Legal & Compliance

1.1 Regulatory framework:
Alexandria’s activities and the Platform are subject to U.S. export control and sanctions laws, including:

• (a) the International Traffic in Arms Regulations ("ITAR") (22 C.F.R. Parts 120–130), administered by the U.S. Department of State Directorate of Defense Trade Controls ("DDTC");
• (b) the Export Administration Regulations ("EAR") (15 C.F.R. Parts 730–774), administered by the U.S. Department of Commerce Bureau of Industry and Security ("BIS"); and
• (c) economic sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC"), which restrict or prohibit transactions with designated countries, entities, and individuals.

1.2 Access restrictions:
Access to the Platform is restricted to persons who have confirmed their eligibility in accordance with our Terms of Service. Persons located in, or nationals or residents of, any country or region subject to U.S. sanctions are prohibited from accessing the Platform.

1.3 Denied-parties screening:
Alexandria screens users against applicable U.S. government denied-parties and restricted-entity lists, including the OFAC Specially Designated Nationals and Blocked Persons List, the BIS Entity List, Denied Persons List, and Unverified List, and the State Department Debarred Parties List. Access will be denied or terminated where a match is identified. Screening records are retained for a minimum of five (5) years in accordance with applicable recordkeeping requirements.

1.4 User responsibility:
Alexandria’s compliance program does not substitute for users’ own export control and sanctions compliance obligations. Each user is independently responsible for ensuring that its use of the Platform and engagement of Alexandria’s services complies with all applicable export control and sanctions laws. Questions about compliance matters may be directed to legal@alexandria.com.

2.1 Either directly or through third parties, Alexandria may provide government relations and lobbying services as described on the Platform. To the extent those activities constitute “lobbying activities” within the meaning of the Lobbying Disclosure Act of 1995 (“LDA”) (2 U.S.C. §§ 1601 et seq.), Alexandria complies with all applicable federal registration and reporting requirements. Where Alexandria’s government relations activities extend to state legislatures or state executive branch agencies, Alexandria complies with applicable state lobbying registration and disclosure laws. Users seeking information about lobbying activities may contact legal@alexandria.com.

2.2 Scope of lobbying services:
Alexandria’s lobbying services are provided pursuant to a separate written engagement agreement. These services are issue- and client-specific and do not extend to all users of the Platform by virtue of access alone. Alexandria does not represent that its lobbying activities will produce any particular legislative, regulatory, or procurement outcome.

2.3 No improper payments:
Alexandria strictly prohibits the payment, offer, or authorization of anything of value to any government official, employee, or agent for the purpose of influencing any official action, in violation of applicable law. See Section 4 (Anti-Corruption and Ethics) below.

3.1 Not a registered broker-dealer:
Alexandria may introduce clients to capital partners, strategic investors, and financial institutions as part of its capital solutions services. Alexandria is not a broker-dealer registered with the Financial Industry Regulatory Authority ("FINRA") or the U.S. Securities and Exchange Commission ("SEC") under Section 15(b) of the Securities Exchange Act of 1934 (15 U.S.C. § 78o). Nothing on the Platform constitutes an offer or solicitation to buy or sell any security. Users seeking investment advice or securities placement services should engage a licensed broker-dealer or registered investment adviser.

3.2 Not a registered investment adviser:
Alexandria is not a registered investment adviser under the Investment Advisers Act of 1940 (15 U.S.C. § 80b-1 et seq.) and does not provide investment advice as defined under that Act.

3.3 Not a law firm:
Alexandria’s compliance support services (including guidance on export controls, industrial security issues, the Cybersecurity Maturity Model Certification ("CMMC"), the Federal Acquisition Regulation ("FAR"), and related regulatory frameworks) are provided for informational and facilitation purposes only and do not constitute legal advice. Alexandria does not establish an attorney-client relationship with any user. Users should retain qualified legal counsel for specific legal questions.

3.4 Not a licensed financial advisor or accountant:
Nothing on the Platform constitutes financial, tax, or accounting advice. Users should consult qualified financial and tax advisors before making any decisions based on information provided through the Platform.

4.1 FCPA compliance:
Alexandria conducts its business in compliance with the Foreign Corrupt Practices Act ("FCPA") (15 U.S.C. §§ 78dd-1 et seq.) and equivalent anti-bribery and anti-corruption laws of other applicable jurisdictions. Alexandria prohibits:

• (a) the offer, payment, promise, or authorization of any bribe, kickback, or improper payment to any government official, political party, or their representatives in connection with obtaining or retaining business or any improper advantage;
• (b) the offer or receipt of any improper gift, hospitality, or benefit intended to improperly influence a government procurement or contracting decision; and
• (c) any indirect payment through third parties, agents, or intermediaries that would violate the FCPA or applicable local law.

4.2 Conflicts of interest:
Alexandria maintains policies to identify, disclose, and manage conflicts of interest arising from its services. Where Alexandria has or may have a material conflict of interest in connection with a client engagement, it will disclose that conflict to the affected client in writing prior to proceeding. Users who identify a potential conflict of interest are encouraged to raise the matter with legal@alexandria.com.

4.3 Ethics reporting:
Alexandria maintains a confidential reporting mechanism for employees, contractors, and third parties to report concerns about potential violations of applicable law, ethical standards, or Alexandria’s internal policies. Reports may be submitted to legal@alexandria.com. Alexandria prohibits retaliation against any person who makes a good-faith report under this mechanism, consistent with applicable whistleblower protection statutes.

5.1 FAR and DFARS:
To the extent Alexandria performs work under, or in support of, U.S. government contracts or subcontracts, it complies with applicable requirements under the Federal Acquisition Regulation ("FAR") (48 C.F.R. Ch. 1) and the Defense Federal Acquisition Regulation Supplement ("DFARS") (48 C.F.R. Ch. 2). Users engaging Alexandria in connection with U.S. government prime contracts or subcontracts should disclose the applicable contract number and agency to enable Alexandria to assess its compliance obligations.

5.2 Organizational conflicts of interest (OCI):
Where Alexandria’s advisory, facilitation, or lobbying activities could create an unfair competitive advantage or impair its objectivity in connection with a specific government contract opportunity, Alexandria will take appropriate mitigation or avoidance measures and will disclose the conflict to affected clients. Users who have concerns about OCI in connection with an engagement should contact legal@alexandria.com.

5.3 Cybersecurity and CMMC:
Alexandria may advise clients on compliance with the Cybersecurity Maturity Model Certification ("CMMC") framework established under DFARS 252.204-7021 and related regulations. Alexandria’s own information systems that process, store, or transmit Controlled Unclassified Information ("CUI") are managed in accordance with applicable regulatory requirements. The Platform is not designed or authorized for the storage or transmission of CUI.

Foreign ownership, control or influence (“FOCI”) restrictions:

Companies performing U.S. government contracts involving U.S. government classified information are subject to FOCI restrictions. Firms that are majority-owned or controlled by a foreign entity or persons may be ineligible for certain U.S. government contracts awards. Alexandria advises clients to obtain qualified legal counsel regarding their FOCI status prior to submitting proposals.

5.4 CFIUS:
Certain transactions involving Alexandria or its clients may be subject to review by the Committee on Foreign Investment in the United States ("CFIUS") under the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA") (50 U.S.C. § 4565 et seq.). Alexandria does not provide legal opinions on CFIUS jurisdiction or mandatory filing obligations. Users who believe a proposed transaction may be subject to CFIUS review should obtain qualified legal counsel before proceeding.

5.5 Additional compliance frameworks:
Depending on the nature of a specific engagement, users and Alexandria may also be subject to the following regulatory frameworks, among others:

• (a) the Defense Contract Audit Agency ("DCAA") audit requirements applicable to cost-type and certain other government contracts;
• (b) the False Claims Act (31 U.S.C. §§ 3729 et seq.), which imposes civil and criminal liability for knowingly submitting false or fraudulent claims to the U.S. government;
• (c) the Procurement Integrity Act (41 U.S.C. § 2101 et seq.), which restricts the disclosure and receipt of certain procurement-sensitive information; and
• (d) the Truth in Negotiations Act ("TINA") (10 U.S.C. § 3841 et seq.), which requires contractors to submit cost or pricing data and certify its accuracy, currency, and completeness for certain negotiated contracts.

Users are independently responsible for assessing and complying with all applicable regulatory requirements in connection with their own government contracting activities.

6.1 Facilitator role:
Alexandria supports early-stage companies in navigating the Small Business Innovation Research ("SBIR") and Small Business Technology Transfer ("STTR") programs administered by U.S. federal agencies pursuant to the Small Business Innovation Development Act of 1982 (15 U.S.C. § 638). Alexandria acts as a facilitator and advisor; it is not a program agency and does not make SBIR or STTR award decisions.

6.2 Eligibility determinations:
SBIR and STTR eligibility determinations (including assessments of small business status, U.S. ownership, and employment requirements) are made exclusively by the relevant federal program agencies, not by Alexandria. Alexandria’s facilitation services do not constitute a guarantee of eligibility or award.

6.3 Foreign ownership restrictions:
Companies seeking SBIR or STTR awards are subject to foreign ownership, control, or influence ("FOCI") restrictions. Firms that are majority-owned by, or subject to the control of, a foreign entity or foreign government may be ineligible for certain SBIR and STTR awards. Alexandria advises clients to obtain qualified legal counsel regarding their foreign ownership status prior to submitting proposals.

6.4 IP rights:
SBIR and STTR awards carry specific intellectual property protections, including data rights provisions under DFARS 252.227-7018, that govern the government’s rights in technical data and computer software developed under these programs. Users should consult qualified counsel regarding the interaction between SBIR/STTR data rights, any IP licensing arrangements, and their compliance obligations.

7.1 Platform IP:
All content, methodologies, analytical frameworks, reports, databases, and software on or relating to the Platform are the intellectual property of Alexandria or its licensors and are protected under applicable U.S. and international intellectual property law, including copyright, trademark, and trade secret law. The Alexandria name, logo, and branding are trademarks of Alexandria Holdings LLC. Unauthorized use is prohibited.

7.2 User technology:
Alexandria recognizes that users may share proprietary technology concepts, business plans, and other sensitive information in connection with its services. Alexandria maintains confidentiality obligations in respect of such information as set out in its Terms of Service. Users are encouraged to ensure that appropriate protections — such as provisional patent applications and confidentiality agreements — are in place before disclosing proprietary technical information through the Platform or to any third party introduced through the Platform.

7.3 Trade secrets:
Alexandria’s internal processes, intelligence networks, and analytical methodologies constitute trade secrets under the Delaware Uniform Trade Secrets Act (6 Del. C. §§ 2001 et seq.) ("DUTSA"). Any misappropriation of Alexandria’s trade secrets may give rise to injunctive relief, damages, and fee-shifting remedies under DUTSA.

8.1 No endorsement:
The appearance of any third-party company, capital provider, government agency, technology platform, or individual on or through the Platform does not constitute Alexandria’s endorsement, sponsorship, or recommendation of that party. Alexandria makes no representation or warranty regarding the qualifications, reliability, financial condition, or regulatory compliance of any third party introduced through or mentioned on the Platform.

8.2 No guarantee of outcomes:
Alexandria’s facilitation, advisory, and lobbying services involve inherently uncertain processes, including government procurement decisions, investment committee approvals, and legislative outcomes. Alexandria makes no guarantee that any engagement will result in a contract award, capital raise, regulatory approval, placement of personnel, or any other specific outcome.

8.3 Independent contractors:
Third parties introduced through the Platform — including capital partners, compliance consultants, legal counsel, and executive candidates — act independently of Alexandria and are not Alexandria’s agents or employees. Alexandria is not liable for the acts, omissions, representations, or obligations of any such third party.

9.1 Data protection:
Alexandria’s collection, use, and processing of personal data is governed by its Privacy Notice. That notice addresses Alexandria’s obligations under the Delaware Personal Data Privacy Act (6 Del. C. §§ 12D-101 et seq.), the EU General Data Protection Regulation ("GDPR"), UK GDPR, and the Delaware data breach notification law (6 Del. C. §§ 12B-101 et seq.).

9.2 Cybersecurity:
Alexandria maintains technical and organizational security measures to protect the Platform and user data against unauthorized access, disclosure, or destruction. Unauthorized access to Alexandria’s computer systems may constitute a criminal offense under 11 Del. C. § 932 et seq. (Delaware Computer Fraud) and the Computer Fraud and Abuse Act (18 U.S.C. § 1030). Users must not attempt to probe, scan, or penetrate any part of the Platform’s infrastructure.

9.3 Security concerns:
To report a security vulnerability or potential data breach, please contact legal@alexandria.com as promptly as possible. Alexandria will investigate all reports and respond in accordance with its incident response procedures and applicable law.

10.1 Questions or concerns regarding this Legal & Compliance page, or Alexandria’s regulatory compliance posture generally, may be directed to:

Alexandria Holdings LLC
Attn: Legal & Compliance

411 Brazos Street, Suite 209
Austin, TX 78701

Email: legal@alexandria.com
Website: alexandria.com/demo