Export Compliance Policy

1. Applicable Regulatory Frameworks

• US Export Administration Regulations (EAR) and ITAR
• EU Dual-Use Regulation (2021/821) and Common Military List controls
• UK Export Control Order 2008 and Strategic Export Controls
• UAE Strategic Goods and Dual-Use Items controls
• Uganda Export Policy and mineral export licensing requirements
• OECD Due Diligence Guidance for Responsible Mineral Supply Chains

2. Commodity Classification

All commodities are classified under applicable export control schedules prior to transaction execution. Special attention is given to strategic minerals which may be subject to critical minerals export restrictions.

3. End-User Controls

All transactions are subject to end-user screening. We obtain end-user declarations where required by law and verify that stated end-use is consistent with the commodity and the counterparty's business.

4. Licensing

Where an export licence is required, KGML will obtain the relevant permission before the transaction proceeds. Export documentation must be accurate, complete, and retained for the period required by applicable law.

5. Record Keeping

All export documentation, licences, and compliance records are retained for a minimum of five years following the date of export.