Compliance | Ansei Dynamics

§01

Export controls (Canada & cross-border)

Ansei is in the process of registration with the Controlled Goods Program (CGP) administered by Public Services and Procurement Canada under the Defence Production Act for the possession, examination, and transfer of controlled goods. Items not subject to the Controlled Goods regime are evaluated under the Export and Import Permits Act (EIPA) and its Export Control List (ECL), with permits issued by Global Affairs Canada — Trade Controls Bureau. U.S.-origin components and any re-exports are evaluated for applicability of the U.S. International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Foreign-national access to controlled technical data requires a security assessment and is permitted only under appropriate authorization and on a need-to-know basis.

DO NOT TRANSMIT CONTROLLED-GOODS OR ITAR/EAR-CONTROLLED TECHNICAL DATA TO ANSEI WITHOUT A PRE-ESTABLISHED CONTROLLED CHANNEL.

§02

Cybersecurity (CCCS / ITSG-33)

Our information-systems environment is built to the security guidance of the Canadian Centre for Cyber Security (CCCS), including ITSG-33 (IT Security Risk Management — A Lifecycle Approach), and is operated in alignment with the PSPC Contract Security Program (CSP) Document Safeguarding requirements. For cross-border U.S. Department of Defense work, we additionally align with NIST SP 800-171 Rev. 2 and are pursuing CMMC Level 2 assessment per DFARS 252.204-7012. Cyber incidents are reported promptly to CCCS, to affected customers, and — where required by contract — to U.S. Department of Defense reporting portals.

§03

Trade sanctions & restricted-party screening

All counterparties — customers, suppliers, consultants, and visitors requiring controlled access — are screened against Canadian and allied restricted-party lists, including the Consolidated Canadian Autonomous Sanctions List (Global Affairs Canada) under the Special Economic Measures Act (SEMA), the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), the United Nations Act, and the Freezing Assets of Corrupt Foreign Officials Act; and, for cross-border activity, the U.S. OFAC SDN List, the Commerce Entity List and Denied Persons List, and the EU Consolidated List. Transactions involving comprehensively sanctioned jurisdictions are prohibited absent authorization.

§04

Anti-bribery & anti-corruption

Ansei prohibits bribery and corrupt payments in any form. Our program is designed to comply with Canada's Corruption of Foreign Public Officials Act (CFPOA) and the secret-commission and bribery offences of the Criminal Code (s.426); the U.S. Foreign Corrupt Practices Act (FCPA); and the UK Bribery Act 2010. We do not make facilitation payments, and we apply diligence to intermediaries acting on our behalf.

§05

Supply-chain integrity & forced-labour reporting

Procurement of critical materials, electronics, and energetics is governed by source-of-supply controls. We report annually as required by the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211), and we maintain controls aligned with the Customs Tariff prohibition on importation of goods produced by forced labour. For cross-border U.S. defense work, we additionally observe NDAA §889(a)(1)(A)/(B) (prohibition on covered telecommunications equipment) and NDAA §1260H awareness for entities of concern. Suppliers of integrated circuits and energy-storage cells are qualified against counterfeit mitigation requirements (SAE AS5553-aligned).

§06

Conflict minerals

We exercise due diligence on the sourcing of tin, tantalum, tungsten, and gold (3TG) and cobalt in our supply chain, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Smelter-level reporting is requested from in-scope suppliers using the RMI Conflict Minerals Reporting Template (CMRT). For U.S.-listed downstream customers we additionally support disclosure obligations under §1502 of the Dodd-Frank Act.

§07

Personnel security & insider-risk program

Personnel performing on classified or controlled programs are sponsored for clearances (Reliability Status, Secret, or Top Secret) and trained under the PSPC Contract Security Program (CSP) and the Controlled Goods Program (CGP), including the CGP's required Security Assessment and Security Plan. Ansei operates a documented insider-risk program with a designated senior official, aligned with CCCS guidance.

§08

Quality & product qualification

Engineering and production processes are being developed against AS9100D / ISO 9001:2015 for aerospace and defence. Energy-storage hardware qualification follows applicable MIL-STD-810H (environmental engineering), MIL-STD-461G (EMI/EMC), and the UN Manual of Tests and Criteria, Section 38.3 (lithium-battery transportation) requirements, with transportation of dangerous goods in Canada governed by the Transportation of Dangerous Goods Act and its Regulations (TDGR).

§09

Equal opportunity & employment equity

Ansei is an equal opportunity employer and recruits without regard to grounds protected by the Canadian Human Rights Act, the Charter of human rights and freedoms (Quebec), and applicable provincial human-rights codes. As a federally regulated supplier under federal-contract programs, Ansei intends to maintain an employment-equity program consistent with the Employment Equity Act and the Federal Contractors Program (FCP), and a pay-equity plan under the Pay Equity Act and Quebec's Pay Equity Act (LSST).

§10

Environmental, health & safety

We operate in compliance with applicable federal and Quebec EHS requirements, including the Act respecting occupational health and safety (LSST) administered by the Commission des normes, de l'équité, de la santé et de la sécurité du travail (CNESST); WHMIS 2015 under the federal Hazardous Products Act; the Environment Quality Act (Quebec); and the Transportation of Dangerous Goods Act. High-energy testing is conducted only in designated facilities with documented procedures and trained personnel.

§11

Reporting concerns

Suspected violations of law, contract, or Ansei policy — including export-control, fraud, or cybersecurity matters — may be reported, anonymously where permitted, to ethics@anseidynamics.com. Reports may also be made externally to Quebec's Protecteur du citoyen under the Act to facilitate the disclosure of wrongdoings relating to public bodies, where applicable. Ansei prohibits reprisal against any individual making a good-faith report.

§12

Government inquiries

Lawful inquiries from federal or provincial authorities — including Global Affairs Canada (Trade Controls Bureau), PSPC (Industrial Security Sector / Controlled Goods Directorate), CSIS, the RCMP, and contracting officers of the Department of National Defence (DND) — should be directed to compliance@anseidynamics.com for routing to the appropriate program counsel.

Compliance Posture.