UNIVERSAL. — %Veer &MSS% NC UWA Guidelines CUBA CUBA GUIDELINES Issuer: Kathlynn L. Self, Director, Corporate Compliance/Audit I. OVERFLIGHT PERMITS, NAVIGATION FEES AND EMERGENCY LANDING PERMITS 3 II. AUTHORIZED PRE-TRIP SUPPORT ACTIVITIES INVOLVING FLIGHTS TO AND FROM CUBA 3 III. AUTHORIZED TRIP SUPPORT SERVICES PURSUANT TO UWA'S TSP AUTHORIZATION FOR U.S. REGISTERED AIRCRAFT 3 IV. DIPLOMATIC FLIGHTS TO OR FROM U.S. AND CUBA 6 V. TRIP SUPPORT FOR UNLICENSED TRIPS TO CUBA AND TRIPS BY NON-U.S. AIRCRAFT OR PERSONS 7 VI. PROHIBITED TRANSACTIONS AND SERVICES 7 VII. DEFINITIONS AND CLARIFICATION OF REGULATIONS: 7 COMPLIANCE SUMMARY UWA complies with all U.S. laws associated with the U.S. embargo on Cuba including the Cuban Assets Control Regulations (CACR) administered by the Office of Foreign Assets Control (OFAC) and the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security, Department of Commerce (BIS). This guideline applies to all of UWA's U.S. employees, subsidiaries, joint venture partners, employees and agents, wherever located. Any trip support services involving flights to or overflights of Cuba must be explicitly approved. BUSINESS CRITICAL: TRIPS INVOLVING CUBA 1. Required Licenses and/or Approvals to be obtained by the customer: (1) Temporary Sojourn License (as defined in the guidelines); (2) Authorization from OFAC for individuals traveling to Cuba; and (3) Signed Cuba Travel Affidavit for each passenger. 2. Authorized Pre-Trip Support Services: Pending delivery of required license and exemption, pre-trip paperwork and filing are authorized. Trip must be put on manual hold and only the Director, Corporate Compliance/Audit, or his/her designee, is authorized to remove it. 3. Authorized Trip Support Services: Once it is determined that a valid temporary sojourn license has been obtained and the travel to Cuba is authorized under the CACR, trip support services can be provided