Trade Compliance Policy

Safeera will conduct equipment, software, technology and compute transactions in accordance with applicable export controls, economic sanctions, customs and anti-diversion requirements. This Policy applies to Safeera personnel and representatives. Counterparties are bound to the requirements incorporated into their accepted agreements.

1. Transaction-specific assessment

Advanced GPUs, systems, firmware, software, encryption and technical information may be subject to different controls. Determine the applicable classification, origin, destination, end user, ownership and intended use for the actual transaction. Do not assume that a domestic installation, a residential host or remote access makes a transaction exempt. Equally, do not assume that every cloud interaction is automatically a hardware export.

Use the law and official restrictions in force at the time of the transaction. A country list or historical marketing statement is not a substitute for current review. Obtain required licenses or other authorizations before proceeding and observe their conditions. Unresolved classification or eligibility questions require review by a responsible human with qualified assistance where needed.

2. Customer and supplier information

Counterparties must provide accurate legal identity, location, relevant beneficial ownership, recipients, end users, site and intended use when reasonably required for compliance. Keep material information current. An intermediary must identify the actual party receiving the benefit where required; it may not use its own account to conceal a restricted user.

Safeera may decline or place a transaction on hold where information is insufficient or a material warning sign remains unresolved. Requests must be proportionate and handled under applicable privacy requirements. Citizenship, national origin or a residential address alone is not a universal prohibition; the actual legal restrictions and facts must be evaluated.

3. Prohibited evasion

Do not disguise shipment origin or destination, misclassify components, falsify end-use statements, use an undisclosed reseller, conceal a blocked owner or route payment through an unrelated party to evade controls. Do not use proxies, stolen identities or location-obscuring methods to defeat a lawful service restriction. Legitimate security tools are not prohibited merely because they protect traffic; evasion is.

Do not transfer a Unit, controlled component, technical information or account access to another person or location without required permission and legal review. A financing arrangement or equipment purchase does not remove applicable transfer restrictions.

4. End-use and access controls

Access is limited to approved accounts, locations and uses within the accepted service. Requests associated with prohibited military, weapons, surveillance or other restricted end uses must be assessed under applicable law. A reseller is responsible for the end-user obligations in its agreement and may not create unauthorized subaccounts.

Safeera may use lawful identity, location, authorization and transaction records necessary for screening and enforcement. A compliance review does not authorize unrestricted inspection of private workload content. Scope, access and retention remain subject to applicable data terms and law.

5. Hold, suspension and notice

The responsible company decision-maker may halt shipment, activation, transfer or the affected service while a material issue is reviewed. Continuing unlawful activity is prohibited. Restrictions must be proportionate and preserve safe local operation of equipment. Provide an explanation and a path to supply missing information where law permits.

A hold does not automatically forfeit a reservation, earned payment or prepayment. Funds and property must be handled as the contract and applicable blocking, refund or other legal requirements provide. If a transaction cannot lawfully proceed, Safeera will notify the counterparty where permitted and resolve the unperformed portion accordingly.

6. Records and reporting

Retain classifications, diligence, screening results, authorizations, shipping records and material decisions for the periods required by applicable law, license and legal hold. Different requirements may have different retention periods. Do not alter records or treat an agent-generated screening result as final authority without the required review.

Report suspected evasion or a relevant change to legal@safeera.ai, and an associated account compromise to security@safeera.ai. Safeera will assess necessary containment, correction and official reporting with qualified advice where appropriate. Good-faith reporting is protected from retaliation. Protected communications with regulators do not require permission.

7. Governance

The CEO is responsible for assigning competent review and ensuring no transaction proceeds without required authorization. Internal approval cannot override law. This Policy does not promise that any particular destination or customer is eligible, and does not certify an item classification without the actual technical assessment.

Contact: Safeera, Attention: Legal, 101 Jefferson Dr., Menlo Park, CA 94025, United States; legal@safeera.ai.