Export Control & Compliance Policy

Effective Date: 24/10/2025 Last Updated: 24/10/2025

Noorder Dynamics B.V. ("we", "our", or "us"), established in The Netherlands, is dedicated to the highest standards of international trade compliance. This Export Control & Compliance Policy outlines our commitment to strictly adhering to all applicable Dutch, European Union (EU), and international export control laws, regulations, and sanctions.

This commitment is fundamental to our business operations and our role as a trusted partner in the defense and security ecosystem.

1. Our Commitment to Compliance

Noorder Dynamics B.V. maintains a zero-tolerance policy for violations of export control and sanctions laws. Our commitment includes, but is not limited to, compliance with:

  • EU Dual-Use Regulation: Regulation (EU) 2021/821, controlling the export, transfer, brokering, technical assistance, and transit of dual-use items.

  • Common Position on Arms Exports: The EU Common Position defining common rules governing control of exports of military technology and equipment.

  • Dutch National Legislation: All relevant Dutch national laws governing the export of strategic goods and services.

  • International Sanctions: All trade and financial sanctions imposed by the United Nations (UN), the European Union (EU), and relevant national authorities.

  • Wassenaar Arrangement: The multilateral export control regime related to conventional arms and dual-use goods and technologies.

2. Scope of Policy

This policy applies to all activities conducted by Noorder Dynamics B.V., including:

  • The export, re-export, and transfer of our products (including the Modular Launcher System - MLS), technology, and related software.

  • The provision of services, technical assistance, training, and financing related to strategic goods.

  • All employees, contractors, consultants, and third-party partners acting on behalf of Noorder Dynamics B.V.

3. Classification and Licensing

We employ rigorous internal procedures to ensure that all our products and technology are correctly classified for export purposes.

  • Classification: All MLS components, A-Kits/B-Kits, software, and technical data are assessed to determine their appropriate control list classification (e.g., EU Common Military List or Dual-Use Regulation annexes).

  • Licensing: We ensure that all required export and transfer licenses are obtained from the relevant Dutch and EU competent authorities prior to any transaction involving controlled items or destinations. This includes conducting thorough End-Use and End-User Checks to mitigate diversion risk.

4. Sanctions and Restricted Parties Screening

  • We conduct mandatory, ongoing screening of all customers, partners, suppliers, employees, and relevant third parties against all applicable EU, UN, and national sanctions lists and denied party lists.

  • Transactions involving sanctioned countries, entities, or individuals are strictly prohibited unless expressly authorized by a competent governmental authority.

5. Compliance Training and Internal Controls

  • Training: All employees involved in the sale, transfer, engineering, or documentation of controlled items receive mandatory, recurring training on export control regulations and procedures.

  • Internal Compliance Program (ICP): We maintain a documented ICP to manage and mitigate export compliance risks across all business functions.

  • Documentation: We maintain complete and accurate records of all export-controlled transactions, classifications, and licenses for the prescribed period required by law.

6. Reporting Violations

  • Noorder Dynamics B.V. is committed to transparency. Any suspected violation of this policy or applicable export control laws must be immediately reported to the Compliance Officer or senior management.

  • Failure by any employee or third party to comply with this policy will result in appropriate disciplinary action, up to and including termination of employment or contract, and may result in severe criminal and civil penalties.

7. Contact for Compliance Inquiries

For specific questions regarding the classification, end-use, or licensing requirements of Noorder Dynamics B.V. products or technology, please contact our Compliance Department:

Compliance Officer Noorder Dynamics B.V. Email: office@noorderdynamics.com

(Subject: Export Compliance Inquiry)