International Export Compliance Certification
Thank you for taking the time to fill out this International Export Compliance Certification. As part of doing business with Exelis
Systems Corporation and providing non-US companies to perform a defense service, Exelis Systems Corporation is requesting
information from your Corporation. In order for Exelis Systems Corporation to apply for proper export authorizations and to
comply with the United States International Traffic and Arms Regulations (ITAR), Exelis Systems Corporation needs to have
some information about your company. It is possible that Exelis Systems Corporation will need to apply for a Technical
Assistance Agreement (TAA) from the United States, Department of Defense Trade Compliance (DDTC). This certification will
help our Export Control Office determine if export control authorization is needed. For more information, please see page 2-3 on
definitions.
Section 1: Supplier Export Compliance Point of Contact:
Name of authorized company individual to discuss and respond to the export compliance requirements of this certification:
Printed
Name:
Company
Name:
Printed Title:
Telephone:
Email:
Section 2: Supplier Information:
1.
Are you a NON-U.S. company or other legal entity?
Yes (This means that you are NOT a corporation, business association, partnership, society, trust, or any other
entity that is incorporated to do business in the United States.)
No (This means that your company or legal entity is a U.S. corporation, business association, partnership, society,
trust, or any other entity that is incorporated to do business in the United States.)
2.
Yes
No
Does your company employ Host Country/Local Nationals (HCN), Third Country Nationals (TCN) or
Dual Nationals (DCN) as contract labor or consultants? If Yes, please provide us a list indicating the
citizenship and country of birth (as listed on Passport) of your employees and attach it to this certification.
3.
Yes
No
Does your company employ any Host Country/Local Nationals (HCN), Third Country Nationals, (TCN)
or Dual Nationals (DN) who have passports or were born in the following countries? (Afghanistan,
Burma, Belarus, China, Cote d’lvoire, Cuba, Cyprus, Democratic Republic of the Congo, Eritrea, Haiti, Iran,
Iraq, Lebanon, Liberia, Libya, North Korea, Rwanda, Russia, Sierra Leone, Somalia, Sudan, Syria, Venezuela,
Vietnam, Yemen, Zimbabwe and Shri Lanka) If Yes, please circle those that apply. For more information
see definitions on page 3.
4.
Yes
No
Will you be providing Exelis Systems Corporation any Host Nationals (HCN), Third Country Nationals
(TCN), or Dual Nationals (DCN) that will be working on Defense Articles? (see Definitions on page 2) If
Yes, you will Need a signed Technical Assistance Agreement (TAA) approved by the United States
State Department. Exelis Systems Corporation will apply for the TAA.
5.
Yes
No
Does your company employ and provide any labor providers to Exelis Systems Corporation that is a
U.S. person? A U.S. person is someone who is a U.S. citizen or U.S. permanent resident alien (sometimes
referred to as a “green card holder”).
6.
Yes
No
Are you familiar with the U.S. International Trade Arms Regulations (ITAR)? If No, would you be
interested in receiving training? Yes or No (please circle)
7.
Yes
No
Will you subcontract any of your labor services out to NON-U.S. companies in any way?
Section 3: Certification:
I certify that to the best of my knowledge the above information is true and correct.
Your Printed Name
Printed Company Name
Your Printed Title
Today’s Date
Your Personal Signature
Please mail this completed form to the Exelis Systems Corporation, Program Office Purchasing Dept.
Form-PU-032 (Rev. 03/10)
Previous editions are obsolete.
Page 1 of 4
Use/disclosure of data on this sheet is subject
to the restrictions as stated in P&SP QM 2.1.
Form-PU-032 (Rev. 03/10)
Previous editions are obsolete.
Page 2 of 4
Use/disclosure of data on this sheet is subject
to the restrictions as stated in P&SP QM 2.1.
Pertinent ITAR Definitions
The International Traffic and Arms
The International Traffic in Arms Regulations (ITAR), 22 CFR §§ 120-130, is implemented by the Department of State and to regulate
defense articles and services and related technical data that are identified on the Munitions Control List (MCL), 22 CFR § 121.1. Complete,
on-line versions of the ITAR and MCL are available online at www.pmdtc.org/reference.htm.
§ 120.15 U.S. Person
U.S. person means a person (as defined in § 120.14 of this part) who is lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or
who is a protected individual as defined by 8 U.S.C. 1324b(a)(3). It also means any corporation, business association, partnership, society,
trust, or any other entity, organization or group that is incorporated to do business in the United States. It also includes any governmental
(federal, state, or local) entity. It does not include any foreign person as defined in § 120.16 of this part.
History: 49 FR 47684, Dec. 6, 1984; 58 FR 39285, July 22, 1993; 59 FR 25811, May 18, 1994; amended at 71 FR 20534, Apr. 21, 2006.
§ 120.16 Foreign Person
Foreign person means any natural person who is not a lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or who is not a
protected individual as defined by 8 U.S.C. 1324b(a)(3). It also means any foreign corporation, business association, partnership, trust,
society, or any other entity or group that is not incorporated or organized to do business in the United States, as well as international
organizations, foreign governments and any agency or subdivision of foreign governments (e.g., diplomatic missions).
History: 59 FR 25811, May 18, 1994; 71 FR 20534, Apr. 21, 2006.
§ 120.10 Technical Data
(a) Technical data means, for purposes of this subchapter:
(1) Information, other than software as defined in § 120.10(a)(4) which is required for the design, development, production,
manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. This includes information in
the form of blueprints, drawings, photographs, plans, instructions, and documentation;
(2) Classified information relating to defense articles and defense services;
(3) Information covered by an invention secrecy order;
(4) Software as defined in § 121.8(f) of this subchapter directly related to defense articles;
(5) This definition does not include information concerning general scientific, mathematical or engineering principles commonly
taught in schools, colleges, and universities or information in the public domain as defined in § 120.11. It also does not include
basic marketing information on function or purpose or general system descriptions of defense articles.
§ 120.9 Defense Service
Defense service means:
(1) The furnishing of assistance (including training) to foreign persons, whether in the United States or abroad in the design,
development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation,
demilitarization, destruction, processing, or use of defense articles;
(2) The furnishing to foreign persons of any technical data controlled under this subchapter (see § 120.10), whether in the United
States or abroad; or
(3) Military training of foreign units and forces, regular and irregular, including formal or informal instruction of foreign persons in the
United States or abroad or by correspondence courses, technical, educational, or information publications and media of all kinds,
training aid, orientation, training exercise, and military advice.
(a)
§ 120.6 Defense Article
Defense article is any item or technical data that is specifically designed, developed, configured adapted, or modified for a military or
intelligence applicability (120.3(b)). A defense article could be a firearm, ammunition, tank or military vehicle, warship, launch vehicle,
spacecraft systems, explosives, military training equipment, protective personnel equipment and shelters, military electronics, optical
guidance and control equipment, toxicological agents, nuclear weapons, directed energy weapons, Defense Services or Tech Data (121.1)
It does not include basic marketing information on function or purpose or general system descriptions.
§ 120.3 Policy on Designating and Determining Defense Articles and Services
An article or service may be designated or determined in the future to be a defense article (see § 120.6) or defense service (see § 120.9) if
it:
(a) Is specifically designed, developed, configured, adapted, or modified for a military application, and
(1) Does not have predominant civil applications, and
(2) Does not have performance equivalent (defined by form, fit, and function) to those of an article or service used for civil
applications; or
(b) Is specifically designed, developed, configured, adapted, or modified for a military application, and has significant military or
intelligence applicability such that control under this subchapter is necessary.
Form-PU-032 (Rev. 03/10)
Previous editions are obsolete.
Page 3 of 4
Use/disclosure of data on this sheet is subject
to the restrictions as stated in P&SP QM 2.1.
The intended use of the article or service after its export (i.e., for a military or civilian purpose) is not relevant in determining whether the
article or service is subject to the controls of this subchapter. Any item covered by the U.S. Munitions List must be within the categories of
the U.S. Munitions List. The scope of the U.S. Munitions List shall be changed only by amendments made pursuant to section 38 of the
Arms Export Control Act (22 U.S.C. 2778).
§ 120.22 Technical Assistance Agreement.
An agreement (e.g., contract) for the performance of a defense service(s) or the disclosure of technical data, as opposed to an agreement
granting a right or license to manufacture defense articles.
Please Note: A Technical Assistance Agreement is not a contract. It is only a technology and data handling agreement. A TAA is between
the US signatory (Exelis Systems Corporation) and the foreign party or parties. A TAA is an authorization from DDTC (Directorate of Defense
Trade Controls) to authorize the release of ITAR controlled technical data to foreign persons. A foreign party or parties has an obligation to
protect all ITAR controlled technical data, hardware, or defense services that flow to them by an agreement and prohibit any use by a third
party that has not been previously authorized in the TAA.
Additional Definitions
Third Country National (TCN) describes individuals of other nationalities hired by a government or government sanctioned contractor who
represent neither the contracting government nor the host country or area of operations.
Host Country Nationals (HCN’s) are those personnel who are local nationals to the area of operations.
Dual Nationals is a citizen of two separate nations or dual nationality
Export Control Marking
The following markings are applicable to technical data that is transmitted. Please note that each marking has its own restrictions on who
can receive the data, and what U.S. Government department can approve the transfer outside the U.S. (U.S. Dept. of State or U.S. Dept. of
Commerce). Exelis Systems Corporation’s technical data which need to be protected will have one of the following Export control
statements. Failure to have the markings does not release the company from any requirement for complying with export regulations:

ITAR Statement: This information is subject to the controls of the International Traffic in Arms Regulations (ITAR). This
information shall not be provided to non-U.S. persons or transferred by any means to any location outside the United States
without advanced written permission from Exelis Systems Corporation and approval from the United States Department of
State. http://www.pmddtc.state.gov

EAR Statement (Applies to all ECCNs including EAR99): This information is subject to the controls of the Export Administration
Regulations (EAR). This information shall not be provided to non-U.S. persons or transferred by any means to any location
outside the United States without advanced written permission from Exelis Systems Corporation and approval from the U.S.
Department of Commerce. http://www.acess.gppo.gov.bis

Non-Export Controlled: This information is not subject to the controls of the International Traffic in Arms Regulations (ITAR) or
the Export Administration Regulations (EAR). However, this information may be restricted from transfer to various embargoed
countries under U.S. laws and regulations.
For Further Definitions go to: www.pmddtc.state.gov/itar
Form-PU-032 (Rev. 03/10)
Previous editions are obsolete.
Page 4 of 4
Use/disclosure of data on this sheet is subject
to the restrictions as stated in P&SP QM 2.1.