Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Amgen GLOBAL CORPORATE COMPLIANCE POLICY"

Transcription

1 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers, and temporary staff are not Amgen employees, and nothing in this Policy should be construed to the contrary. 2. Policy It is Amgen s policy to comply with all applicable export and import control laws and regulations. This Policy sets forth the requirements for proper trade compliance activities, including export and import of goods, software, or technology. Export Control Laws It is important to ensure that Amgen s global supply chain is not interrupted, and movement of goods comply with international trade regulations specific to each country s jurisdiction. In the United States ( U.S. ), for example, there are laws that govern, and in many cases restrict, the final destination of the sale and/or shipment of goods, software, and technology to ensure that certain individuals, businesses, or entities, including individuals and organizations associated with known terrorist activities, do not receive items made by or from a U.S. company. In addition, Amgen must adhere to regulations around trade embargoes that may dictate partial or complete prohibition of commerce and trade with a particular country. The Directorate of Defense Trade Controls and the U.S. Bureau of Industry and Security in cooperation with the Office of Foreign Assets Control, are responsible for managing the flow and sale of U.S. software, goods, and technology from the U.S. All subsidiaries of the U.S. companies are bound to comply with the U.S. export control laws, and violations can result in civil and criminal penalties for Amgen and Covered Persons as well as suspension or denial of export privileges and debarment from U.S. Government procurement. Countries other than the U.S., such as members of the European Union, also have export control restrictions, and Covered Persons are required to follow all applicable laws related to exports. When controlled technology is released to foreign nationals within the U.S. or outside the U.S., deemed export occurs. Technology is "released" when it is exchanged verbally, in written or electronic format, or made available for visual inspection or through practice or application by persons with knowledge of the technology. Amgen Global Trade Office conducts controlled technology assessments and maintains a list of controlled technologies within Amgen facilities. Hiring of foreign nationals either within or outside the U.S. into facilities with controlled technology are subject to review by the Global Trade Office. Anti-boycott regulations require U.S. firms and their subsidiaries to refuse to participate in unsanctioned foreign boycotts of countries friendly to the United States, for example, Israel. Any requests received by Covered Persons that are discriminatory in nature towards a country or a business, and are made in connection with international transactions, must be refused and reported to the Global Trade Office. Effective Date: June 1, 2015 FORM

2 Import Control Laws Globally, countries regulate the flow of goods, technology and persons into their borders. In the U.S., for example, Customs and Border Protection ( CBP ), a division of the U.S. Department of Homeland Security, secures and facilitates trade and travel into the U.S. Many of the regulations enforced by CBP are intended to prevent acts of terrorism and to assure that goods entering the country are legitimate and that appropriate duties and fees are paid. Wherever Amgen operates, Covered Persons are required to follow all applicable laws related to imports. Violations of import control laws may result in importations, including hand-carries, being rejected or seized, and civil and criminal penalties imposed on Amgen and Covered Persons. Since Amgen products are also regulated by the U.S. Food and Drug Administration ( FDA ), it is important to note that the FDA also regulates import and export of drugs, biologics, combination products and medical devices. Other government agencies having jurisdiction over commodities Amgen imports may include the U.S. Department of Agriculture, U.S. Centers for Disease Control and Prevention, U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, other agencies depending on the commodity. Similar agencies may exist globally, and Amgen is also subject to adherence to other government agency regulations when applicable outside the U.S. Generally, these laws are in addition to, and not in lieu of, regulations referenced above. General Guidelines for Compliance with Export and Import Laws Covered Persons are advised to consult Global Trade Office Amgen s trade compliance group, for guidance on export and import compliance in advance of a planned import or export transaction. Some transactions may be prohibited or restricted and require securing permits or licenses prior to the transaction. When appropriate, Global Trade Office will liaise with other key stake holders and functions for cross-functional perspective and advice. Covered Persons must comply with export and import controls and requirements when engaging in any of the following activities (which is a non-exhaustive list): Shipment or movement of goods (including hand-carries) across international borders whether between Amgen locations or third parties on Amgen s behalf, including contract manufacturers, logistics service providers and other business partners; Creation of international shipping documentation such as a Customs/Commercial invoice, statement of Origin or shipping waybill; and Transfer of technology outside of the U.S. and within the U.S. to foreign nationals either verbally or in written form, which is subject to deemed export regulations. This includes transfer of technical data, blueprints, training on specific methods and/or technologies needed for product use and/or development. Covered Persons are required to follow all procedures that Amgen s Global Trade Office has established to ensure export and import compliance, which include: Providing accurate and complete information on imported goods and exported goods where such information is required; Valuing goods in alignment with applicable regulations and Amgen policies; Marking goods with the appropriate country of origin where required to provide such information. Country of Origin regulations are complex and are determined by each Effective Date: June 1, 2015 FORM

3 destination country, Covered Persons should contact Global Trade Office for guidance on country of origin marking when it is not known; and Maintaining relevant records in accordance with the regulations, typically five years. Covered Persons should contact Global Trade Office if they have any questions about international transfer of goods, software, or technology. Covered Persons are prohibited from making payments or offering anything of value to Government Officials (as defined in Amgen s Global Corporate Compliance Policy - Anticorruption and U.S. Foreign Corrupt Practices Act), directly or indirectly (e.g., via third parties), in order to influence those officials behavior in relation to import or export shipments, clearances, licenses, permits, certificates or statements. In the event there is a threat that Amgen s business is being paralyzed by a Government Official, Covered Persons are required, in advance of taking any action, to contact local Amgen Management and the Law Department immediately to discuss the situation and permissible options. For further guidance on this topic, please see Amgen s Global Corporate Compliance Policy - Anti-corruption and U.S. Foreign Corrupt Practices Act. Basic Shipping Procedures Because of the complexity of export and import laws, Amgen s Global Trade Office has established procedures and controls to help ensure that shipping and other international activities are performed in a compliant manner. Covered Persons are required to follow these procedures. All international export activity must be shipped via approved shipping locations (posted on Global Trade Office Site on MyAmgen) for final processing. Third parties exporting or importing on behalf of Amgen must be instructed to contact Global Trade Office to ensure compliant transactions. All internationally shipped goods must be accompanied by documentation to meet customs and other government agencies rules and regulations. Consult Global Trade Office to review the documentation for shipments originating from or bound for the U.S. as well as for general guidance on international shipping procedures and processes, including documentation, Customs valuation, country of origin, tariff classification, right to import, import duties/taxes, Free Trade Agreements and other special programs, INCOterms and any other aspects of international trade. Supply Chain Security Amgen is a voluntary member of supply chain security programs including the Customs-Trade Partnership Against Terrorism ( C-TPAT ) program (U.S.) and Authorized Economic Operator ( AEO ) program (E.U.). This commits Amgen to maintain high standards and security measures throughout our supply chain. Procedures in support of these standards are designed to enhance the security of our facilities, people, cargo shipping, cargo receiving and cargo tracking processes. Amgen s goal in participating in these programs is to prevent cargo loss and cargo tampering, including the introduction of illegal merchandise into the global supply chain. One of the aspects of this program includes the ongoing security screening of our business partners such as suppliers, manufacturers, importers, carriers, consolidators, and customs brokers to verify the integrity of their security practices and to ensure they follow security procedures that meet a similar supply chain security standard. Effective Date: June 1, 2015 FORM

4 Amgen s Global Trade Office is responsible for administering the Amgen C-TPAT program and works with the Amgen regional offices to ensure they meet the security standards of C-TPAT and/or the applicable supply security program within their region. Effective Date: June 1, 2015 FORM

5 3. Additional Information Every Covered Person worldwide is required to follow (1) the Amgen Code of Conduct, (2) laws and regulations applicable in the relevant jurisdictions, and (3) Amgen governance documents applicable to him or her, including without limitation, those relating to this Policy. Covered Persons should exert due diligence in preventing violations of such laws, regulations, and governance documents. Covered Persons must refer to the governance documents in effect for the geographic area in which they work, or for which they are responsible, or request guidance from their manager or compliance representative with responsibility for that geographic area. The term governance documents in this Policy means Amgen s written policies, standards, procedures, business practices, and manuals. Amgen expects its managers to (1) be familiar with (or take appropriate steps to become familiar with) the laws, regulations, and Amgen governance documents applicable to the activities they manage or supervise, (2) ensure their direct reports have appropriate training on compliance requirements to perform their job functions, and (3) supervise their direct reports with respect to compliance requirements and activities. If Amgen determines that any Covered Person has violated this Policy, related standards, procedures or controls, applicable laws or regulations, or any governance documents, appropriate disciplinary measures will be taken, up to and including immediate termination of employment, to the extent permitted by applicable laws. The following is a non-exhaustive list of possible disciplinary measures to which Covered Persons may be subject (subject to applicable law): oral or written warning, suspension, removal of job duties/responsibilities, demotion, reduction in compensation, and/or termination of employment. Subject to applicable laws, Amgen reserves the right to take whatever disciplinary or other measure(s) it determines in its sole discretion to be appropriate in any particular situation, including disclosure of the wrongdoing to governmental authorities. Nothing in this Policy changes the at-will nature of employment at Amgen, its affiliates or subsidiaries, where applicable. Amgen may also terminate the services or work engagement of non-employee Covered Persons for violation of this Policy. Effective Date: June 1, 2015 FORM

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts

Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts Olga Torres, Associate Ol T A i t Braumiller Schulz LLP International Trade Law www.globaltradelaw.net Overview Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance

More information

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically

More information

Key Elements of International Trade Compliance. Presented by:

Key Elements of International Trade Compliance. Presented by: Key Elements of International Trade Compliance Presented by: International Business Transactions International Civil Litigation 2 I. Introduction Every international shipment implicates at least TWO legal

More information

EXPORT CONTROLS COMPLIANCE

EXPORT CONTROLS COMPLIANCE Responsible University Official: Vice President for Research Responsible Office: Office for Export Controls Compliance Origination Date: May 1, 2014 EXPORT CONTROLS COMPLIANCE Policy Statement Northwestern

More information

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk

More information

Complying with the U.S. Foreign Corrupt Practices Act

Complying with the U.S. Foreign Corrupt Practices Act Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption

More information

ABBVIE C-TPAT SUPPLY CHAIN SECURITY QUESTIONNAIRE

ABBVIE C-TPAT SUPPLY CHAIN SECURITY QUESTIONNAIRE AbbVie is a participant in the U.S. Customs supply chain security program called the Customs-Trade Partnership Against Terrorism (C-TPAT). Participation in C-TPAT requires AbbVie to ensure that its overseas

More information

Export Control What You Need to Know

Export Control What You Need to Know Export Control What You Need to Know What are export control regulations? US Export control regulations restrict the use of, and access to, certain sensitive or controlled technical information, materials

More information

DHL GLOBAL FORWARDING Import Customs Brokerage USA

DHL GLOBAL FORWARDING Import Customs Brokerage USA Trade Lane Management DHL GLOBAL FORWARDING Import Customs Brokerage USA Patrick Demler / Robert Marjai, Chicago December 15 2011 OVERVIEW MODULES 1. USA Import brokerage / CBP and OGA (Other Government

More information

Foreign Corrupt Practices Act & Compliance Policy

Foreign Corrupt Practices Act & Compliance Policy Team Resources Management () INTEGRITY MANAGEMENT SYSTEM (IMS) Printed documents are considered uncontrolled. Controlled documents can be found on the Atlantica server. -2-POL-057 1 0 02-Dec-2013 1 of

More information

U.S. Code. Customs and Border Protection (CBP)

U.S. Code. Customs and Border Protection (CBP) The following is a brief overview of what you can expect if your shipment has been selected for examination by Customs and Border Protection or the U.S. Government. U.S. Code Under title 19, section 1467

More information

Protecting the Value of Your Transaction y

Protecting the Value of Your Transaction y International Trade Due Diligence: Protecting the Value of Your Transaction y by Megan A. Gajewski, Susan M.C. Kovarovics, Michael D. Mellen and Christina A. Zanette You just closed a deal for your client,

More information

How to build a great compliance program for your U.S. imports

How to build a great compliance program for your U.S. imports How to build a great compliance program for your U.S. imports For the importer of record, compliance means the complete and accurate recording of all internal processes through books and records, from

More information

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011) DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply

More information

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of

More information

University of Louisiana System

University of Louisiana System Policy Number: M-(16) University of Louisiana System Title: EXPORT CONTROL Effective Date: October 26, 2009 Cancellation: None Chapter: Miscellaneous Policy and Procedures Memorandum The University of

More information

5/29/2015. Export Compliance Overview. Agenda. Regulatory Overview. In the News. Key Program Elements. Quiz

5/29/2015. Export Compliance Overview. Agenda. Regulatory Overview. In the News. Key Program Elements. Quiz Export Compliance Overview William Barthell Global Trade Compliance Symantec Corporation June 19, 2015 Agenda Regulatory Overview In the News Key Program Elements Quiz Copyright 2015 Symantec Corporation

More information

CONCERNING CONSULTATION, COOPERATION AND THE EXCHANGE OF INFORMATION

CONCERNING CONSULTATION, COOPERATION AND THE EXCHANGE OF INFORMATION STATEMENT OF INTENT CONCERNING CONSULTATION, COOPERATION AND THE EXCHANGE OF INFORMATION The Ministry of Agriculture, Forestry and Fisheries of Japan The Ministry of Economy, Trade and Industry of Japan

More information

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY Goodman Global Group, Inc. and our affiliates (collectively, the Company ) are committed to complying with all laws applicable

More information

FOREIGN CORRUPT PRACTICES ACT POLICY

FOREIGN CORRUPT PRACTICES ACT POLICY FOREIGN CORRUPT PRACTICES ACT POLICY Purpose The purpose of this Policy is to ensure compliance from SWOP's employees and representatives with the US Foreign Corrupt Practices Act ("FCPA"). The Lay Person's

More information

Trusted Traders Programs Overview

Trusted Traders Programs Overview Trusted Traders Programs Overview Presentation to WCO Knowledge Academy for Customs and Trade July 4, 2014 1 Trusted Traders Programs Objective: To facilitate the movement of legitimate goods by providing

More information

MANUFACTURING AGREEMENT

MANUFACTURING AGREEMENT MANUFACTURING AGREEMENT AGREEMENT made this day of, 20, (the Effective Date ) by and between Hat World, Inc., a Minnesota corporation, having its principal office at 7555 Woodland Drive, Indianapolis,

More information

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3 Mastering Global Trade Compliance for Growth Through Export Track 1 Session 3 Julie Gibbs Director BPE Global Jgibbs@bpeglobal.com 415-595-8543 www.bpeglobal.com 2 Abstract It's not a small world after

More information

Managing Cross Border Regulations. Global Customs

Managing Cross Border Regulations. Global Customs Managing Cross Border Regulations Global Customs GM is one of the world s largest manufacturers of passenger motors vehicles GM maintains a family of global brands including: Buick, Cadillac, Chevrolet,

More information

DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS

DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS Are you fully COMPLIANT? The international trade and compliance landscape is rapidly changing, and global supply chains are facing major challenges.

More information

COMPLIANCE PROGRAM FOR XL GROUP PLC

COMPLIANCE PROGRAM FOR XL GROUP PLC 1 COMPLIANCE PROGRAM FOR XL GROUP PLC I. PURPOSE The purpose of the XL Group plc Compliance Program (the Program ) is to (a) help protect XL Group plc companies from financial or reputational harm that

More information

FCPA, Sanctions, Export, & Antiboycott Compliance

FCPA, Sanctions, Export, & Antiboycott Compliance FCPA, Sanctions, Export, & Antiboycott Compliance Charlie Parker 713-632-8000 Cam Barker 512-533-0150 The Law US PERSONS CANNOT: Bribe foreign government officials FCPA Enter into transactions with Sanctioned

More information

Director of Logistics & Compliance James Hall

Director of Logistics & Compliance James Hall Minimizing Risk Exposure While Fully Utilizing Freight Forwarders Expertise To Effectively Apply Compliance In Challenging Locations Director of Logistics & Compliance James Hall What is Compliance Adherence

More information

LAUREATE ANTI-CORRUPTION POLICY

LAUREATE ANTI-CORRUPTION POLICY LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery

More information

Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes

Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes John W. Boscariol February 23, 2016 Why This Now Matters to Canadian Companies

More information

Services Summary TRADITIONAL CUSTOMS SERVICES. Instruments of International Traffic Foreign market entry plans

Services Summary TRADITIONAL CUSTOMS SERVICES. Instruments of International Traffic Foreign market entry plans Services Summary What distinguishes GTS from others is our ability to identify your business needs, customize a practical solution and take the action steps necessary to implement that solution. Our practice

More information

Harvard Export Control Compliance Policy Statement

Harvard Export Control Compliance Policy Statement Harvard Export Control Compliance Policy Statement Harvard University investigators engage in a broad range of innovative and important research both in the United States and overseas. These activities

More information

FLUOR HUMAN RESOURCES POLICY POLICY/PROCEDURE

FLUOR HUMAN RESOURCES POLICY POLICY/PROCEDURE Page 1 of 5 HR-720 Supersedes: 09-21-06 I. POLICY A. Fluor s employees, officers, directors, and any agents, subsidiaries, joint ventures, consortiums, consultants, brokers, or other individuals, intermediaries,

More information

Global Supply Chain Security Recommendations

Global Supply Chain Security Recommendations Global Supply Chain Security Recommendations These minimum security criteria are fundamentally designed to be the building blocks for foreign manufacturers to institute effective security practices designed

More information

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011 SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its

More information

A Message for Warehouse Operators And Security Guidelines for Warehouse Operators

A Message for Warehouse Operators And Security Guidelines for Warehouse Operators A Message for Warehouse Operators And Security Guidelines for Warehouse Operators Kingchem LLC is a participant in the Customs-Trade Partnership Against Terrorism (C-TPAT). C-TPAT is a voluntary joint

More information

Anti-Bribery and Books & Records Provisions of. The Foreign Corrupt Practices Act. Current through Pub. L. 105-366 (November 10, 1998)

Anti-Bribery and Books & Records Provisions of. The Foreign Corrupt Practices Act. Current through Pub. L. 105-366 (November 10, 1998) [As of July 22, 2004] Anti-Bribery and Books & Records Provisions of The Foreign Corrupt Practices Act Current through Pub. L. 105-366 (November 10, 1998) UNITED STATES CODE TITLE 15. COMMERCE AND TRADE

More information

Worldwide Anti-Corruption Policy

Worldwide Anti-Corruption Policy Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton

More information

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Introduction To Commerce Department Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Overview The Department of Commerce s Bureau of Industry and

More information

Intermec Security Letter of Agreement

Intermec Security Letter of Agreement Intermec Security Letter of Agreement Dear Supplier, Please be advised that Intermec Technologies has joined US Customs and Border Protection (USC&BP) in the Customs-Trade Partnership Against Terrorism

More information

MANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

MANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Purpose The purpose of this Foreign Corrupt Practices Act Compliance Policy (this Policy ) is to help ensure compliance by Manning

More information

Export Control Guidelines. Background Information

Export Control Guidelines. Background Information Export Control Guidelines Background Information The University of Notre Dame expects that all personnel, including faculty, staff, visiting scientists, postdoctoral fellows, students, and all other persons

More information

576 Valley Rd, #234 Wayne, NJ 07470 Tel: (973) 333-4922 Fax: (973) 595-7720. Attention: Date:

576 Valley Rd, #234 Wayne, NJ 07470 Tel: (973) 333-4922 Fax: (973) 595-7720. Attention: Date: Attention: 576 Valley Rd, #234 Tel: (973) 333-4922 Fax: (973) 595-7720 From: Date: Cheryl Biron I would like to take this time to thank you for your interest in becoming a qualified carrier for One Horn

More information

Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations

Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations Presented by: Norm Hebert, Director, International Research Administration,

More information

Bottomline s Code of Business Conduct and Ethics

Bottomline s Code of Business Conduct and Ethics Bottomline s Code of Business Conduct and Ethics Bottomline Technologies (the Company) Code of Business Conduct and Ethics is the compass by which directors, officers, employees and contractors (each,

More information

Evergreen Solar, Inc. Code of Business Conduct and Ethics

Evergreen Solar, Inc. Code of Business Conduct and Ethics Evergreen Solar, Inc. Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD At Evergreen Solar, Inc. (the Company or Evergreen Solar ), we believe that conducting business ethically is critical

More information

Administrative Policy No. AD 2.26 Title:

Administrative Policy No. AD 2.26 Title: I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates

More information

U.S. Economic Sanctions Laws and How They Affect Insurance Brokers

U.S. Economic Sanctions Laws and How They Affect Insurance Brokers U.S. Economic Sanctions Laws and How They Affect Insurance Brokers The United States Government imposes economic sanctions against several countries and a large number of individuals and entities, in response

More information

Rail Carrier Security Criteria

Rail Carrier Security Criteria Rail Carrier Security Criteria Rail carriers must conduct a comprehensive assessment of their security practices based upon the following C-TPAT minimum-security criteria. Recognizing that rail carriers

More information

Customs Trade Partnership Against Terrorism (C-TPAT) International Supply Chain Security Risk Assessment Frequently Asked Questions

Customs Trade Partnership Against Terrorism (C-TPAT) International Supply Chain Security Risk Assessment Frequently Asked Questions Customs Trade Partnership Against Terrorism (C-TPAT) International Supply Chain Security Risk Assessment Frequently Asked Questions In an effort to clarify the April 23, 2010 bulletin regarding international

More information

What Every Contract Manufacturer Needs to Know About Export Compliance

What Every Contract Manufacturer Needs to Know About Export Compliance A Compliance Assurance LLC White Paper P.O. Box 211415 Royal Palm Beach, FL 33421 561.641.5036 www.wearecompliant.com What Every Contract Manufacturer Needs to Know About Export Compliance By James Anzalone,

More information

FREIGHT FORWARDER GUIDANCE

FREIGHT FORWARDER GUIDANCE U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT AND COMPLIANCE DIVISION FREIGHT FORWARDER GUIDANCE February 2012 Freight Forwarder Guidance Members

More information

CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS

CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS Thomas B. McVey Direct Dial: 202.293.8118 tmcvey@williamsmullen.com CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS By: Thomas B. McVey Williams Mullen June 2, 2014 The

More information

C-TPAT Executive Summary

C-TPAT Executive Summary C-TPAT Executive Summary Customs and Border Protection (CBP) established the Customs-Trade Partnership against Terrorism (C-TPAT) as part of a comprehensive strategy designed to enhance national security

More information

Antiboycott Legal Compliance Guide

Antiboycott Legal Compliance Guide Antiboycott Legal Compliance Guide NOTE: This document has been modified from its original format. It has been optimized for on-screen viewing and desktop printing. English 2 Antiboycott Legal Compliance

More information

WAREHOUSE SECURITY BEST PRACTICE GUIDELINES CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM

WAREHOUSE SECURITY BEST PRACTICE GUIDELINES CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM BACKGROUND WAREHOUSE SECURITY BEST PRACTICE GUIDELINES CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM In the aftermath of September 11, U.S. Customs and Border Protection (CBP) in cooperation with its trade

More information

CARDINAL RESOURCES LLC INTRODUCTION

CARDINAL RESOURCES LLC INTRODUCTION CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group

More information

U.S. Export Control Laws

U.S. Export Control Laws U.S. Export Control Laws Holland & Hart International Practice Group Trip Mackintosh July 31, 2001 I. General overview. U.S. export control laws apply to virtually every international transaction. In most

More information

welcome to Telect s Minimum Security Criteria for Customs-Trade Partnership Against Terrorism (C-TPAT) Foreign Manufacturers Training Presentation

welcome to Telect s Minimum Security Criteria for Customs-Trade Partnership Against Terrorism (C-TPAT) Foreign Manufacturers Training Presentation welcome to Telect s Minimum Security Criteria for Customs-Trade Partnership Against Terrorism (C-TPAT) Foreign Manufacturers Training Presentation Minimum Security Criteria Scope Designed to be the building

More information

STATEMENT FROM THE CHAIRMAN

STATEMENT FROM THE CHAIRMAN STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions

More information

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,

More information

Risk-Based Approach to Managing Supply Chain Security and Compliance

Risk-Based Approach to Managing Supply Chain Security and Compliance Risk-Based Approach to Managing Supply Chain Security and Compliance Supply chain security remains a U.S. policy priority, and the U.S. Government continues to work closely with the trade community to

More information

A Primer on U.S. Export Controls

A Primer on U.S. Export Controls A Primer on U.S. Export Controls Presentation for the Pacific Northwest Defense Coalition By Akana K.J. Ma Partner, Ater Wynne LLP 16 July 2013 (503) 226-8489/akm@aterwynne.com Akana K.J. Ma 2013 All Rights

More information

Employee Code of Conduct GENERAL STATEMENT OF BUSINESS PHILOSOPHY

Employee Code of Conduct GENERAL STATEMENT OF BUSINESS PHILOSOPHY Employee Code of Conduct GENERAL STATEMENT OF BUSINESS PHILOSOPHY The commitment to excellence is fundamental to the philosophy of CFA Institute. This commitment means that employees share a common set

More information

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014

UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS. Revised as of March 3, 2014 I. Statement of Policy UNIVERSAL INSURANCE HOLDINGS, INC. CODE OF BUSINESS CONDUCT AND ETHICS Revised as of March 3, 2014 Universal Insurance Holdings, Inc. ( UIH ) and its subsidiaries (collectively,

More information

Foreign Corrupt Practices Act ( FCPA )

Foreign Corrupt Practices Act ( FCPA ) Foreign Corrupt Practices Act ( FCPA ) OVERVIEW The Foreign Corrupt Practices Act ( FCPA ) was passed in 1977 in an effort to address concerns over the integrity of U.S. markets after hundreds of U.S.

More information

CODE OF ETHICS AND BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT CODE OF ETHICS AND BUSINESS CONDUCT TABLE OF CONTENTS The Oracle Code of Ethics and Business Conduct........1 Understanding this Code..........................1 Applicability of This Code..........................2

More information

Customs-Trade Partnership Against Terrorism (C-TPAT) Security Guidelines for Suppliers/Shippers

Customs-Trade Partnership Against Terrorism (C-TPAT) Security Guidelines for Suppliers/Shippers Customs-Trade Partnership Against Terrorism (C-TPAT) Security Guidelines for Suppliers/Shippers In support of Vectora's C-TPAT program implementation, these security requirements and guidelines are provided

More information

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: C150 Page 1 of 10

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: C150 Page 1 of 10 Page 1 of 10 TITLE: POLICY AND PROCEDURES REGARDING COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT ( FCPA ) POLICY: All Hospital Personnel are responsible for complying with the U.S. Foreign Corrupt

More information

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 31, ISSUE 1 / JUNE 13, 2013 Expert Analysis Software Development and U.S. Export Controls

More information

APPENDIX B ABOUT U.S. CUSTOMS AND BORDER PROTECTION: MISSION AND CORE VALUES

APPENDIX B ABOUT U.S. CUSTOMS AND BORDER PROTECTION: MISSION AND CORE VALUES APPENDIX B ABOUT U.S. CUSTOMS AND BORDER PROTECTION: MISSION AND CORE VALUES Northern Border Activities B-1 July 2012 CBP MISSION We are the guardians of our Nation s borders. We are America s frontline.

More information

EXPORT CONTROL COMPLIANCE

EXPORT CONTROL COMPLIANCE 03.370 EXPORT CONTROL COMPLIANCE Authority: Provost and Vice Chancellor for Academic Affairs History: Established October 1, 2007 Source of Authority: Related Links: Responsible Office: Export Administration

More information

FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY The following guidelines are derived from the United States Foreign Corrupt Practices Act ( FCPA ), and no deviation from these guidelines is permitted.

More information

Security Criteria for C-TPAT Foreign Manufacturers in English

Security Criteria for C-TPAT Foreign Manufacturers in English Security Criteria for C-TPAT Foreign Manufacturers in English These minimum security criteria are fundamentally designed to be the building blocks for foreign manufacturers to institute effective security

More information

BUYING AGENCY AGREEMENT

BUYING AGENCY AGREEMENT THIS AGREEMENT ( Agreement ) is made this day of, 20xx, by and between, with its principal place of business at referred to hereinafter as Buyer, and, with its principal office at, hereinafter referred

More information

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries

More information

This Policy supersedes the Terex Corporation Policy on Transactions in Iran, dated June 7, 2013.

This Policy supersedes the Terex Corporation Policy on Transactions in Iran, dated June 7, 2013. TEREX CORPORATION POLICY REGARDING TRANSACTIONS IN IRAN (the Policy ) applies to all Terex operations and Terex team members worldwide. This Policy supersedes the Terex Corporation Policy on Transactions

More information

By placing an order with International Checkout Inc. and / or using its website, you agree and are bound to the Terms & Conditions below.

By placing an order with International Checkout Inc. and / or using its website, you agree and are bound to the Terms & Conditions below. By placing an order with International Checkout Inc. and / or using its website, you agree and are bound to the Terms & Conditions below. 1. How It Works International Checkout Inc. ( we / us ) has agreements

More information

Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013

Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013 Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics March 10, 2013 This Code of Business Conduct and Ethics (the "Code") sets forth legal and ethical standards of conduct for directors,

More information

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012

Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 Ryanair Holdings PLC Code of Business Conduct & Ethics 2012 1 TABLE OF CONTENTS 1. INTRODUCTION 3 2. WORK ENVIRONMENT 3 2.1 Discrimination & Harassment 3 2.2 Privacy of Personal Information 3 2.3 Internet

More information

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY THIS POLICY HAS BEEN APPROVED BY THE BOARD OF DIRECTORS OF MUELLER INDUSTRIES, INC. ON FEBRUARY 11, 2010 AND IS APPLICABLE TO ALL DIRECTORS, OFFICERS, EMPLOYEES,

More information

Export Management and Compliance Program Guide

Export Management and Compliance Program Guide Export Management and Compliance Program Guide The UAMS Export Management and Compliance Program Guide attempts to provide relevant information about export controls and how they affect the academic and

More information

H. R. 5005 11 SEC. 201. DIRECTORATE FOR INFORMATION ANALYSIS AND INFRA STRUCTURE PROTECTION.

H. R. 5005 11 SEC. 201. DIRECTORATE FOR INFORMATION ANALYSIS AND INFRA STRUCTURE PROTECTION. H. R. 5005 11 (d) OTHER OFFICERS. To assist the Secretary in the performance of the Secretary s functions, there are the following officers, appointed by the President: (1) A Director of the Secret Service.

More information

International Nonproliferation Export Control Program (INECP) Foundations of an Effective Strategic Trade Control System

International Nonproliferation Export Control Program (INECP) Foundations of an Effective Strategic Trade Control System International Nonproliferation Export Control Program (INECP) Foundations of an Effective Strategic Trade Control System Components of an Effective Strategic Trade Control System 3 Components Interdiction

More information

Guidance To The Commerce Department's REEXPORT CONTROLS. U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services

Guidance To The Commerce Department's REEXPORT CONTROLS. U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services fin BIS Reexport covers 6/14/06 10:13 AM Page 1 Guidance To The Commerce Department's REEXPORT CONTROLS U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services Guidance

More information

Credit Application And Agreement. End Use / End User Certification. Form 5401 93 REV. 1 1/2009 Page 1 of 11

Credit Application And Agreement. End Use / End User Certification. Form 5401 93 REV. 1 1/2009 Page 1 of 11 Credit Application And Agreement End Use / End User Certification Form 5401 93 REV. 1 1/2009 Page 1 of 11 CREDIT APPLICATION AND AGREEMENT I. Company Information: Business Name: Type of Business: Telephone

More information

Regulatory Compliance and Trade

Regulatory Compliance and Trade Regulatory Compliance and Trade Global Transaction Services Cash Management Trade Services and Finance Securities Services Fund Services Regulatory Compliance and Trade 2007 These materials are provided

More information

Code of Ethics. I. Definitions

Code of Ethics. I. Definitions Code of Ethics Old North State Trust, LLC (the Company ) has adopted this Code of Ethics in recognition of the principle that all Supervised Persons (as defined below) of the Company have a fiduciary duty

More information

SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy

SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy General Policy: SEKO Logistics ( SEKO ) conducts its business ethically and in compliance with all laws in the countries where SEKO

More information

Number: M-002 Revision: A Page 1 of 9. Traffic in Arms Regulations (ITAR) MANUAL

Number: M-002 Revision: A Page 1 of 9. Traffic in Arms Regulations (ITAR) MANUAL Page 1 of 9 THIS DOCUMENT IS CONSIDERED UNCONTROLLED UNLESS ISSUED IDENTIFIED AS CONTROLLED Page 2 of 9 REVISION HISTORY DATE CHANGE DESCRIPTION 10/21/09 Original release Approval: Robert Faia Robert Faia,

More information

Corp. Offices: Transportation Ave. Laredo, TX Tel: (956) / Fax: (956)

Corp. Offices: Transportation Ave. Laredo, TX Tel: (956) / Fax: (956) Corp. Offices: 14213 Transportation Ave. Laredo, TX 78045 Tel: (956) 724-8417 / Fax: (956) 724-9015 www.transcontinentalinc.com Vendor Policy The payment terms herein have been established to ensure that

More information

RESTRICTED PARTY SCREENING USING SOFTWARE TO MANAGE TRADE COMPLIANCE

RESTRICTED PARTY SCREENING USING SOFTWARE TO MANAGE TRADE COMPLIANCE RESTRICTED PART Y SCREENING USING SOFTWARE TO MANAGE TRADE COMPLIANCE Today s complex supply chains place strong demands on companies and require the simultaneous management of many distinct and important

More information

THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS:

THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS: THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS: INSTRUCTIONS: Read this entire order form, including the incorporated terms and conditions located at http://www.seagate.com/about/legal-privacy/purchasing-and-pricing/purchase-orders-legal-overview/

More information

C-TPAT Importer Security Criteria

C-TPAT Importer Security Criteria C-TPAT Importer Security Criteria Importers must conduct a comprehensive assessment of their international supply chains based upon the following C-TPAT security criteria. Where an importer outsources

More information

APPRAISAL MANAGEMENT COMPANY

APPRAISAL MANAGEMENT COMPANY STATE OF ARKANSAS APPRAISER LICENSING AND CERTIFICATION BOARD APPRAISAL MANAGEMENT COMPANY STATUTES 1 ARKANSAS APPRAISER LICENSING AND CERTIFICATION BOARD APPRAISAL MANAGEMENT COMPANY STATUTES SUBCHAPTER

More information

publish in advance any regulation governing customs matters that it proposes to adopt; and

publish in advance any regulation governing customs matters that it proposes to adopt; and CHAPTER SIX CUSTOMS ADMINISTRATION ARTICLE 6.1 : PUBLICATION AND NOTIFICATION 1. Each Party shall ensure that its laws, regulations, guidelines, procedures, and administrative rulings governing customs

More information

Export Controls and Archeology Research. Marie Hladikova, Export Control Director Office of Research Compliance

Export Controls and Archeology Research. Marie Hladikova, Export Control Director Office of Research Compliance Export Controls and Archeology Research Marie Hladikova, Export Control Director Office of Research Compliance Legal Disclaimer The information contained in this presentation does not constitute legal

More information

THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS:

THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS: THE FOLLOWING ARE INSTRUCTIONS FROM THE FRONT SIDE OF SEAGATE PURCHASE ORDERS: INSTRUCTIONS: Read this entire order form, including the incorporated terms and conditions located at http://www.seagate.com/about/legal-privacy/purchasing-and-pricing/purchase-orders-legal-overview/

More information