Summary
This document is a U.S. Export Compliance Manual that outlines the policies and procedures established by Ziff Davis, Inc. to comply with U.S. export control and economic sanctions laws and regulations. It details the importance of adhering to the U.S. Export Administration Regulations (EAR) and the Office of Foreign Assets Control (OFAC) regulations. The manual provides guidance for establishing operating procedures to ensure compliance with various export regimes, including those regulating the export of commercial and dual-use technology, software, and hardware. It also describes the role of the Trade Compliance Officer responsible for the development and enforcement of the export compliance program, including training, due diligence, and oversight of compliance functions. The document emphasizes the necessity for all employees to understand their responsibilities regarding export laws and the consequences of noncompliance, which can include substantial penalties. Additionally, it includes appendices with key definitions and checklists relevant to export compliance.
