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Team, For compliance with the UK embargo on Argentina and sales via Embraer in Brazil for KC-390 please review the following Trade Compliance guidance. This applies as UK Personnel have been involved in the contract and the requirement flows to the USA and applies to any sales made direct/indirectly to Embraer, LMI or their subcontractors that are for end use on the KC-390. We also wanted to notify you that for all sales KC-390 related we now require and have a 100% end user / end use cert (EUC) T:\Trade Compliance\End Use and End User Certification\End Use and End User Certification form.doc . Upon receipt please forward the completed EUC to Trade Compliance for review. Currently we have two subs that we are aware of OGMA and Aciturri and more may be signed up later. Overview: In October 2013 our US regs. changed under US Export Control Reform and no longer align with the UK regs. Basically, when their parts or data are transferred to us they are treated as military under the UK regulations and are marked as such. Under our US regulations we have reclassified the parts and technology under our jurisdiction to the (EAR) Export Administration Regulations, to ECCN (Export Commodity Classification Number) 9A991.d for the parts and 9E991 for the related technology. When we send data out of here we mark it according to our jurisdiction. This applies to current and any new or redesigned parts which are reviewed on a part by part basis when they are set up. • For data transfers made by MPCO- our local site Tech Data Release (TDR) form must be used as long as there are no confirmed End User/End User in Argentina. At the time of sale/transfer we can proceed in most cases, unless a license requirement is identified. o We are seeing some interesting requests ~ as a reminder when making data transfers make sure you know who the parties are according to our contracts and what our deliverables are (e.g. we sold to Embraer but get a request from OGMA, then we’d want to flow data to Embraer and have them transfer it to their customer OGMA). The TDR would list both Embraer and OGMA in both countries. • Visits to MPCO – our site visit form must be used and completed in advance of the visit, we’ll screen and evaluate any exchanges/transfer of data. • For hardware shipments we can ship to Embraer in Brazil and OGMA and Aciturri in Portugal and Spain, as long as there are no End User/End User in Argentina at the time of sale and they pass screening at the time of export. o If at any time, even after the sale (e.g. in a conf. call or email) we learn there is a confirmed Argentinean connection involving our parts then contact Trade Compliance. I’ve received some questions about what can/cannot be done from engineering, I’ve received the following summary from my TCO counterpart at Loughborough on the status of the KC390 UK export licenses. OIEL – (Open Individual Export License) used for physical shipment of parts: • Valid until 2020 or until a contract is signed with Argentina • Annual EUU on file for Embraer S.A – expired April 2017, MPCL requested the renewal we’re waiting confirmation of their, new shipments will be held if the original copy of the renewal EUU is not provided on time • Amendment request submitting to UK ECO on 28/03/17 to include Portugal & Spain as consignee destinations: o OGMA are yet to provide an annual EUU undertaking to support this. o Aciturri have provided an EUU o If the amendment is approved we will need original copies of EUU before shipping to OGMA or Aciturri, if it is not approved we will have 4 week license application processing times OGEL –(Open General Export License) Used for technology: • Still able to be utilized for transfers between MPCL & MPCO for technology relating to the KC390 • No expiration , however should a contract with Argentina be signed we should not make any technology transfers without consulting Trade Compliance SITCL – (Standard Individual Trade Control License) for novation of parts from MPCL to MPCO: • Expired following initial transfer of parts from MPCL to MPCO • Required for the transfer of manufacturing parts from MPCL to MPCO • May be required if new designs are created by MPCL with the intention to transfer to MPCO • Due to UK nationals managing both UK & US sites/departments if there is a requirement for novating any of the existing MPCL manufactured parts please alert Trade Compliance immediately to ensure we can review if additional UK licenses are required. Purchased items/materials for KC-390: • Will review on case by case. Please call or email me directly with any questions.

INTO JAPANESE

KC 390 のアルゼンチンとブラジルのエンブラエルを介して販売英国禁輸措置の遵守のためのチームは、次の貿易規則の順守ガイダンスを確認してください。英国担当者が契約に関与するいると米国に流れるし、エンブラエル、LMI または下請け業者が直接/間接的に行われる任意の販売に適用される要件に該当します。