Letter of Management Commitment to Trade Compliance

International Trade Compliance – Critical to Our Business

Seagate is committed to complying with all applicable U.S. export control and sanction requirements, including the Export Administration Regulations and the Export Control Reform Act of 2018. This commitment is reflected in our policies, including our Code of Conduct and International Trade Compliance Policy.

Seagate expects all employees, contractors, and business partners, including those of Seagate’s subsidiaries and affiliates, to follow U.S. export laws and regulations, no matter where they are located. No Seagate products, technology, or software may be transferred to a prohibited end user or end use without proper approval. This includes foreign-made items derived from U.S. technology that are subject to export controls.

We expect no one to engage in activities that violate U.S. trade laws, including those aimed at controlling end uses related to advanced semiconductors, supercomputing, military applications, nuclear proliferation, missile technology, or chemical and biological weapons.

Non-compliance puts Seagate’s global business at risk and can result in serious consequences, including fines, imprisonment, and termination of employment or business relationships.

We ask our employees and business partners to take this matter seriously and to support us in this effort. Questions about U.S. export and sanction requirements can be directed to Seagate’s International Trade Administration team ([email protected]). Reports of non-compliance may be made in confidence (where allowed by law) to our Ethics Helpline, either online, or by using the toll-free telephone number, both of which are available 24 hours a day, seven days a week. If you’re not sure about the right course of action, please contact our International Trade Administration team for help.

Dave Mosley
CEO and Chair

Gianluca Romano
EVP and CFO

Jim Lee
EVP and CLO