STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09_ PAGE: 1 of 12

Export and Trade Compliance Procedure
TITLE:

Notice: The information contained herein is the property of Kennametal Inc. and/or a Kennametal Inc. subsidiary,and may contain proprietary or trade secret information and intellectual property rights. It has been submitted toyou in confidence for use internally within Kennametal for a specific purpose and may only be used for that
purpose. The reproduction, distribution and utilization of this procedure, in whole or in part, as well as thecommunication of any of its contents to any unauthorized individuals is prohibited. All rights reserved.
This page is a record of allrevisions of the Procedure.

REV
05

BY
Mike
Waldrop06

Mike
Waldrop07

Mike
Waldrop

For convenience, the nature of the revision is briefly noted underremarks. Please review the Procedure to assure complete
understanding of all relevant changes, additions, or deletions. Unlessotherwise stated, this revision should be implemented upon receipt.
REMARKS
Removed Jeff Black and replaced with Mike Waldrop, other minor
updates to general wording. Added Iran to the embargoed countries
list. Expanded the Embargo on the Crimea region of the Ukraine.

PAGES

3,7,9

Added restrictions on China, Venezuela and Russia end users and end
uses. Removed strict restrictions on Sudan. Added information toEuropean technology controls. Added additional information related
to weapon systems sales.
Modified country restrictions for Cambodia and Turkey

08

Mike
Waldrop

3,4

09

Mike
Waldrop

7,11

Removed specific computer system references and named
responsibilities for Technology controls. Russia and Belarus wereadded to the list of embargoed countries. Expanded China controls onsupercomputer and semiconductor manufacture equipment included
Additional comments regarding Entity List screening requirements
for China. Hard Carry export/import Guidance.
.

REVISSUED BY

APPROVED BYAPPROVAL DATE

00

Mike Waldrop

Kevin Nowe01/24/2014

01

Mike Waldrop

Kevin Nowe

02/11/2015

02

Mike Waldrop

Kevin Nowe

09/23/2015

03

Mike Waldrop

Kevin Nowe04/01/201604

Jeff Black

Michelle Keating

08/25/2017

05

Mike Waldrop

Michelle Keating

03/08/2019

06

Mike Waldrop

Michelle Keating

02/05/2021

07

Mike Waldrop

Michelle Keating

01/24/2022

08

Mike Waldrop

Michelle Keating

02/08/2023

09

Mike Waldrop

Michelle Keating

01/25/2024

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 2 of 11

Export and Trade Compliance Procedure
I.

SCOPE

This Export and Trade Compliance Procedure (this “Procedure”) is effective
immediately and supersedes the previous version of the Procedure, which is dated
January 20, 2024. It is important to review this Procedure to understand the changes
that have occurred since it was last distributed and to reacquaint yourself with thisProcedure generally. This Procedure applies to business conducted by Kennametal
Inc. and its branches, subsidiaries and affiliates worldwide (hereinafter collectively
called “Kennametal”).
The focus of this Procedure is on United States law. Laws of otherjurisdictions in which Kennametal operates may be applicable and should beobserved. In the event of a conflict between United States law and that of anotherjurisdiction, please contact Kennametal’s Office of the General Counsel. It is
important to note that this Procedure applies to transfers of items (hardware,
software, and technology) or services across borders, whether or not those transfers
are between and among Kennametal affiliates or involve third parties. In addition, theProcedure also applies to transfers of technology or software source codes thatinvolve foreign persons, as more fully described below.
Kennametal’s Trade Compliance Department has implemented an Export
Management System, which provides structure and guidance to assure
Kennametal’s continued compliance with applicable laws. In order to ensure theeffectiveness of Kennametal’s Export Management System, it is critical that theTrade Compliance Coordinators at each Kennametal facility, as well as all others
who are in any way involved in the exportation of products, services and technology,
fully understand this Procedure and accept their responsibility to assure fullcompliance with all aspects of it.
If you have any questions about the effect of this Procedure on any particular
proposed transaction, please contact the Trade Compliance Department. Completionand submission of the attached questionnaire will help expedite a review of thematter and will eliminate the delays caused when additional information must be
requested.
II.

TECHNOLOGY TRANSFER

1.
The restrictions set forth below apply to the foreign and domestic sale,purchase or transfer by any means of products, components, software and services
from all countries, as well as the transfer of the technology to produce, develop
and/or use such products.
2.
It is important to note that the countries where Kennametal conducts
business, the transfer of the technology to produce, develop or use products as anexport that is governed by multiple export regulations. For this reason, any referencein this Procedure to “products” also includes services and the technical informationthat would allow a company to produce, develop or use the products. With respect tosome types of items, such as defense and military-related items, or transfers which
The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 3 of 11

Export and Trade Compliance Procedure
involve sanctioned countries or persons, a broader range of technology and services
are controlled, not limited to technology related to the production, development or
use of items. This Procedure also applies to:a) the transfer of technology and software source codes to foreign individuals
within a country that are not citizens of the country. For example, those whoare not U.S. citizens or U.S. lawful permanent residents, located in the U.S.,
and access technology in the U.S.;b) the export from one foreign country to another of certain foreign-madeproducts that incorporate U.S. controlled content; andc) the trade with restricted and embargoed countries, entities and individuals, as
more fully described below.
3.
Similarly, without appropriate authorization, Kennametal may nottransfer controlled technology or know-how to nationals of countries that areotherwise subject to export-licensing requirements for such technology or knowhow, regardless of where such transfer occurs. This would include the transfer ofexport-controlled technology within the United States to Kennametal employee who
is a foreign national, to a foreign national on temporary assignment from a nonUnited States Kennametal affiliate, or to a foreign national visiting a Kennametal
facility or attending a meeting with Kennametal employees. In light of theserestrictions, advance compliance planning must be initiated before approving eventemporary intra-company transfer of non-United States nationals to Kennametal
facilities within the United States, as well as the temporary transfer of employees
worldwide to countries of which they are not citizens or permanent residents.
4.
This Procedure also applies to technology transfers from and within
the European Union (“EU”). The EU provides for an additional layer of complexity astransfers related to controlled defense technology transferred among member
nations. While most non-military items can be moved freely among the member
states, each member state maintains unique export requirements for military items
and technology. For further guidance on this topic, please contact Petra Stockmann,
Manager Trade Compliance EMEA, at petra.stockmann@kennametal.com.
5.
This Procedure requires Global IT to establish and maintain theappropriate controls to prevent unwarranted access to controlled data. These
controls must be maintained by the various business systems, networks and accesspoints that make up Kennametal’s global computing environment.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 4 of 11

Export and Trade Compliance Procedure
III.

EMBARGOED AND RESTRICTED COUNTRIES AND RESTRICTEDENTITIES

For various reasons, there are groups of countries with which trade is
specifically prohibited or restricted. The transaction of business with these countries,
including both the sale/exportation of products to and purchase/importation of
products from these countries, is specifically restricted as follows:
1.

Embargoed Countries –Country

Prohibitions

Notes

Belarus

All Transactions

1.A

Cuba

All Transactions

1.A

Iran

All Transactions

1.A

North Korea

All Transactions

1.A

RussiaAll Transactions

1.A

Syria

All Transactions

1.A

Venezuela

All Transactions with theGovernment of Venezuela

1.B

A.

These countries (including their governments, companies andnationals) are subject to comprehensive trade control
restrictions; thus Kennametal does not generally conduct any
transactions with or involving these countries. Please contact
the Trade Compliance Department or the Office of the GeneralCounsel for guidance or with any questions.

B.

The Government of Venezuela is subject to a general embargo,
thus U.S. persons are prohibited from engaging in alltransactions with the Government and any entity it owns.
Kennametal generally does not conduct transactions with or
involving Venezuela. Please contact the Trade ComplianceDepartment or the Office of the General Counsel for guidance orwith any questions.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 5 of 11

Export and Trade Compliance Procedure
2.

Kennametal Restricted Countries -Country
Afghanistan
Armenia

Prohibitions
End user/End use restrictions
Military and defense end use concerns

Notes
2.A
2.A

Azerbaijan

Military and defense end use concerns

2.A

Burma/Myanmar

End user/End use restrictions

2.A

Cambodia

Military and defense end use concerns

2.A

Central Africa
Republic

Military and defense end use concerns

2.A

China

Expanded sanctioned parties / entity list
2.C
additions. Military and defense end use andend-user concerns. Comprehensive newcontrols on the export of equipment to be usedin the manufacture of advanced computers andsemiconductors (including civilian enduse/user).

Congo

Military and defense end use concerns

2.A

Cypress

End user/End use restrictions

2.A

Eritrea

Military and defense end use concerns

2.A

Iraq

End user/End use restrictions

2.A

Haiti

End user/End use restrictions

2.A

LebanonMilitary and defense end use concerns

2.A

Libya

Military and defense end use concerns

2.A

Palestinian
Territories (WestBank and Gaza
Strip)
Somalia

End user/End use restrictions

2.A

Military and defense end use concerns

2.A

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 6 of 11

Export and Trade Compliance Procedure
South Sudan

Military and defense end use concerns

2.A

Sri Lanka

Military and defense end use concerns

2.A

Sudan

Military and defense end use concerns

2.A

TurkeyActivities related to offshore drilling ofHydrocarbons not authorized by the Republicof Cyprus.

2A

UkraineAll transactions are prohibited to those areasthat are not under the control of Ukraine. This
includes Crimea, Donetsk, Kherson, Luhansk,
and Zaporizhzhia.

2.B

Venezuela

Unless EAR99, or controlled for AT or CC
purposes only, most products cannot beexported without a license.

2.D

Yemen

End user/End use restrictions

2.A

Zimbabwe

Military and defense end use concerns

2.A

A.

Other countries are subject to trade control restrictions that are
more limited in scope. These include full or partial restrictions on
defense trade activities with these countries, end-use or enduser based restrictions, limited sanctions, or European tradingrelated restrictions. For any proposed transactions involving
these countries, contact the Trade Compliance Department at
Mike.Waldrop@Kennametal.com and include the information
requested on the Export and Trade Compliance Review Form.

B.

Certain transactions to Ukraine are restricted by both the US
and the EU. ALL transactions to the following regions areprohibited: Crimea, Donetsk, Kherson, Luhansk, andZaporizhzhia. Please contact the Trade Compliance Department
or the Office of the General Counsel for guidance or with anyquestions.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 7 of 11

Export and Trade Compliance Procedure
C.

China - While United States law generally permits exports andre-exports of commercial items to China, the United States andthe EU have implemented a comprehensive arms embargo
against China that prohibits, absent a United States Presidential
waiver, all exports or re-exports of defense articles, defense
services and related technical data to China or to Chinese
nationals; all temporary imports into the United States ofdefense articles from China; and all brokering of defense articles
and defense services involving China. In addition, exports andre-exports of more than 30 types of commercial, dual-use items
that would not otherwise require United States Government
licensing to be exported or re-exported to China require
licensing if the exporter knows or has reason to know that theitem is intended for Chinese military end-use or a military enduser, or for the manufacture of supercomputers andsemiconductors (even in civilian end-use/user). These
restrictions have been further expanded in 2023. In addition,even if the contemplated trade does not involve theabovementioned type of items, it is highly advisable to makesure the Chinese counterparty is not on the Entity List
(Supplement No. 4 to Part 744 of the Export Administration
Regulations). Because of the increasing enforcement focus on
China, any prospective business with Chinese customers thatinvolves any connection to defense, military, supercomputer orsemiconductor applications should be carefully reviewed by theTrade Compliance Department by contacting
Gracie.Gu@kennametal.com and include the information
requested on the Export and Trade Compliance Review Form inadvance of engaging the business.

D.

While the Government of Venezuela is subject to a U.S.
embargo, not all transactions with Venezuelan nationals or
privately owned Venezuelan companies will requireauthorization from the Office of Foreign Assets Control (OFAC).
However, the sale of U.S. origin products classified as anythingother than EAR99 or controlled for anti-terrorism or crime control
purposes, will require a license from the Department ofCommerce. Additionally, exports and re-exports of more than 30
types of commercial, dual-use items that would not otherwise
require United States Government licensing to be exported or
re-exported to Venezuela where there is military end-use or a
military end-user should be carefully reviewed by the Trade
Compliance Department. For any proposed transactions
involving Venezuela, contact the Trade Compliance Department
at Mike.Waldrop@Kennametal.com and include the information
requested on the Export and Trade Compliance Review
Questionnaire.
The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 8 of 11

Export and Trade Compliance Procedure
3.

Restricted Entities –In addition to the embargoed countries and Kennametal Restricted
Countries outlined above in tables 1 and 2, governments periodicallyissue lists of specific companies, vessels, groups and individuals inmany countries with whom trade is prohibited. Targetedcomprehensive sanctions are also in place against certain identified
persons and entities involved with weapons proliferation, terrorism,
narcotics trafficking and other sensitive activities. The relevant lists
issued by the various governments are available online through the
Kennametal site KDS.Kennametal.com from all computers connectedto the Kennametal network.
All new customer and vendor accounts recorded on the Kennametal’s
global ERP system SAP are screened automatically when customer orvendor data is changed or when a sales order or purchase order are
entered or changed.
For distributors, other 3rd party transactions and those Kennametaltransactions not being performed on SAP, screening of the relevant
parties must be performed manually against these lists, prior toinitiating any business, to ensure that there are no dealings with orcommitments to restricted parties
If you have any questions related to restricted entities, please contact
the Trade Compliance Department or the Office of the GeneralCounsel.

IV.

HIGH RISK INDICATORS

1.
There are other situations in which proposed transactions must be
reviewed by the Trade Compliance Department or the Office of the General Counsel,
prior to proceeding to do business. These situations include the following:A.

If the circumstances suggest a risk of diversion1 to a prohibitedor sensitive country destination or end-user; andB.

If there are suspicious or questionable circumstances involved ina sale, such as a lack of the usual information about a proposedtransaction, a request to use an unusual route for shipment or
unusual product specifications that are inconsistent with thecustomer’s stated end-use of the product.

1 See Tri-Seal Compliance Note (March 2, 2023) issued by DOJ, OFAC and BIS for common
red flag indicators of diversion; see BIS Common High Priority Items List for Russia; see also
Quint-Seal Iran Ballistic Missile Procurement Advisory (October 18, 2023) for Iran diversion.
The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 9 of 11

Export and Trade Compliance Procedure2.
Any situation involving any of the circumstances set forth above, orsimilar circumstances suggesting the possible diversion to an unintended party,
location or end-use, should serve as a red flag or warning and should result in an
immediate inquiry addressed to the Trade Compliance Department or the Office of
the General Counsel prior to proceeding. In such cases, as much information as
possible should be provided in advance on the attached Export and Trade
Compliance Review Form.

V.

MISSILES, NUCLEAR ACTIVITIES, CHEMICAL AND BIOLOGICALWEAPONS AND TERRORISM

1.
United States law and this Procedure restrict Kennametal fromengaging in any activity which supports the design, development, production,
stockpiling or use of missiles, nuclear weapons, chemical or biologicalweapons or certain nuclear research or power facilities outside of the list of
countries below. Any business related to this section must be discussed with theTrade Compliance Department or the Office of the General Counsel immediately as
it will require export licensing.

2.
Because of the high concern for activities that may support the
proliferation of weapons of mass destruction (including nuclear explosives; chemicaland biological weapons; and missiles) and terrorism, no business should be
conducted that could provide possible support for such activities or lead to the illegal
diversion of products for such purposes.

VI.

Australia
GreeceNorwayAustria
Iceland
Portugal
Belgium
IrelandSpain
CanadaItaly
SwedenDenmarkJapan
TurkeyFinland
Luxembourg
United Kingdom
FranceNetherlands
United States of America
Germany
New Zealand
MUNITIONS AND CONVENTIONAL WEAPONS
Prior Trade Compliance Department or the Office of the General Counsel
approval is required for the import or export (direct or indirect) of products,
components, services or technology that are specially designed for or that are
to be used in the production, servicing and/or sale of munitions (including
ammunition and conventional weapons) and for the manufacture of any suchproducts or components, including ammunition, firearms, or components ofeither ammunition or firearms.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 10 of 11

Export and Trade Compliance ProcedureVII.

ANTIBOYCOTT REGULATIONS

Any request or invitation to Kennametal to participate in the Arab Boycott ofIsrael (or Boycotts of any other country in which the United States does notparticipate) must be reported immediately to the Trade Compliance Department or
the Office of the General Counsel and not acted upon in any way until guidance isprovided. Such requests are most likely to come from Middle Eastern countries andprobably would be contained in commercial documents such as requests for
quotation, purchase orders, letters of credit or a combination of these documents,
although the requests may take any form, and may even be oral. Some examples
are as follows: requests to certify that goods are not of Israeli origin or requests toagree not to deal with certain “blacklisted” suppliers. Kennametal is required topromptly report to the United States Government such requests received by
Kennametal, subsidiaries or affiliates, whether or not such business is actuallytransacted. All such reporting is coordinated through the Trade ComplianceDepartment and the Office of the General Counsel.
VIII.

EXPORT DOCUMENTATION AND LICENSING

1.
In addition to the restrictions, considerations and prohibitions under
United States law that are discussed above, it is imperative that proper export
licensing and documentation procedures be followed with respect to all exports fromany country to ensure that they are conducted in accordance with Kennametal’s
procedures, the laws of the country from which the export occurs and any other lawsthat might apply. For example, United States law requires that exports from theUnited States satisfy certain documentation and other requirements, including, whennecessary, the use of a destination control statement on shipping documents and thecompletion and filing of Electronic Export Information (an Automated Export System
record related to an export transaction). In addition, in some cases, it is necessary toapply for and receive prior approval from United States authorities for the export orre-export of certain products or for sales to certain destinations. Governments ofother countries have similar export procedures that must also be followed whenapplicable.
2.
All Kennametal personnel who are involved in the exportation or
importation of products, including the preparation of export or import documentation,must receive appropriate training, to assure that they understand the requirements
associated with exporting products from or importing products into their country. In
order to schedule export/import compliance training or to address any questions
regarding required documentation, licensing or training, please contact the Trade
Compliance Department directly.
If you have any questions at any time concerning this Procedure or its
application to a specific transaction, please contact Mike Waldrop, Sr Manager,
Ethics and Compliance Programs, by telephone at +(01) 724.539.5147 or by e- mailat Mike.Waldrop@kennametal.com. The Trade Compliance Department will makeThe electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 11 of 11

Export and Trade Compliance Procedure
every effort to provide you with a prompt answer and will not unreasonably refuse ordelay lawful business opportunities.
This Procedure is to be followed in all cases and will be updated as necessary
by the Trade Compliance Department. Compliance with this Procedure and theapplicable export, import and other trade compliance laws of the United States andother countries is extremely important! Please distribute this Procedure throughout
your organization as appropriate.
IX.

Exports or Imports transported by an individual, otherwise known as a
“Hand Carry”

A hand carry is when an item of commercial value is transported by an individualcrossing an international border in their luggage, suitcase, or vehicle. A handcarried item may include samples, prototypes, equipment, tools, or otheritems. Hand carry items are considered business moves which must follow export
and import regulations just like a transported shipment. It is a recommended
practice is to avoid hand carries or only use hand carries for extremely urgent or
emergency situations when there is no alternative mode of transportation. Travelers
must follow applicable export control and customs requirements for the hand carried
item in the export and import countries. Failure to properly declare hand carried
items across a border can lead to customs delays, seizure of goods, or violation ofimport and export laws. Consult with the Trade Compliance department for
guidance in the event you are considering a hand carry export.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.

STANDARD PROCEDURE
PROCEDURE NO. : EXP0001
REVISION: 09__ PAGE: 12 of 11

Export and Trade Compliance Procedure
X.

Export and Trade Compliance Review Questionnaire (Products,
Services, Software, and Technology)

All inquiries made for the purpose of requesting a compliance review oftransactions, in accordance with Kennametal’s Export and Trade Compliance
Procedure (Products, Services, and Technology), must contain the following
information. For all such inquiries, complete this questionnaire and email it to the
Kennametal Trade Compliance group or the Office of the General Counsel.
1.
Name and location of the Kennametal representative or affiliate who ismaking the inquiry.
2.
Shipping route for the products, including the ultimate country ofdestination.
3.

Name, address, and line of business of the direct customer.

4.
Name, address, and line of business of the ultimate end-user of the
products, services, or technology and any intermediate user of the products,
services, or technology, if different from the customer listed in #3, above.
5.
Products, services, or technology being exported and where they
originated or were manufactured.
6.
7.
exported.

Customer’s intended end use for the products, services or technology.
Value (in U.S. Dollars) of products, services, or technology being

8.
The percentage (%) of value stated in #7, above, which represents the
U.S. content of the product, if the product was manufactured abroad.

The electronic version of this Procedure is a controlled document.
Any printed copies of this document are for REFERENCE ONLY.