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1. Ensure Timely Filings. Establish clear protocols and automated alert mechanisms so that all visa petitions, extensions, amendments, and transfers are filed within the applicable regulatory windows, thereby maintaining uninterrupted, lawful employment authorization for each foreign national employee.

2. Mitigate Risk of Status Lapses and Unauthorized Employment. Prevent any circumstance in which a foreign national employee continues working for OWS without valid employment authorization, which would expose both the employee and the Company to serious legal consequences, including but not limited to monetary penalties, debarment from future visa sponsorship, and potential criminal liability.

3. Support Regulatory Compliance. Ensure that OWS meets all obligations imposed by the United States Citizenship and Immigration Services ("USCIS"), the U.S. Department of Labor ("DOL"), the U.S. Department of State ("DOS"), and other relevant federal agencies with respect to the employment of foreign national workers, including compliance with the Immigration and Nationality Act ("INA"), applicable regulations codif

4. Provide Structured Reporting. Create a framework for regular, structured reporting to OWS management—including the General Counsel, the Director of Human Resources, and the Chief Executive Officer—as well as to outside immigration counsel, Calderwood & Harkness LLP, to ensure transparency and accountability in the immigration program.

5. Facilitate Strategic Workforce Planning. By maintaining accurate and up-to-date immigration status information, enable OWS to make informed hiring and retention decisions, plan for future visa sponsorship needs, and evaluate alternative immigration pathways where appropriate.

6. Preserve the Company's Reputation and Operational Continuity. Protect OWS's ability to retain key engineering and scientific personnel whose work is essential to the Company's competitive position in photonic integrated circuit ("PIC") technology and related semiconductor markets, and to satisfy any inquiries from investors, customers, or government agencies regarding the Company's immigration compliance posture.

1. Primary Point of Contact. Serve as the primary internal point of contact for all matters relating to the immigration status of OWS's foreign national employees and pipeline candidates. All inquiries, notifications, and communications regarding immigration status—whether from employees, hiring managers, or external parties—shall be directed to the Immigration Program Manager in the first instance.

2. Database Maintenance. Establish and maintain the master Immigration Status Tracking Database as described in Section 5 of this Policy. The Immigration Program Manager is responsible for ensuring that the database is accurate, current, and complete at all times, and that all required data fields are populated for each beneficiary.

3. Deadline Monitoring and Alert Generation. Monitor all visa expiry dates, filing deadlines, and processing milestones for each beneficiary in accordance with the alert schedule set forth in Section 6.1 of this Policy. The Immigration Program Manager shall generate and distribute automated alerts to the relevant stakeholders at each trigger point and shall personally verify that appropriate action has been initiated

4. Coordination with Outside Counsel. Serve as the primary operational liaison to Calderwood & Harkness LLP for day-to-day immigration matters. The Immigration Program Manager's primary contacts at Calderwood & Harkness are Megan Chu, Lead Associate, and Tanya Benavides, Paralegal. The Immigration Program Manager shall transmit all petition-related documents, employee information, and supporting evidence to outside c

5. Receipt and Logging of Government Correspondence. Receive, log, and distribute all USCIS receipt notices (Form I-797C), approval notices (Form I-797A), RFEs, Notices of Intent to Deny ("NOIDs"), denial notices, and any other government correspondence relating to OWS-sponsored immigration cases. Copies of all such correspondence shall be provided to Calderwood & Harkness LLP within two (2) business days of receipt.

6. Initiation of Extension and Amendment Processes. Initiate extension, amendment, and transfer petition processes in coordination with outside counsel within the required filing windows established by this Policy. The Immigration Program Manager shall not wait for automated alerts alone but shall proactively review upcoming deadlines on a monthly basis.

7. Quarterly Reporting. Prepare and distribute quarterly status reports to OWS management in the format and with the content specified in Section 9 of this Policy.

8. FDNS Site Visit Response. Serve as the first point of contact for FDNS site visit notifications, in coordination with Samantha Kowalski, Director of Human Resources. Upon learning of a scheduled or unannounced site visit, the Immigration Program Manager shall immediately notify Calderwood & Harkness LLP and implement the Company's FDNS Site Visit Preparedness Guide & Protocol. 3.2 Director of Human Resources — Sam

1. I-9 Compliance and E-Verify. Oversee the completion, verification, and retention of Form I-9 (Employment Eligibility Verification) for all new hires, including visa-dependent employees, in coordination with Sentinel Background Verification Corp. (Account Lead: Tyler Ng). Ensure that all I-9 forms are completed within three (3) business days of the employee's start date, as required by 8 C.F.R. § 274a.2(b)(1)(ii).

2. Notification of Personnel Changes. Notify the Immigration Program Manager of all new hires, terminations, resignations, and leaves of absence involving visa-dependent employees within one (1) business day of the event or, in the case of new hires, as soon as an offer has been accepted and a start date confirmed. This notification obligation extends to all voluntary and involuntary separations, regardless of the ci

3. FDNS Site Visit Coordination. Serve as the primary designated contact for FDNS site visits at all OWS worksites. In the event of an unannounced site visit, the Director of Human Resources shall greet the FDNS officer, verify identification, and facilitate the visit in accordance with the Company's FDNS Site Visit Preparedness Guide & Protocol. The secondary contact for FDNS visits is Rajesh Anand, Immigration Prog

4. Worksite Change Approvals. Approve all worksite change requests for visa-dependent employees and route such requests to the Immigration Program Manager and outside counsel for LCA amendment evaluation before the change takes effect.

5. Training and Awareness. Ensure that all hiring managers and supervisors with responsibility for visa-dependent employees receive annual immigration compliance training as described in Section 11.1 of this Policy. 3.3 VP of Engineering — Dr. Yun-Sheng Chen As the senior technical leader responsible for OWS's engineering workforce, the VP of Engineering plays a critical role in supporting the immigration program. Dr

1. Hiring Manager Attestations. Provide hiring manager attestations, technical support letters, expert opinion letters, and other documentation required for visa petition filings, including detailed descriptions of the beneficiary's job duties, the specialty nature of the position, and the beneficiary's qualifications.

2. Notification of Material Changes. Promptly notify the Immigration Program Manager and the Director of Human Resources of any proposed or actual changes to the job duties, reporting structure, worksite assignment, or compensation of any visa-dependent employee. Such notification must occur before the change takes effect to allow for evaluation of whether an amended or new visa petition is required.

3. Pipeline Identification. Identify prospective pipeline candidates for future visa sponsorship and communicate anticipated hiring plans to the Immigration Program Manager and Director of Human Resources with sufficient advance notice to permit timely initiation of the visa sponsorship process.

4. Technical Expertise. Serve as a resource for outside counsel in preparing petition materials that require detailed technical descriptions of OWS's products, technology, and the specialized nature of the roles performed by visa-dependent employees. 3.4 General Counsel — Patricia Langford The General Counsel provides overall legal oversight of the immigration program and serves as the senior legal authority within O

1. Legal Oversight. Provide overall legal oversight of the Company's immigration program, including review of compliance audit findings, escalated matters, and any issues that present significant legal risk to the Company.

2. Primary Client Contact for Outside Counsel. Serve as the primary client contact for Calderwood & Harkness LLP under Engagement Reference SC-OWS-2025-0520-IMM. All matters requiring strategic legal judgment, significant financial expenditure, or involvement of senior management shall be escalated to the General Counsel.

3. Policy Governance. Review and approve all updates, amendments, and revisions to this Policy and related immigration compliance procedures. No material change to this Policy shall take effect without the written approval of the General Counsel.

4. Investor and Board Liaison. As necessary and appropriate, serve as the liaison to Crestline Ventures Fund IV, LP—the majority shareholder of OWS, holding 62.4% equity, with Managing Partner Howard Driscoll—on immigration program matters that may be of interest or concern to the Company's investors or board of directors, including matters relating to compliance risk, regulatory developments, or the retention of key

5. Emergency Escalation. Receive and act upon emergency escalation alerts as described in Section 6.1 of this Policy, particularly in circumstances where a beneficiary's authorized period of stay is within thirty (30) days of expiration and no extension or change of status petition has been filed. 3.5 Outside Immigration Counsel — Calderwood & Harkness LLP Calderwood & Harkness LLP serves as OWS's outside immigration

1. Petition Preparation and Filing. Prepare and file all visa petitions (Forms I-129, I-140), LCAs (Form ETA-9035), PERM labor certifications (Form ETA-9089), and related government correspondence on behalf of OWS, in accordance with the deadlines and filing strategies established in coordination with the Immigration Program Manager and General Counsel.

2. Compliance Advisory. Advise OWS on filing strategies, compliance best practices, and regulatory changes affecting the Company's immigration program. This includes monitoring USCIS policy memoranda, DOL guidance, federal register notices, and relevant judicial and administrative decisions.

3. Quarterly Status Reports. Prepare and deliver quarterly written status reports to OWS in the format and with the content specified in Section 9.1 of this Policy.

4. Processing Time Monitoring. Monitor USCIS processing times at applicable service centers and advise OWS on the advisability of premium processing (Form I-907) where available and strategically appropriate.

5. Government Fee Tracking. Monitor changes to USCIS filing fees, DOL processing fees, and other government charges, and provide advance notice to OWS of any fee increases that may affect the Company's immigration budget.

6. RFE and NOID Response. Prepare and file responses to RFEs, NOIDs, and other government inquiries on pending petitions within the applicable deadlines.

7. PAF Maintenance Support. Assist OWS in maintaining compliant PAFs at each worksite, including preparation of PAF-required documentation in connection with each LCA filing. 3.6 Individual Beneficiaries (Foreign National Employees) Each foreign national employee of OWS whose employment authorization is visa-dependent bears personal responsibility for cooperating with the Company's immigration program and for maintai

1. Prompt Notification of Changes. Promptly notify the Immigration Program Manager of any changes in personal circumstances that may affect immigration status, including but not limited to marriage, divorce, birth or adoption of a child, change of residential address, international travel plans, receipt of visa approvals or denials from other petitioners, and any communication received directly from USCIS, DOL, or th

2. Travel Document Maintenance. Maintain valid travel documents at all times, including a passport with a validity period of at least six (6) months beyond the end of the beneficiary's current authorized period of stay.

3. Cooperation with Information Requests. Cooperate fully and promptly with all information requests and documentation needs arising from petition preparation, extension filings, and RFE responses. Delays in providing requested information may jeopardize the timely filing of petitions and may result in a lapse of employment authorization.

4. Compliance with Petition Terms. Refrain from engaging in any unauthorized employment or any employment outside the terms and conditions of the approved petition, including but not limited to secondary employment, freelance work, consulting engagements, or self-employment, unless specifically authorized under the terms of the beneficiary's visa classification and approved by OWS.

5. Acknowledgment. Each beneficiary shall acknowledge receipt and understanding of this Policy in writing. A copy of the signed acknowledgment shall be retained in the beneficiary's immigration file. SECTION 4: IMMIGRATION CLASSIFICATION CATEGORIES TRACKED This Section identifies all current visa holders, pipeline candidates, and pending green card cases tracked under this Policy. The information set forth below refl

1. Dr. Ankit Mehrotra • Position: Senior Photonics Engineer • SOC Code: 17-2199 (Engineers, All Other) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: September 1, 2023 – August 31, 2026 • PERM Status: Filed; Priority Date March 15, 2024 (EB-2) • Notes: Third-year extension; PERM case pending at DOL; I-140 not yet filed

2. Wei-Lin Tsai • Position: RF Design Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Initial • Validity Period: October 1, 2024 – September 30, 2027 • PERM Status: None • Notes: First H-1B approval; three-year validity; no green card process initiated

3. Sunita Raghavan • Position: Process Integration Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Transfer (from prior employer) • Validity Period: January 15, 2024 – January 14, 2027 • PERM Status: Filed; Priority Date June 1, 2024 (EB-2) • Notes: Transfer approved; AC21 portability invoked at time of transfer; PERM recruitment completed

4. Jae-Won Park • Position: Analog IC Designer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: April 1, 2023 – March 31, 2026 • PERM Status: Filed; Priority Date November 20, 2023 (EB-2) • Notes: Approaching end of initial three-year period; extension filing window opens September 2025; monitor PERM case status for seventh-ye

5. Oleksandr Kovalenko • Position: FPGA Verification Engineer • SOC Code: 15-1252 (Software Developers) • Worksite: Site A — San Jose, CA • Petition Type: Initial • Validity Period: October 1, 2024 – September 30, 2027 • PERM Status: None • Notes: First H-1B approval; Ukrainian national; no green card process initiated

6. Maria Fernanda Salinas • Position: Embedded Systems Engineer • SOC Code: 15-1252 (Software Developers) • Worksite: Site B — Austin, TX • Petition Type: Transfer (from prior employer) • Validity Period: July 1, 2024 – June 30, 2027 • PERM Status: None • Notes: Transfer approved; LCA certified for Austin MSA; Mexican national

7. Takeshi Nakamura • Position: Signal Integrity Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: June 1, 2022 – May 31, 2025 • I-94 Status: Expired May 31, 2025 • Extension Status: Extension petition filed March 15, 2025 by prior counsel (Whitfield & Parekh LLP); pending receipt; 240-day automatic extension rule appl

8. Priya Venkataraman • Position: Packaging Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site C — Portland, OR • Petition Type: Initial • Validity Period: October 1, 2024 – September 30, 2027 • PERM Status: None • Notes: Only H-1B worker at Portland site; LCA certified for Portland MSA

9. Dmitri Volkov • Position: Test Automation Engineer • SOC Code: 15-1252 (Software Developers) • Worksite: Site A — San Jose, CA • Petition Type: Transfer (from prior employer) • Validity Period: March 15, 2025 – March 14, 2028 • PERM Status: None • Notes: Recently approved transfer; Russian national; previously employed by Granville Staffing Solutions, Inc.; prior petition records maintained in beneficiary file

10. Hyun-Soo Kim • Position: Layout Design Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: November 1, 2023 – October 31, 2026 • PERM Status: Filed; Priority Date February 28, 2024 (EB-3) • Notes: EB-3 classification (Level II position at time of PERM filing); monitor visa bulletin for EB-3 worldwide priority date ad

11. Rania El-Masri • Position: Systems Architect • SOC Code: 15-1211 (Computer Systems Analysts) • Worksite: Site B — Austin, TX • Petition Type: Initial • Validity Period: October 1, 2024 – September 30, 2027 • PERM Status: None • Notes: First H-1B approval; LCA certified for Austin MSA; Lebanese national

12. Chen Xiaoming • Position: Reliability Engineer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: August 15, 2023 – August 14, 2025 • Critical Note: Extension must be filed by June 15, 2025 (180-day advance filing window); approaching end of second three-year period • PERM Status: Filed; Priority Date April 5, 2024 (EB-2) •

13. Fatima Al-Rashidi • Position: DevOps / CI-CD Engineer • SOC Code: 15-1252 (Software Developers) • Worksite: Site A — San Jose, CA • Petition Type: Initial • Validity Period: October 1, 2024 – September 30, 2027 • PERM Status: None • Notes: First H-1B approval; Saudi Arabian national; no green card process initiated

14. Arjun Krishnamurthy • Position: Power Management IC Designer • SOC Code: 17-2072 (Electronics Engineers, Except Computer) • Worksite: Site A — San Jose, CA • Petition Type: Extension • Validity Period: December 1, 2022 – November 30, 2025 • PERM Status: Filed; Priority Date July 22, 2023 (EB-2); PERM audit pending from prior counsel (Whitfield & Parekh LLP) • Notes: Extension filing should target no later than Ju

15. Dr. Seo-Yeon Cho • Position: Principal Photonics Researcher • Classification: O-1A (Extraordinary Ability — Sciences) • Worksite: Site A — San Jose, CA • Validity Period: March 1, 2024 – February 28, 2026 • Notes: O-1A extension will be required; extension filing should begin no later than August 2025; beneficiary has 47 peer-reviewed publications and 8 issued U.S. patents in silicon photonics; South Korean natio

16. Dr. Vikram Iyer • Position: Chief Architect, PIC Platform • Classification: O-1A (Extraordinary Ability — Sciences) • Worksite: Site A — San Jose, CA • Validity Period: May 15, 2023 – May 14, 2026 • Notes: Senior technical leader; extension filing should begin no later than November 2025; beneficiary has extensive publication record and has served as keynote speaker at IEEE Photonics Conference; Indian national

17. Dr. Amara Osei-Bonsu • Position: Lead Quantum Photonics Scientist • Classification: O-1A (Extraordinary Ability — Sciences) • Worksite: Site A — San Jose, CA • Validity Period: September 1, 2024 – August 31, 2027 • Notes: Recently approved; Ghanaian national; no extension needed within current planning horizon 4.3 O-1B Extraordinary Achievement in Arts (1 Current Holder) OWS currently employs one (1) individual i

18. Luciana Moretti • Position: Senior UX/Industrial Designer • Classification: O-1B (Extraordinary Achievement — Arts) • Worksite: Site A — San Jose, CA • Validity Period: January 15, 2025 – January 14, 2028 • Notes: Recently approved petition; Italian national; responsible for the industrial design of OWS's photonic transceiver product line; recipient of multiple international design awards, including the Red Dot D

1. Full legal name (as it appears on the beneficiary's passport) and any prior names (maiden name, former names)