Sanctioned Country Policy  for  US Export Law

Version: 1.0

Effective Date: September 16, 2025

This policy outlines E2E Networks' unwavering commitment to complying with all applicable export controls and economic sanctions laws and regulations, particularly those of the United States. This policy is a critical component of our corporate governance, designed to mitigate risk and ensure legal and ethical business practices.

General Policy Statement

E2E Networks is committed to full compliance with applicable U.S Export law regulations governing the export, re-export, and import of products and technology directly or indirectly and via any means, including electronic transfer, is wholly responsible for doing so in accordance with the U.S. Export Administration Regulations and the laws of host countries.

It is the responsibility of every E2E Networks employee, partner, and customer to adhere to these regulations. Violations can lead to severe penalties, including criminal and civil fines, and the denial of export privileges. This policy is a critical component of E2E Networks' operational integrity and commitment to ethical business practices.

Scope and Applicability

This policy applies to all E2E Networks employees, partners, customers, vendors and any other individuals or entities who are acting on behalf of the company.

Product-Specific Controls

Each product category at E2E Networks is subject to specific export classifications and controls:

  • High-Performance GPU (High-Performance Graphics Processing Unit): Classified under 3A090 applies to Nvidia A100, H100, H200, and L40S GPUs, among other advanced ICs. These products are subject to U.S. export controls and require a license for export to any destination with high-performance computing restrictions.

  • Operating System: Generally classified as EAR99 or 5D992 Mass Market-eligible applies to Microsoft Server license, which allows for export to non-embargoed countries under the designation of "No License Required" (NLR). However, a license is strictly required for shipments to a restricted list of countries.

  • Firewall: Classified under 5A002, 5D002, and 5E002 applies to Fortinet cloud firewall appliances. These products are subject to additional restrictions and require a U.S. export license for shipments to government end-users in certain countries.

List of Restricted Countries

A license is strictly required for any shipment of E2E Networks' products to the following countries and regions:

  • Afghanistan
  • Armenia
  • Azerbaijan
  • Bahrain
  • Belarus
  • Burma (Myanmar)
  • Cambodia
  • Central African Republic
  • China (including Hong Kong)
  • Congo
  • Cuba
  • Egypt
  • Eritrea
  • Georgia
  • Haiti
  • Iran
  • Iraq
  • Jordan
  • Kazakhstan
  • Kuwait
  • Kyrgyzstan
  • Laos
  • Lebanon
  • Libya
  • Macau
  • Moldova
  • Mongolia
  • Nicaragua
  • North Korea
  • Oman
  • Pakistan
  • Qatar
  • Russia
  • Saudi Arabia
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Tajikistan
  • Turkmenistan
  • Uzbekistan
  • Venezuela
  • Vietnam
  • Yemen
  • Zimbabwe
  • Covered Region of Ukraine (Crimea, Donetsk, and Luhansk regions)

Note: This list of restricted countries is based on evolving government regulations and is not exhaustive. The ECCN (Export Control Classification Number) for our products—3A090(Group D countries), EAR99(Group E countries), 5D992 Mass Market-eligible(Group E countries), 5A002(Group D countries), 5D002 (Group D countries), and 5E002(Group D countries)—are identified using the U.S. Bureau of Industry and Security (BIS), interactive commerce control list as the source of truth, all the above mentioned ECCN can be found at: https://www.bis.gov/regulations/ear/interactive-commerce-control-list and Source of country groups: https://www.bis.gov/regulations/ear/740#supplement-1-740

Policy Enforcement and Due Diligence

E2E Networks mandates a rigorous process of due diligence for every Signup to ensure compliance to offer the services to a limited set of countries.

Reporting Violations

Any suspicious activity or potential violation of this policy must be reported immediately to the E2E Networks Compliance Officer or senior management. Failure to report a known violation may result in severe disciplinary action.

Training and Awareness

E2E Networks provides mandatory training to all employees to ensure they are fully aware of and compliant with this policy and all relevant export laws and regulations.

Contact Information

For any questions, concerns, or to report a potential violation related to this policy, please contact:

Email: compliance@e2enetworks.com

Registered Office Address: E2E Networks Limited, Awfis, First Floor, A-24/9, Mohan Cooperative Industrial Estate, Mathura Road, Saidabad, New Delhi-110044.

We will investigate the matter and are committed to resolving any privacy concerns that you may have.