ORBITEXSPACE
L11Compliance

Compliance & Ethics

1. Overview

OrbitExSpace Inc. ("OrbitExSpace", "we", "us") is committed to conducting our business with integrity, in compliance with applicable laws, and in a manner that respects the rights and dignity of all people. This page summarizes our compliance commitments. It is not a substitute for specific legal advice or for the detailed terms in our separate policies.

2. Sanctions and Restricted Parties

We comply with all applicable economic sanctions programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce, the U.S. Department of State, and other competent authorities. We do not transact with parties subject to comprehensive sanctions or that appear on any restricted party list, including:

3. Restricted Party Screening

We screen prospective counterparties against applicable lists, including:

  • OFAC Specially Designated Nationals and Blocked Persons List.
  • U.S. Department of Commerce Entity List, Denied Persons List, and Unverified List.
  • U.S. Department of State Debarred List and Statutorily Debarred Parties.
  • Equivalent lists maintained by the European Union, the United Kingdom, and other jurisdictions where we operate.

A counterparty that appears on any applicable list is ineligible to receive goods, services, or technology from OrbitExSpace.

4. Embargoed Jurisdictions

We do not sell, license, or transfer technology to any person or entity located in, or ordinarily resident in, a country subject to comprehensive U.S. sanctions. The list of such jurisdictions may change; we apply current sanctions guidance at the time of any transaction.

5. Anti-Bribery and Anti-Corruption

We prohibit bribery and corruption in all forms, whether direct or indirect, in both the public and private sectors. We comply with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other applicable anti-corruption laws. Our personnel, agents, and partners may not offer, promise, give, authorize, or accept anything of value to improperly influence a decision or gain an improper advantage.

We maintain internal controls, record-keeping, and approval processes designed to prevent and detect improper payments. Violations may result in disciplinary action, termination, and referral to authorities.

6. Human Rights Statement

We respect internationally recognized human rights, including those set out in the Universal Declaration of Human Rights and the International Labour Organization's core conventions. We do not use forced labor, child labor, or trafficked labor in any form, and we expect our suppliers to uphold the same standard.

We provide a workplace that is free from harassment and discrimination, where individuals are treated with dignity and where differences are respected. We identify and address human-rights risks in our operations and supply chain through reasonable due diligence.

7. Environmental and Sustainability Statement

We are committed to environmentally responsible engineering and operations. We consider environmental impact in design decisions, minimize waste and energy use in our operations, and comply with applicable environmental laws. We recognize that the environments we engineer for — the Moon and Mars — deserve the same care we apply on Earth, and we support the principle that space activities should be conducted in a manner that preserves the space environment for future generations.

8. Equal Opportunity and Non-Discrimination

OrbitExSpace is an equal opportunity organization. We make decisions about hiring, promotion, compensation, and engagement on the basis of merit and ability. We do not discriminate on the basis of race, color, national origin, ancestry, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, disability, veteran status, or any other characteristic protected by applicable law.

Where U.S. export control laws require us to limit access to controlled technology based on nationality, we do so only as required to comply with those laws and not as a matter of arbitrary discrimination.

9. Contact

OrbitExSpace Inc.
Los Angeles, California
compliance@orbitexspace.com

Legal & Compliance Contact — legal@orbitexspace.com

This document is provided for informational purposes only and does not constitute legal advice or a representation of certification, accreditation, registration, Government approval, contract status, or authorization. OrbitExSpace programs are in development. Statements regarding FAR/DFARS, ITAR, EAR, NIST SP 800-171, CMMC, or other frameworks apply only where applicable and as required by contract or law.

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