Export Management Policy Statement

It is the policy of Dwyer Instruments, LLC (Dwyer), that all employees, departments, divisions, domestic and foreign subsidiaries, and affiliates, comply with all U.S. export control laws and regulations, and under no circumstances shall transactions be conducted by, or on behalf of Dwyer contrary to such. All Dwyer employees, especially those with export related responsibilities, must apply due diligence in abiding by the Export Administration Regulations, and comply with Dwyer's export control guidelines, policies, and procedures as outlined in the company's Export Management and Compliance Program policy manual.

The U.S. government regulates exports of U.S. products, technology, and software, including the movement of U.S. origin commodities between foreign countries. Controls are used to regulate the export and re-export of dual-use items; items that have both a civilian and military application. These controls are in place to prevent the distribution of dual-use items that can compromise national security. Certain Dwyer products may be strictly controlled to prevent diversion to those interested in proliferating weapons of mass destruction or terrorist supporting entities.

Penalties for violations of U.S. export control laws and regulations may be imposed by law. It is important to understand that Dwyer and its employees may be subject to criminal penalties and/or administrative sanctions, including substantial fines, revocation of export/import privileges, and imprisonment. Accordingly, Dwyer will view the failure of any employee to comply with its Export Management and Compliance Program, as a serious violation of company policy and will be subject to appropriate disciplinary action.

Export compliance is an important aspect of our corporate culture and is the responsibility of all Dwyer personnel. Formal training will be provided for all employees on a regular and on-going basis, and will be tailored to fit specific departmental requirements and individual responsibilities.