Compliance

Regulatory Compliance & Audit Protocol | Difen Consulting S.L.

Tax ID: CIF B-10676930 | Head Office: Lepant 270, Barcelona, Spain, 08013

I. Regulatory Status and Security Commitment

Difen Consulting S.L. operates under a strict "Zero Risk" policy regarding international trade. Our entity is currently in the final stages of aligning internal protocols for registration with the Special Register of Foreign Trade Operators of Defense and Dual-Use Material (REOCE), under the Ministry of Economy, Trade and Business of Spain.

This transition period reflects our commitment to establishing a compliance structure that not only meets administrative minimums but exceeds the control standards required by the Joint Interministerial Regulatory Board (JIMDDU). Our priority is to act as a legal firewall, ensuring the viability of every operation before its submission to the competent authorities.

II. Comprehensive Due Diligence Protocol

Difen Consulting implements a multi-dimensional Due Diligence process for every partner and technological asset, based on the following pillars:

1. Origin Audit & Component Traceability: We perform exhaustive monitoring of the manufacturer's supply chain to identify critical elements subject to third-country legislation (such as U.S. ITAR/EAR regulations or EU export controls). This preventive analysis avoids diplomatic bottlenecks or administrative seizures during international transit.

2. Counterparty Verification & Business Ethics: We evaluate the corporate solvency and compliance history of our partners, ensuring all transactions align with International Non-Proliferation Treaties and the guidelines of the European Union's Common Position 2008/944/CFSP.

3. Sensitivity Analysis & Classification: We accurately determine the tariff and defense classification of each system, identifying whether the material must be treated as Defense Material (DM) or Dual-Use (DU) products according to Regulation (EU) 2021/821.

III. Documentary Review & Legal Safeguarding

The legal team at Difen Consulting supervises the integrity of all documentation required for export and import, ensuring full legal validity within Spanish territory and broader European markets:

• Validation of End-User Certificates (EUC): We implement a verification protocol for the authenticity of end-user certificates, guaranteeing that the recipient and the declared use are legitimate and auditable by inspection authorities at any time.

• Documentary Harmonization: We adapt technical files and supply contracts to comply with the legal terminology and security requirements demanded in international government tenders.

• Licensing & Authorization Management: We act as the technical-legal liaison with regulatory bodies, managing individual, global, or general transfer licenses depending on the strategic nature of the project.

IV. Protection of Intangible Assets & Confidentiality

Difen Consulting S.L. assumes full responsibility for the protection of sensitive information shared by our partners. All our documentary review processes are shielded by:

• Non-Disclosure Agreements (NDA) under Spanish legislation with jurisdiction in Barcelona.

• Classified Information Management Protocols: We ensure that technical blueprints, operational capabilities, and software specifications are handled under strict digital security measures, limiting access exclusively to personnel accredited for license management.

V. Transparency & Corporate Responsibility

Our commitment is Total Transparency. The meticulous prior review conducted by Difen Consulting drastically reduces administrative processing times and eliminates the risk of sanctions for involuntary non-compliance. We operate with the conviction that a successful export does not end with the sale, but with the correct and legal reception of the material at its final destination.

Our Mission