PUBLIC COMMITMENT STATEMENT
Public Commitment Statement
Shaping a New Blueprint for the Space Economy
Emposat Co., Ltd.
Public Commitment on Global Compliance, Anti-Sanctions and Anti-Proliferation
As a technology company specializing in civilian commercial satellite telemetry, tracking and command (TT&C) and data reception services, we always adhere to the principle of peaceful use of outer space, strictly comply with the Export Control Law of the People's Republic of China, the National Security Law and other applicable laws and regulations, fully align with UN Security Council sanctions resolutions and internationally recognized anti-proliferation and export control rules, and have established and implemented a complete Sanctions Compliance Program (SCP). To proactively manage cross-border compliance risks, clearly define business boundaries, and eliminate the possibility of non-compliant cooperation, we hereby make the following compliance commitments:
I. Adhering to Civilian and Peaceful Use Boundaries
We only provide neutral, civilian, and commercial technical services such as satellite ground station TT&C and data reception. All businesses are exclusively for peaceful purposes. We will not, in any form, use our products, services, or technologies for military conflicts, warfare, the development/proliferation of weapons of mass destruction, terrorist activities, or intelligence collection, and we proactively isolate the risk of non-peaceful applications of aerospace technology.
II. Strictly Prohibiting Any Cooperation with Sensitive Entities
We have established a partner compliance screening mechanism covering the entire business chain, and routinely check against the UN sanctions list, the OFAC SDN list, and high-risk entity lists related to military, proliferation, and terrorism. We solemnly commit that we have never cooperated with any military-affiliated entity; going forward, we will not engage in any direct or indirect business with any entity listed under international sanctions, military-related entities, proliferation-related entities, or other high-risk non-compliant parties, nor will we circumvent compliance screening and sanctions prohibitions through third parties, affiliates, or concealed transactions.
III. Upholding Business Neutrality and Responsibility Boundaries
We only provide pure technical services of satellite TT&C and data reception to customers. We do not possess information on customers' specific satellite missions, payload configurations, data content, or end use, and do not participate in non-TT&C activities such as mission design or application development. We strictly uphold the neutrality and compliance boundaries of commercial services.
IV. Implementing a Full-Process Sanctions Compliance Program (SCP)
We have established a sanctions compliance management system consistent with OFAC compliance and internal control requirements, including full-process mechanisms such as partner due diligence, periodic screening of high-risk entities, graded approval for cross-border business, employee compliance training, retention of compliance records, regular internal audits, and reporting and handling of risk incidents, ensuring that all business activities are compliant and traceable, risks are controllable, and international regulatory compliance requirements continue to be met.
V. Strictly Observing Geographic Compliance and Cross-Border Business Rules
When conducting global business, we strictly avoid internationally sanctioned jurisdictions, high-risk conflict areas, and UN embargoed regions. All cross-border services, technical exchanges, and commercial cooperation strictly comply with China's export control regulations and the laws and regulations of the places where business is conducted. We do not engage in non-compliant cross-border transactions.
VI. Complying with Laws and Openly Accepting Supervision
We firmly comply with applicable Chinese and foreign laws and regulations and internationally recognized compliance standards, oppose any unfounded associations and malicious speculation lacking factual basis, and voluntarily accept compliance supervision from regulatory authorities of various countries, the global commercial space industry, and the public.
Emposat Co., Ltd.
June 15, 2026