Thank you very much for your request and the opportunity to comment.

Due to a media publication in the German "Behörden Spiegel" from 1 August 2023, we became aware on 3 August 2023 about an analysis on this topic, which had been published by Stanford University on 9 July 2023.

The authors of the analysis you mentioned are the same ones, and both analyses are based on the same data source.

We took the report very seriously and immediately reviewed internally the information it contained.

According to pages 5 and 14 to 16, the above-mentioned analysis refers to a large number of different product groups (i.e., not exclusively to weapons), including small electronic devices (pages 11-13). According to the authors, around one third of the customs tariff numbers described in the report are classified as "critical" components, while the rest, which also applies to our product, are of a purely civilian use.

It was mentioned in the report that an ebm-papst compact fan (ebm-papst standard product 8414 NML) had not been found in a weapon, but in a radio transmitter (radio unit). Electronic components such as compact fans can be used in many different ways, e.g. for cooling electronics. We expressly do not design our products for military purposes or for dual use.

Below please find a copy from the report concerning the product:

Source: https://sanctions.nazk.gov.ua/en/military-components/602/

The goal of our internal analysis was to exclude indirect connections as far as possible. After our internal review, we were able to rule out a direct connection. We have a great interest in ensuring that our products are not used for military purposes in Russia or anywhere else under any circumstances.

We strictly adhere to the existing sanctions; our export controls go far beyond the legally specified requirements; and all projects with any indications of a possible sensitive use are strictly checked on a case-by-case basis.

Furthermore, we condemn the Russian government's war of aggression and completely stopped business with Russia in June 2022. We were one of the first Western companies to sell our two former Russian subsidiaries to the local management at that time. Immediately after the start of the war, we stopped all deliveries from Germany or other ebm-papst subsidiaries to Russia. Even transports that went through Russia, such as goods shipments by rail from Germany via Russia to China, were stopped.