Scope of International Activity
As a freight forwarder of United States (“U.S.”) commodities and technical data, OCEANAIR is subject to the legal requirements of U.S. export control laws, including the Export Administration Act, the Export Administration Regulations, the Arms Export Control Act, the International Traffic in Arms Regulations, the Foreign Corrupt Practices Act, the Foreign Assets Control Regulations, and all Foreign Trade Regulations.

Policy of Compliance
OCEANAIR is firmly committed to full compliance with all U.S. export control laws and regulations. These laws and regulations ensure that valuable U.S. technology, commodities, and raw materials are not diverted to uses inconsistent with U.S. national interests and policy. It is OCEANAIR’s policy to adhere to the conditions of the Foreign Corrupt Practices Act (FCPA).

The Export Compliance System
In recognition of this policy, OCEANAIR has established export control policies and a proactive internal control procedure to ensure that no export of any commodity or technical data to any foreign nationals or entities can occur without first ensuring that such transfers are authorized by the U.S. Government. OCEANAIR’s commitment requires that each employee understands the limitations these regulations impose on business transactions and be diligent in observing these laws.

It is OCEANAIR’s corporate policy not to make any export contrary to the United States export control laws or regulations.

Penalties for Violations:
A violation of any export law or regulation may result in serious civil, criminal, and administrative penalties against OCEANAIR, its management, and/or individual employees. Additionally, failure of any employee to comply with this policy may constitute grounds for disciplinary action.