smith that fall under the scope of Article 8g of Council Regulation (EU) No 765/2006 or any other provision of the Council Regulation (EU) No 765/2006, or Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items (recast), or in the Council Common Position 2008/944/CFSP of 8 December 2008 defining common rules governing control of exports of military technology and equipment.

(ii) You shall undertake best efforts to ensure that the purpose of 10 (i) above not be frustrated by any third parties further down the commercial chain, including by possible resellers.

(iii) You shall set up and maintain an adequate monitoring mechanism to detect conduct by any third parties further down the commercial chain, including by possible resellers, that would frustrate the purpose of 10 (i) above. You will notify Smith of any problems in applying 10 (i) and (ii) above.

(iv) You will monitor third parties further down the commercial chain, including possible resellers, with certain tools to detect compliance with all subject regulations, including local laws. You will notify Smith of any known compliance concerns in relation to this section 10.

(iii) Any violation of this section 10 shall constitute a material breach of your agreement with Smith, and Smith shall be entitled to seek appropriate remedies, including the termination of Smith’s agreement with you.

11. Parts may be subject to the EAR, as amended. As such, you will abide by all applicable US and/or the applicable selling country export control laws and regulations for any Parts purchased from Smith. You will not export, re-export, import to any other country or transmit any Parts except in accordance with all applicable laws, regulations, and, if applicable, the terms of any

license or licenses issued by any applicable government authority. You understand that Smith is a U.S. person and agree not to cause Smith to facilitate the shipment, transmittal, transfer or servicing of items for prohibited end-uses under the EAR, including but not limited to §734.9, §742.6, §744.23 and §744.6 of the EAR, as may be amended from time to time. You will also comply with the International Labor Organization’s conventions on forced labor.

12. If you are unable to fulfill the above export control requirements, you will advise Smith of the change in writing to [email protected] before placing orders with Smith. You agree that this certification shall pertain to all orders and shall survive the term and termination of the relationship between you and Smith.

i Currently under Supplement No. 1 to Part 740, Title 15 (Country Groups) the D:5 Countries are: • China (including Hong Kong)• Afghanistan • Belarus • Burma • Cambodia • Central African Republic • Congo (Democratic Republic of) • Cuba • Eritrea • Haiti • Iran • Iraq • North Korea • Lebanon • Libya • Nicaragua • North Korea • Russia • Somalia • South Sudan • Sudan • Syria • Venezuela • Zimbabwe. Subject to change based on the Department of State orders the State Department’s list of countries subject to U.S. arms embargoes shall be controlling. ii Currently in Part 772 of the EAR, “Advanced-Node Integrated Circuits” include integrated circuits that meet any of the following criteria: (1) Logic integrated circuits using a non-planar transistor architecture or with a “production” ‘technology node’ of 16/14 nanometers or less; (2) NOT AND (NAND) memory integrated circuits with 128 layers or more; or (3) Dynamic random-access memory (DRAM) integrated circuits having: (a) a memory cell area of less than 0.0026 µm2; (b) a memory density greater than 0.20 gigabits per square millimeter; or (c) more than 3000 through-silicon vias per die. iii Currently under Supplement No. 1 to Part 740, Title 15 (Country Groups) the D:1, D:4 and D:5 Countries are: • China (including Hong Kong)• Afghanistan • Armenia • Azerbaijan • Bahrain • Belarus • Burma • Cambodia • Central African Republic • Congo (Democratic Republic of) • Cuba • Egypt • Eritrea • Georgia • Haiti • Iran • Iraq • Jordan • Kazakhstan • North Korea • Kuwait • Kyrgyzstan • Laos • Lebanon • Libya • Nicaragua • Macau • Moldova • Mongolia • Oman • Pakistan • Qatar • Russia • Saudi Arabia • Somalia • South Sudan • Republic of Sudan • Syria • Tajikistan • Turkmenistan • United Arab Emirates • Uzbekistan • Venezuela • Vietnam • Yemen • Zimbabwe. Subject to change based on the Department of State orders the State Department’s list of countries subject to U.S. arms embargoes shall be controlling