Trade & Technology Transfer

OrbitExSpace Inc. ("OrbitExSpace", "we", "us") operates in a regulated international trade and technology-transfer environment. This page sets out our international trade, technology-transfer, and government-contracting compliance commitments. It supplements our Export Control Policy; where the two overlap, the more specific policy controls. These commitments apply where applicable and as required by contract or law.

We comply with the customs, export, import, and sanctions laws of the jurisdictions in which we operate, including U.S. Customs and Border Protection import requirements, the EAR, OFAC sanctions programs, and the anti-boycott provisions of the EAR (15 CFR Part 760). This includes accurate classification of goods, correct valuation, accurate country-of-origin determination, and proper documentation. We maintain trade records for the periods required by applicable law.

We do not transfer controlled technology to unauthorized recipients. A release of technology to a non-U.S. person — wherever located — may constitute an export or a deemed export and may require authorization. We assess the export control implications of any disclosure of technical information, software, or technical data before it occurs, and we obtain the required licenses, exceptions, or exemptions.

Controlled technical data is stored, transmitted, and accessed under controls designed to prevent unauthorized release. This includes access controls, encryption in transit and at rest, marking and accountability, and logging of access. We classify technical data early, mark it appropriately, and review its classification periodically. We do not publicly disclose controlled technical data or controlled program information.

Where we engage with parties outside the United States or transfer technology subject to another jurisdiction, we comply with the applicable export and dual-use control regime, including Regulation (EU) 2021/821 on dual-use items and the restricted-party lists of the relevant jurisdiction, and we apply current controls at the time of any transfer.

If and when we engage as a contractor or subcontractor to the U.S. Government, we comply with the applicable procurement rules, including the Federal Acquisition Regulation ("FAR") and the Defense FAR Supplement ("DFARS"), and with applicable flow-down clauses. Our commitments include:

We do not represent that we hold any Government contract, are CMMC certified, or have a particular System Security Plan approved unless and until that status is verified. We will not misrepresent our status, capabilities, or eligibility in any procurement.

We engage with public procurement processes honestly and transparently. We do not engage in bid-rigging, price-fixing, or any practice that distorts competition. We disclose conflicts of interest that could affect a procurement and respect the integrity of the process.

To the extent any of our technology becomes subject to the ITAR, we will register with DDTC as required, obtain the required authorizations, and apply the access controls and recordkeeping that ITAR demands. At the date of this statement, we have not determined any of our technology to be ITAR-controlled and have not registered with DDTC. We will update this page if that status changes.

For any future space object we launch or for which we are the operator, we will comply with the Registration Convention by ensuring that the object is registered with the appropriate national registry and with the United Nations. We acknowledge that the launching state retains jurisdiction and control over the object on orbit and may bear international liability for damage under the Liability Convention. We will allocate liability among parties by agreement, maintain the insurance appropriate to the mission, and honor our obligations to the launching state.

For questions regarding international trade, technology transfer, or government-contracting compliance, contact:

OrbitExSpace Inc.
Legal & Compliance
legal@orbitexspace.com