EXP-01 Export Control and ITAR Awareness

Revision 3 · Effective 2025-12-01

1 Purpose

Tallgrass manufactures defense articles for defense customers, and some of our drawings, models and parts are controlled under the International Traffic in Arms Regulations (ITAR). This document explains what every employee and contractor must do to keep that data and hardware under control.

This is awareness guidance, not a complete statement of the regulations. When in doubt, stop and contact the Empowered Official (EO), Gail Thornton, at exportcompliance@tallgrasspc.com before acting.

2 Scope

Applies to all employees and contractors at the Wichita plant and the Overland Park sales office, and to all ITAR-controlled jobs, technical data, hardware, visitors and shipments.

3 Definitions

Technical data: drawings, models, specifications, CMM and NC programs, process sheets and other information needed to make a defense article.
Export: sending or taking a controlled item or technical data out of the United States, or releasing technical data to a foreign person anywhere, including inside our own building (a "deemed export").
U.S. person: a U.S. citizen, lawful permanent resident, or protected individual. Status is verified by HR.
Empowered Official (EO): the person authorized to sign export license applications and approve exports on behalf of Tallgrass.

4 Responsibilities

Empowered Official: approves exports and foreign-national visits, performs restricted-party screening, investigates suspected violations, maintains export records.
HR Manager: verifies U.S. person status and provides the list of verified U.S. persons to the EO and IT.
IT Lead: restricts the "ITAR Programs" SharePoint site to verified U.S. persons approved by the EO.
Every employee and contractor: follows section 5 and reports concerns immediately.

5 Requirements

5.1 Identifying ITAR jobs

ITAR-controlled jobs are flagged "ITAR" on the traveler and in the ERP. Contracts sets the flag at order entry based on the customer PO and drawing markings.
If a drawing or PO is marked as export-controlled but the job is not flagged, stop and contact the EO.

5.2 Handling ITAR technical data

ITAR drawings and models live only in the restricted "ITAR Programs" SharePoint site. Access is limited to U.S. persons verified by HR.
ITAR data is classified Restricted under IT-05 and carries the Restricted sensitivity label.
Never save ITAR data to local drives, USB media, personal cloud storage or other SharePoint sites.
Never send ITAR data to personal email or enter it into any AI tool, including Microsoft 365 Copilot (IT-05).
Printed ITAR drawings stay at the workstation during the shift and are returned to the controlled drawing cabinet at end of shift.

5.3 Visitors and foreign persons

Visits by foreign nationals require EO approval at least 5 business days before the visit. Send the visitor's name, citizenship, employer and purpose to exportcompliance@tallgrasspc.com.
Approved foreign-national visitors are escorted at all times and are not shown ITAR jobs, drawings or hardware unless the EO has confirmed an authorization.
Do not discuss ITAR job details with anyone who has not been confirmed as a U.S. person with a need to know.

5.4 Restricted-party screening

The EO screens every new customer and new supplier against U.S. government restricted-party lists before the first order or purchase order is placed. Purchasing and Sales do not release a first order until screening is recorded as cleared.

5.5 Exports and international shipments

Every export or international shipment needs EO review before it leaves the building. Shipping completes SHP-02 for each export shipment. This also applies to hand-carrying parts or laptops containing technical data on international travel.

5.6 Reporting suspected violations

Report any suspected violation, such as a misdirected email, an unescorted visitor near ITAR work, or data found in the wrong location, to the EO immediately. Do not try to investigate or correct it yourself. Reports can be made in person, by phone, or to exportcompliance@tallgrasspc.com. Retaliation against anyone who reports in good faith is prohibited.

6 Training

ITAR awareness training is required annually for all employees and contractors, and must be completed before a new employee or contractor works on any ITAR-flagged job. Training is recorded per QP-6.2.

7 Records

Export records (licenses, EEI filings, commercial invoices, screening results, EO approvals) are retained 5 years from the date of export in the "Export Records" library. Visitor approvals and violation reports are retained by the EO for the same period.

8 Revision history

Rev	Date	Change	Approved by
1	2021-02-15	Initial release	Margaret Lindqvist
2	2023-05-01	Added "ITAR Programs" SharePoint site and U.S. person verification by HR	Margaret Lindqvist
3	2025-12-01	Added prohibition on sending ITAR data to any AI tool; visitor approval 5 business days ahead; reference to SHP-02	Margaret Lindqvist