Export Control and Trade Compliance Policy

1.1 Purpose

This Export Control & Trade Compliance Policy explains Tool-O's commitment to complying with applicable export control laws, trade sanctions, import restrictions and other trade compliance requirements that may apply to the operation of the Platform.

The purpose of this Policy is to reduce legal and regulatory risks associated with cross-border activities while promoting responsible use of the Platform.

1.2 Objectives

This Policy seeks to:

• promote compliance with applicable export control laws;

• support compliance with trade sanctions;

• reduce regulatory risk;

• encourage lawful cross-border transactions;

• protect the integrity of the Platform;

• support responsible international business practices.

1.3 Scope

This Policy applies to:

• all Users;

• User Accounts;

• listings;

• Bookings;

• payments;

• cross-border activities;

• communications relating to transactions;

• all use of the Platform.

1.4 Guiding Principles

Tool-O administers this Policy in accordance with the following principles:

• legal compliance;

• responsible trade;

• accountability;

• transparency;

• risk management;

• continuous improvement.

1.5 Relationship with Other Policies

This Policy should be read together with the:

• Terms of Use;

• Anti-Money Laundering & Sanctions Policy;

• Payment & Payout Policy;

• Marketplace Integrity Policy;

• Trust & Safety Policy;

• Acceptable Use Policy;

• all other Platform policies.

1.6 Updates

Tool-O may amend this Export Control & Trade Compliance Policy from time to time.

The latest version published on the Platform replaces all previous versions.

2.1 Compliance with Applicable Laws

Users must comply with all applicable export control laws, import regulations, trade sanctions and customs requirements that apply to their activities conducted through the Platform.

Users remain solely responsible for determining whether any applicable legal restrictions apply to their transactions.

2.2 Restricted Transactions

Users must not use the Platform to facilitate transactions that:

• violate export control laws;

• breach applicable trade sanctions;

• circumvent import or export restrictions;

• involve prohibited jurisdictions where unlawful;

• involve prohibited persons or entities;

• otherwise contravene applicable trade compliance requirements.

2.3 Prohibited Goods

Users must not list, offer, rent, transfer or otherwise make available through the Platform any goods where doing so would breach applicable export control or trade laws.

Examples may include:

• military-controlled items;

• defence-related equipment;

• prohibited dual-use goods;

• embargoed products;

• sanctioned goods;

• any other restricted items under applicable law.

2.4 User Responsibilities

Users are responsible for:

• determining whether goods are subject to export controls;

• complying with licensing requirements;

• obtaining any required permits or approvals;

• ensuring lawful importation and exportation;

• complying with customs obligations;

• complying with applicable sanctions laws.

2.5 Cross-Border Activities

Where Platform activities involve multiple jurisdictions, Users must ensure compliance with all applicable laws in each relevant jurisdiction.

Tool-O does not provide legal, customs or export compliance advice.

2.6 Restricted Persons

Users must not knowingly conduct Platform transactions with persons or organisations where doing so would breach applicable sanctions or export control laws.

Users are responsible for undertaking any due diligence they consider appropriate before entering into transactions.

2.7 Investigations

Where Tool-O reasonably suspects a breach of applicable export control or trade compliance requirements, it may:

• investigate the relevant activity;

• request additional information;

• restrict Platform functionality;

• suspend or terminate Accounts;

• remove listings;

• preserve relevant information;

• take other actions reasonably necessary to comply with applicable

laws.

2.8 Reporting Obligations

Users should promptly notify Tool-O where they become aware that a transaction conducted through the Platform may involve:

• export control violations;

• sanctions concerns;

• unlawful cross-border activity;

• prohibited goods;

• false declarations;

• other significant trade compliance risks.

2.9 Cooperation

Users are expected to cooperate with reasonable requests from Tool-O relating to investigations into suspected export control or trade compliance issues, provided such cooperation is consistent with applicable laws.

2.10 Commitment to Responsible Trade

Tool-O supports responsible and lawful trade practices and expects all Users to comply with applicable export control, customs and sanctions requirements when using the Platform.

3.1 Compliance Monitoring

Tool-O may implement reasonable measures to monitor compliance with applicable export control, trade sanctions and trade compliance requirements, including:

• reviewing listings;

• monitoring transaction activity;

• assessing reported concerns;

• reviewing User information where appropriate;

• monitoring compliance trends;

• implementing risk-based controls.

3.2 Risk Assessment

Tool-O may assess export control and trade compliance risks by considering:

• the nature of listed goods;

• countries involved;

• applicable sanctions;

• regulatory requirements;

• transaction characteristics;

• other relevant compliance factors.

3.3 Restricted Jurisdictions

Tool-O may restrict or prohibit Platform access, listings or transactions involving jurisdictions where:

• applicable sanctions apply;

• trade restrictions exist;

• legal compliance cannot reasonably be maintained;

• regulatory obligations require restrictions;

• Platform operations present unacceptable compliance risks.

3.4 Verification Requests

Where reasonably necessary, Tool-O may request additional information from Users, including:

• identity information;

• ownership information;

• details of listed goods;

• intended use of goods;

• destination information;

• documentation reasonably necessary to assess compliance.

Failure to provide requested information may result in restrictions on Platform use.

3.5 Listing Restrictions

Tool-O may refuse, suspend or remove listings that it reasonably believes:

• involve restricted goods;

• breach export control laws;

• violate sanctions requirements;

• present significant regulatory risks;

• otherwise contravene applicable laws or this Policy.

3.6 Record Keeping

Tool-O may maintain records relating to export control and trade compliance matters, including:

• compliance reviews;

• User communications;

• verification records;

• investigation records;

• enforcement actions;

• other relevant compliance information.

Records may be retained in accordance with the Data Retention Policy and applicable laws.

3.7 Cooperation with Authorities

Where required or permitted by applicable law, Tool-O may cooperate with:

• customs authorities;

• export control authorities;

• sanctions regulators;

• law enforcement agencies;

• courts;

• other competent government authorities.

Such cooperation may include preserving or disclosing information where legally required or permitted.

3.8 User Responsibilities

Users remain responsible for:

• complying with applicable trade laws;

• obtaining required licences or approvals;

• ensuring lawful import and export activities;

• maintaining accurate information;

• responding to reasonable compliance requests;

• seeking independent legal or customs advice where appropriate.

3.9 Enforcement Measures

Where Tool-O reasonably believes that this Policy has been breached, it may:

• remove listings;

• suspend or terminate User Accounts;

• restrict transactions;

• preserve relevant information;

• report matters to competent authorities where required or permitted by

law;

• take any other action reasonably necessary to protect the Platform or

comply with applicable legal obligations.

3.10 Commitment to Trade Compliance

Tool-O is committed to supporting lawful domestic and international trade by implementing reasonable compliance measures, encouraging responsible User conduct and taking appropriate action where export control or trade compliance risks are identified.

4.1 Governance

Tool-O is responsible for administering this Export Control & Trade Compliance Policy and may maintain internal procedures to support compliance with applicable export control laws, trade sanctions, customs requirements and related regulatory obligations.

4.2 Compliance

Tool-O seeks to operate the Platform in accordance with applicable export control legislation, trade sanctions, customs laws and other relevant legal requirements.

Nothing in this Policy requires Tool-O to facilitate any transaction that may be unlawful or expose the Platform to unacceptable legal or regulatory risk.

4.3 Policy Review

Tool-O may periodically review this Policy to reflect:

• legislative changes;

• regulatory guidance;

• sanctions updates;

• operational experience;

• international trade developments;

• emerging compliance risks;

• industry best practices.

4.4 Continuous Improvement

Tool-O may periodically review its export control and trade compliance procedures to improve:

• compliance governance;

• risk assessment;

• verification processes;

• investigation procedures;

• record keeping;

• operational controls.

4.5 Risk-Based Approach

Tool-O may apply a risk-based approach when assessing export control and trade compliance matters, taking into account:

• applicable legal requirements;

• regulatory expectations;

• transaction characteristics;

• geographic risks;

• User information;

• operational considerations.

The level of review undertaken may vary depending on the circumstances.

4.6 Relationship with Other Policies

This Export Control & Trade Compliance Policy should be read together with the:

• Terms of Use;

• Anti-Money Laundering & Sanctions Policy;

• Payment & Payout Policy;

• Marketplace Integrity Policy;

• Trust & Safety Policy;

• Acceptable Use Policy;

• all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.7 Contact

Questions regarding this Export Control & Trade Compliance Policy or reports relating to suspected trade compliance concerns may be submitted to Tool-O using the contact details published on the Platform.

4.8 Policy Updates

Tool-O may amend this Export Control & Trade Compliance Policy from time to time.

The latest version published on the Platform replaces all previous versions.

4.9 Commitment

Tool-O is committed to promoting lawful and responsible trade by implementing reasonable compliance measures, supporting regulatory compliance and encouraging Users to conduct transactions in accordance with applicable laws.

4.10 Final Statement

Compliance with export control laws, trade sanctions and customs requirements helps protect Users, the Platform and the broader marketplace.

By maintaining appropriate governance, encouraging responsible User conduct and taking reasonable steps to manage trade compliance risks, Tool-O seeks to operate a secure, lawful and trusted marketplace.

END OF EXPORT CONTROL & TRADE COMPLIANCE POLICY