Compliance Notice

1. Anti-Bribery & Anti-Corruption Policy

Total Drilling Supply has a zero-tolerance policy for bribery and corruption in all forms. We do not offer, pay, promise, or authorize any bribe, kickback, facilitation payment, or improper benefit to any person — whether a government official, state-owned enterprise employee, or private party — in connection with any business transaction.

This policy applies to:

• All Total Drilling Supply employees, officers, and principals
• All agents, intermediaries, and consultants acting on our behalf
• All counterparties to transactions facilitated by Total Drilling Supply
• All jurisdictions in which we operate, without exception

We do not make charitable donations, political contributions, or hospitality payments in circumstances that could be construed as seeking an improper business advantage.

2. US Foreign Corrupt Practices Act (FCPA)

Total Drilling Supply is subject to the US Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1, et seq. The FCPA prohibits US persons and companies, as well as foreign companies listed on US exchanges, from paying or offering anything of value to foreign government officials for the purpose of obtaining or retaining business.

Our FCPA commitments include:

• No payments of any kind to foreign government officials, their family members, or associated entities for business advantage
• Accurate books and records that fairly reflect all transactions
• Internal controls sufficient to provide reasonable assurance of FCPA compliance
• Screening of third-party agents and intermediaries for FCPA risk before engagement

Given our operations in regions including the Middle East, Latin America, and Asia-Pacific, where oilfield equipment transactions frequently involve government-owned energy companies, FCPA compliance is a core business requirement.

3. UK Bribery Act 2010

To the extent our activities have a UK nexus, Total Drilling Supply complies with the UK Bribery Act 2010. The Bribery Act applies to conduct by persons who carry on business in the UK and has broader scope than the FCPA, including:

• Prohibition on bribing another person (Section 1)
• Prohibition on being bribed (Section 2)
• Prohibition on bribing foreign public officials (Section 6)
• Corporate liability for failure to prevent bribery (Section 7) — we maintain adequate procedures to prevent associated persons from bribing on our behalf

Unlike the FCPA, the UK Bribery Act does not permit facilitation payments. We do not make facilitation payments under any circumstances.

4. Sanctions & Export Controls

OFAC Sanctions

Total Drilling Supply complies with economic and trade sanctions administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC). We do not engage in transactions with:

• Individuals or entities on the OFAC Specially Designated Nationals and Blocked Persons (SDN) List
• Countries or regions subject to comprehensive US sanctions programs
• Entities owned 50% or more by SDN-listed parties

We screen all counterparties against OFAC sanctions lists before entering into transactions. Prohibited transactions include the sale, lease, or transfer of oilfield equipment to sanctioned persons or territories.

US Export Controls

The export, re-export, or transfer of oilfield equipment and technology may be subject to US export controls, including regulations administered by:

• US Department of Commerce — Export Administration Regulations (EAR)
• US Department of State — International Traffic in Arms Regulations (ITAR), where applicable
• US Department of Energy, where applicable

All equipment transactions facilitated by Total Drilling Supply are subject to obtaining any required US export licenses or authorizations before the equipment leaves the United States or is transferred to a foreign national. Buyers are responsible for obtaining any required import permits in their destination country.

Other International Sanctions

We are also mindful of sanctions programs maintained by the European Union, United Kingdom, and United Nations. Where transactions involve parties or jurisdictions subject to these programs, we consult with qualified legal counsel to ensure compliance.

5. Buyer & Counterparty Obligations

All parties entering into transactions facilitated by Total Drilling Supply represent and warrant that they:

• Are not named on any applicable sanctions list (OFAC SDN, EU consolidated list, UN Security Council list, or equivalent)
• Will not use equipment purchased for any purpose prohibited by applicable law, including in sanctioned countries or in support of prohibited end uses
• Have not offered, paid, or authorized any improper payment in connection with the transaction
• Will comply with all applicable export control and import licensing requirements
• Will cooperate with any compliance screening or due diligence requests from Total Drilling Supply

Any breach of these representations is grounds for termination of the transaction without liability to Total Drilling Supply.

6. Due Diligence

Total Drilling Supply conducts risk-based due diligence on counterparties to transactions. This may include:

• Screening against OFAC, EU, and UN sanctions lists
• Verification of ultimate beneficial ownership for corporate buyers and sellers
• Review of end-use certificates and destination country information
• Enhanced due diligence for transactions in higher-risk jurisdictions

We reserve the right to decline any transaction where compliance concerns cannot be adequately resolved, without providing reasons.

7. Reporting Concerns

If you have a concern about a potential violation of anti-bribery, corruption, sanctions, or export control laws in connection with an Total Drilling Supply transaction, or if you have been asked to participate in conduct that may violate these laws, please report it promptly:

This Compliance Notice is provided for informational purposes only and does not constitute legal advice. Parties with specific compliance questions regarding a transaction should consult qualified legal counsel in the relevant jurisdiction(s).