Export Compliance Policy
Effective Date: March 2 2026
Updated Date: March 2 2026
Blade Marine Technologies Limited (“Blade”, “Company”, “we”, “us”, or “our”) is committed to full compliance with all applicable export control laws, trade sanctions regulations, insurance requirements, and banking compliance obligations in every jurisdiction in which we operate or distribute products.
This policy applies to all distributors, resellers, partners, customers, and end users worldwide.
1. Applicable Export Control and Sanctions Laws
Blade Marine Technologies Limited complies with, and requires compliance with, all applicable export control and sanctions laws, including but not limited to:
• The laws and regulations of the Hong Kong Special Administrative Region, including trade control requirements administered by the Trade and Industry Department
• United States export control and sanctions laws, including regulations administered by the U.S. Department of Commerce and the U.S. Department of the Treasury (OFAC)
• European Union restrictive measures and dual-use regulations
• United Kingdom sanctions regulations
• Australian sanctions and export control laws
• New Zealand sanctions regulations
• Japanese export control and foreign exchange regulations
• South Korean strategic goods control laws
Where multiple jurisdictions apply to a transaction, Blade adheres to the most restrictive applicable requirement.
2. Prohibited Transactions
Blade strictly prohibits:
• The direct or indirect sale, export, re-export, transfer, or supply of any product, software, service, or technology to any country, territory, region, entity, or individual subject to sanctions or trade restrictions
• Any transaction that would violate the compliance requirements of our insurers, banking institutions, or financial partners
• Circumvention, evasion, or attempted diversion of products to restricted jurisdictions
No product may be:
• Shipped to a sanctioned or embargoed country
• Sold to or through intermediaries where there is knowledge or reasonable suspicion that the ultimate end user is located in a restricted jurisdiction
• Supplied to any sanctioned individual, entity, government body, or organization
3. Ultimate End User and Diversion Prevention
Distributors, resellers, and customers must:
• Identify and verify the ultimate end user and final destination of products
• Conduct appropriate due diligence and screening
• Ensure products are not resold, transferred, or used in violation of export control or sanctions laws
Any suspicion of diversion, sanctions exposure, or restricted involvement must be reported to Blade immediately.
4. EULA and Acceptable Use Enforcement
All Blade products, firmware, software, mobile applications, and connected services are subject to our:
• End User License Agreement (EULA)
• Acceptable Use Policy
• Website Terms and Conditions
Any violation involving sanctioned jurisdictions, restricted parties, prohibited end uses, or diversion activities will result in:
• Immediate suspension or termination of licenses
• Revocation of access to software and connected services
• Immediate withdrawal of technical support
• Termination of distributor or partner agreements
• Investigation and potential legal action where applicable
Blade reserves full discretion to enforce compliance measures necessary to satisfy regulatory, banking, or insurance requirements.
5. Manufacturing and Supply Chain Integrity
Blade Marine Technologies Limited does not:
• Manufacture products in sanctioned countries
• Intentionally source materials or critical components from sanctioned jurisdictions
• Enter into business arrangements that would violate applicable export control or sanctions laws
6. Right to Request Information
Blade reserves the right to request documentation or information reasonably necessary to verify compliance with applicable export control and sanctions laws. Failure to provide such information upon request may result in suspension or termination of supply, licenses, or services.
7. Sanctioned Jurisdictions and Restricted Parties
7.1 For the purposes of this Policy and any related agreement with Blade Marine Technologies Limited (“Blade”), “Sanctioned Jurisdictions” means any country, territory, region, or geographic area that is subject to comprehensive trade embargoes or broad-based sanctions under applicable export control or sanctions laws, including but not limited to the following, as amended from time to time:
(a) Cuba
(b) Iran
(c) Democratic People’s Republic of Korea (North Korea)
(d) Syria
(e) Russia, including any regions subject to comprehensive or sectoral sanctions
(f) Belarus
(g) Sudan (including Darfur)
(h) Somalia
(i) Libya
(j) Venezuela
(k) Myanmar (Burma)
(l) Yemen
(m) Any other country, territory, region, or jurisdiction that becomes subject to comprehensive or substantially restrictive sanctions under the laws of the Hong Kong Special Administrative Region, the United States of America, the European Union, the United Kingdom, Australia, New Zealand, Japan, the Republic of Korea, or any other jurisdiction applicable to Blade or the relevant transaction
7.2 “Restricted Parties” means any individual, entity, organization, government, agency, instrumentality, vessel, aircraft, or other person that is designated, listed, or otherwise subject to asset freezes, trade restrictions, export prohibitions, or similar measures under any applicable sanctions or export control laws, including without limitation:
(a) The U.S. Department of the Treasury Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List and related sanctions lists
(b) The U.S. Department of Commerce Bureau of Industry and Security Entity List, Denied Persons List, Unverified List, or other restricted party lists
(c) The European Union Consolidated Financial Sanctions List
(d) The United Kingdom HM Treasury Office of Financial Sanctions Implementation Financial Sanctions List
(e) The Australian Department of Foreign Affairs and Trade Consolidated Sanctions List
(f) The New Zealand Ministry of Foreign Affairs and Trade Sanctions Register
(g) Relevant Japanese government sanctions and restricted party lists
(h) Relevant Republic of Korea strategic goods control and sanctions lists
(i) Any equivalent or successor list maintained by a competent governmental authority
7.3 No distributor, reseller, customer, or end user shall, directly or indirectly:
(a) Sell, export, re-export, transfer, supply, or otherwise make available any product, software, service, or technology to or for the benefit of any Sanctioned Jurisdiction or Restricted Party
(b) Engage in any transaction that would cause Blade to be in violation of applicable export control or sanctions laws
(c) Take any action intended to circumvent or evade the restrictions described in this Section
7.4 The lists and designations referenced in this Section are subject to amendment, expansion, or replacement at any time by the relevant governmental authorities. Compliance obligations under this Policy shall apply as updated from time to time, regardless of whether a specific jurisdiction or party is expressly named herein.
8. Indemnification
Distributors, resellers, and customers agree to indemnify and hold harmless Blade Marine Technologies Limited, its directors, officers, employees, affiliates, and agents from and against any claims, penalties, fines, losses, damages, liabilities, costs, or expenses (including legal fees) arising out of or relating to violations of export control or sanctions laws resulting from their actions, omissions, negligence, or failure to comply with this policy.
9. Survival
The obligations set forth in this Export Compliance Policy shall survive termination of any agreement, license, distribution relationship, or business engagement with Blade Marine Technologies Limited.
10. No Waiver
Failure by Blade to enforce any provision of this policy shall not constitute a waiver of its rights to enforce such provision or any other provision in the future.
11. Severability
If any provision of this policy is determined to be invalid or unenforceable under applicable law, the remaining provisions shall remain in full force and effect.
12. Ownership and Control
For purposes of this Policy, a person or entity shall be considered a Restricted Party if it is owned or controlled, directly or indirectly, individually or in the aggregate, by one or more sanctioned or designated persons, including where ownership thresholds under applicable sanctions laws are met.
13. Re-Export Restrictions
Products supplied by Blade may be subject to re-export controls under applicable laws. No party shall re-export, transfer, or resell any product in violation of applicable export control or sanctions laws.
14. Compliance Representation
Distributors and commercial partners represent and warrant that neither they nor their beneficial owners are located in, organized under the laws of, or ordinarily resident in any Sanctioned Jurisdiction, nor are they Restricted Parties.
15. Suspension Rights
Blade may immediately suspend performance, shipments, services, or licenses if it reasonably believes a violation of export control or sanctions laws may occur. Blade may immediately terminate any agreement, license, or commercial relationship without liability if a breach of export control or sanctions laws is reasonably suspected or confirmed.
16. Compliance Contact
Any questions regarding this Export Compliance Policy, or any concerns relating to potential sanctions, export control, or diversion issues, must be directed to:
Blade Marine Technologies Limited
Attn: Export Compliance
Unit 1603, 16/F The L.Plaza
367–375 Queen’s Road Central
Sheung Wan
Hong Kong
17. Policy Updates
Blade Marine Technologies Limited reserves the right to update this Export Compliance Policy at any time to reflect changes in applicable laws, regulatory guidance, banking requirements, or insurance obligations.
18. Audit and Inspection Rights
Blade Marine Technologies Limited reserves the right, upon reasonable notice, to audit or request documentation sufficient to verify compliance with applicable export control and sanctions laws.
Distributors and partners shall maintain complete and accurate records relating to the sale, transfer, export, re-export, and end use of Blade products for a minimum of five (5) years, or longer where required by applicable law.
Failure to cooperate with a compliance review may result in suspension or termination of supply, services, or contractual rights.
19. End-Use Restrictions
Products, software, and technology supplied by Blade shall not be used, directly or indirectly, in connection with:
(a) The development, production, handling, operation, maintenance, storage, detection, identification, or dissemination of nuclear, chemical, or biological weapons
(b) Missile systems or unmanned aerial vehicle systems capable of delivering weapons of mass destruction
(c) Military end uses where prohibited under applicable export control laws
(d) Any prohibited surveillance, cyber intrusion, or unlawful intelligence activity
(e) Any other prohibited end use under applicable export control or sanctions regulations
Customers and distributors agree to provide end-use certifications upon request.
20. No Agency or Authorization
Nothing in this Policy or any related agreement shall be construed as granting any distributor, reseller, or partner authority to represent Blade before any governmental authority or to make export control determinations on Blade’s behalf.
All export classification, licensing, and regulatory determinations remain solely within Blade’s discretion.
Each distributor and partner is solely responsible for its own compliance with applicable export control and sanctions laws and shall not rely on Blade for legal determinations relating to such compliance.
21. Governing Law and Jurisdiction
This Export Compliance Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to conflict of law principles.
Blade reserves the right to pursue remedies in any jurisdiction where a violation of export control or sanctions laws has occurred or where assets may be located.
22. Entire Compliance Understanding
This Export Compliance Policy forms part of and is incorporated by reference into all distributor agreements, sales agreements, licenses, and commercial arrangements entered into by Blade Marine Technologies Limited.
In the event of any conflict between this Policy and any other agreement, the provision imposing the most restrictive compliance obligation shall control.
23. Force Majeure
Blade shall not be liable for delays or failures in performance resulting from governmental export restrictions, sanctions designations, licensing denials, or regulatory actions beyond its reasonable control.
24. Reporting Obligation
Distributors and partners must promptly notify Blade in writing if they become aware of any investigation, inquiry, or enforcement action relating to export control or sanctions compliance.
25. Anti-Circumvention Certification
Each distributor shall implement internal compliance procedures reasonably designed to prevent diversion or sanctions violations and shall certify such compliance upon request.
26. Remedies
In addition to any suspension or termination rights set forth herein, Blade Marine Technologies Limited reserves the right to pursue any and all remedies available at law or in equity in the event of a violation of this Policy, including but not limited to injunctive relief, damages, recovery of losses, and reimbursement of legal fees and costs.
All remedies under this Policy are cumulative and not exclusive of any other rights or remedies available under applicable law or contract.
