Compliance

Export Compliance Commitment of MACRO NEO

MACRO NEO is firmly committed to complying with all applicable export control laws and regulations, including those of China, the United States, the European Union, and other relevant jurisdictions. We recognize the importance of adhering to these regulations to fulfill our obligations and responsibilities as a trusted enterprise. Our commitment to export compliance underpins our corporate values of integrity, responsibility, and trustworthiness, as we strive to build enduring relationships with our customers, suppliers, and partners worldwide. At MACRO NEO, we firmly believe that compliance with export control laws and regulations is essential for effectively mitigating trade compliance risks, strengthening our global competitiveness, and ensuring sustainable development.

Internal Compliance Program (ICP)

MACRO NEO has established and implemented an Internal Compliance Program (ICP) founded on the principle of “catch-all” control, placing export control obligations above commercial interests. If MACRO NEO believes that any products, technologies, or services, whether physical or intangible, may be used in the development or manufacturing of weapons of mass destruction, their delivery systems, unauthorized conventional military equipment, or any prohibited end-use that could jeopardize peace or stability or support terrorism, MACRO NEO will apply strict export control measures in accordance with the “catch-all” principle and refrain from exporting such items.

Verification and Compliance Measures

We take proactive measures to verify and screen all transaction parties, including customers, suppliers, and partners, to ensure full compliance with export control laws and sanctions regulations. MACRO NEO conducts export control classifications for all products and technologies and obtains necessary export licenses when required. Additionally, we maintain close communications with government trade compliance regulators, non-governmental organizations, and export control legal and compliance experts to stay informed of policy changes and obtain guidance as needed.

Trade Compliance Office

MACRO NEO has established a dedicated Trade Compliance Office responsible for the development, implementation, and continuous improvement of our export control and sanctions compliance policies, systems, and procedures. This office drives compliance across all relevant business units and corporate functions. To support the effective implementation of these policies, MACRO NEO clearly defines the roles and responsibilities of relevant corporate functions, provides comprehensive guidance documents, and maintains a robust recordkeeping system. We also invest in regular training and professional development to strengthen the export control knowledge and skills of our employees and management team, and conduct periodic internal assessments and audits of our trade compliance program.

Employee Accountability

Every MACRO NEO employee is expected to uphold our trade compliance standards and adhere to the related corporate policies. MACRO NEO has implemented a reward and disciplinary system to recognize employees who successfully uphold export control policies, while addressing and penalizing any violations to reinforce the importance of compliance. Employees found to be in breach of applicable laws and regulations are held legally accountable.