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I. PURPOSE AND OVERVIEW This FDNS Site Visit Preparedness Guide & Protocol (the "Guide") establishes standardized protocols for Optiwave Semiconductor Corp. ("OWS" or the "Company") to follow in the event of unannounced or scheduled site visits by the U.S. Citizenship and Immigration Services ("USCIS") Fraud Detection and National Security Directorate ("FDNS"). The Guide is intended to ensure that OWS management, hum

II. BACKGROUND ON FDNS SITE VISITS A. What Is FDNS? The Fraud Detection and National Security Directorate ("FDNS") is a directorate within USCIS that is responsible for detecting and combating immigration benefit fraud and identifying threats to national security that may arise through the immigration benefit adjudication process. FDNS was established in 2004 as part of a broader reorganization of fraud prevention fu

III. DESIGNATED SITE VISIT CONTACTS Clear lines of communication and a well-defined chain of responsibility are essential to an effective site visit response. The following individuals are designated as OWS's site visit contacts. Their roles and responsibilities are described below. A. Primary Contact Samantha Kowalski Director of Human Resources Optiwave Semiconductor Corp. 4820 Veltrano Parkway, Suite 300, San Jose

IV. IMMEDIATE RESPONSE PROTOCOL — UPON ARRIVAL OF FDNS INSPECTOR The following step-by-step protocol governs the initial response to the arrival of an FDNS officer at any OWS worksite. All reception, front desk, and security personnel must be trained on this protocol. The protocol is designed to ensure that the Company's response is prompt, professional, and cooperative while preserving OWS's rights and ensuring that

1. Greet the inspector courteously and professionally. The initial greeting sets the tone for the entire visit. The receptionist or front desk representative should greet the officer in a calm, welcoming, and professional manner, consistent with the Company's standard visitor procedures. A confrontational, evasive, or dismissive tone is never appropriate.

2. Request and examine the inspector's government-issued identification. Ask to see the officer's USCIS badge or government photo identification. Carefully note the officer's full name, title (e.g., "Immigration Officer," "Compliance Review Officer," "FDNS Officer"), and badge number. If possible, write this information down. Do not attempt to photocopy the officer's credentials without permission, but recording the

3. Request a business card if available. Many FDNS officers carry business cards. If a card is offered, retain it and provide it to the designated contact. If no card is available, ensure that the officer's name and contact information are recorded accurately.

4. Ask the purpose of the visit and which beneficiary or petition the visit concerns. Politely ask the officer to identify the purpose of the visit and, if applicable, the name of the beneficiary or the petition receipt number that is the subject of the visit. The inspector may or may not provide this information in advance; some officers will state the purpose immediately, while others may prefer to discuss details

5. Do NOT refuse entry or act uncooperatively. Under no circumstances should reception or front desk personnel refuse to allow the FDNS officer to enter the facility, ask the officer to leave, or otherwise act in an obstructive or uncooperative manner. Refusal to cooperate with an FDNS site visit can result in adverse consequences for pending and approved petitions, and may be viewed as an indicator of fraud or nonco

6. Immediately notify the designated primary contact. Contact Samantha Kowalski (Director of Human Resources) without delay. If Ms. Kowalski is unavailable, contact Rajesh Anand (Immigration Program Manager) as the secondary contact. At Site B (Austin) or Site C (Portland), the site-specific alternate should be contacted first and should then immediately notify Ms. Kowalski and Mr. Anand. Use the phone numbers provid

7. Ask the inspector to wait briefly in a professional reception or conference area. It is acceptable to ask the inspector to wait in the reception area, a visitor lobby, or a conference room for a brief period — generally no more than five to ten minutes — while the designated contact is notified and arrives. Offer the officer a seat and a comfortable waiting environment. Do not leave the inspector unattended for an

8. Log the visit in the reception visitor log. Record the following information in the facility's standard visitor log: the date of the visit, the time of arrival, the inspector's name, and the agency (USCIS / FDNS). This information will be used in the post-visit documentation procedures described in Section IX. B. Designated Contact Response Upon being notified of the FDNS officer's arrival, the designated contact

1. Arrive at reception within five to ten (5–10) minutes. Promptness is important. The officer has limited time and may be conducting multiple site visits in a single day. A prompt response demonstrates OWS's professionalism and willingness to cooperate.

2. Introduce yourself by name and title. Clearly identify yourself as the Company's designated contact for immigration compliance matters. Provide the officer with your business card, if available.

3. Confirm the inspector's identity again. Verify the officer's name, title, and badge number. Ask again, if not previously disclosed, whether the visit pertains to a specific petition receipt number or beneficiary name.

4. Escort the inspector to a private conference room or office. A private meeting space allows for a focused discussion and protects the confidentiality of employee information. The conference room should be clean, professional, and equipped with adequate seating and a table for document review.

5. Offer water or similar hospitality. Normal professional courtesy — such as offering water, coffee, or tea — is appropriate and expected. This is not an adversarial encounter; it is a routine administrative visit.

6. Ask the inspector what documentation they would like to review and which employees, if any, they would like to interview. Understanding the scope of the visit at the outset allows the designated contact to compile the necessary documents and coordinate employee availability efficiently. The officer may request to review specific petition files, PAF documentation, payroll records, or other materials. The officer ma

7. Begin compiling requested documents. Using the Site Visit Ready Binder (see Section V.C) and the centralized immigration case management system, begin gathering the specific documents requested by the officer. If a document is not immediately available, acknowledge the request and indicate that the document will be produced as promptly as possible.

8. Notify outside counsel (Calderwood & Harkness LLP) and Patricia Langford (General Counsel) as soon as practicable. This notification should occur as soon as the designated contact has greeted the officer and escorted the officer to a conference room — ideally by text message or brief phone call while the officer is settling in. Outside counsel does not need to be present during the visit unless unusual circumstanc

V. DOCUMENTATION READINESS — WHAT TO HAVE AVAILABLE Effective documentation readiness is the cornerstone of a successful FDNS site visit. The ability to produce accurate, complete, and well-organized documentation on short notice demonstrates compliance and professionalism, and significantly reduces the risk of adverse findings. This section describes the documents that may be requested during a site visit, the requi

1. Current list of all visa-holding employees at that site. This list should include each visa holder's full legal name, current job title, visa classification (H-1B, O-1A, or O-1B), petition type (initial, extension, amendment, or transfer), petition receipt number, validity period (start and end dates), and applicable SOC code (for H-1B workers).

2. Copies of approved I-797 notices for each beneficiary at that site.

3. Copies of certified LCAs for each H-1B beneficiary at that site, including the ETA Case Number and all relevant worksite and wage information.

4. Complete PAF documentation for each H-1B beneficiary at that site, including all components listed in Section V.A above.

5. Organizational chart showing each visa holder's reporting structure, including the name and title of each visa holder's direct supervisor.

6. A copy of this FDNS Site Visit Preparedness Guide (the current version).

7. The Quick-Reference Contact Card (see Section XI).

8. The Quick-Reference Checklist — Site Visit Response Steps (see Section XII). The Site Visit Ready Binder must be updated on a quarterly basis and must also be updated promptly upon any of the following events: a new visa-holding employee begins employment at the worksite; a visa holder's status, classification, or worksite assignment changes; a new petition is filed or approved; a petition is denied, revoked, or w

VI. ESCORTING THE INSPECTOR AND FACILITATING THE VISIT A. Worksite Tour The FDNS officer may request to tour the worksite to observe the beneficiary's work area, confirm that the position and duties described in the petition correspond to actual working conditions, and verify that the beneficiary is physically present at the location identified in the petition. Worksite tours are a common component of FDNS site visit

1. Consult with Patricia Langford (General Counsel) or outside counsel (Calderwood & Harkness LLP) before granting access to any export-controlled area. This consultation should occur promptly and should not be used as a pretext for delaying the visit unreasonably. The purpose is to ensure compliance with the TCP and with the deemed export provisions of the EAR, specifically 15 CFR § 734.2(b)(2)(ii), which defines a

2. Understand the scope of the officer's authority. Government inspectors with appropriate credentials generally have a right to inspect the worksite for purposes of verifying employment conditions. However, the purpose of an FDNS site visit is to verify the accuracy of information in visa petitions — not to conduct a technology review, inspect proprietary systems, or evaluate the nature of the Company's intellectual

3. Do NOT disclose controlled technical data to the inspector. If the officer asks questions about the specific nature of the technology being developed, the designated contact should answer in general terms that are sufficient to describe the beneficiary's job duties (e.g., "This employee designs photonic integrated circuits for telecommunications applications") without disclosing controlled specifications, schemati

4. Coordinate with Dr. Yun-Sheng Chen (VP of Engineering) if the inspector requests to tour engineering work areas. Dr. Chen is knowledgeable about the Company's TCP and can assist in navigating the balance between cooperation with the FDNS officer and compliance with export control obligations.

VII. EMPLOYEE INTERVIEW PROTOCOL — DOS AND DON'TS A. General Principles FDNS officers may request to interview the beneficiary (the visa-holding employee) and/or the beneficiary's direct supervisor as part of the site visit. Interviews are one of the primary tools that FDNS officers use to verify the information in petition filings, and OWS should anticipate that at least one interview will occur during most site vis

VIII. SPECIFIC CONSIDERATIONS FOR OWS'S CURRENT VISA PORTFOLIO This section provides guidance specific to OWS's current population of visa-holding employees, including the Company's fourteen (14) H-1B workers, three (3) O-1A workers, and one (1) O-1B worker. Particular attention is given to pending or unusual matters that may require heightened awareness during an FDNS site visit. A. H-1B Holders (14 Current) OWS cur