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Trade Compliance Policy for AQUALON

Introduction

AQUALON is committed to maintaining the highest standards of trade compliance in all its international business activities. This policy outlines the guidelines and procedures AQUALON must follow to ensure compliance with all applicable laws and regulations related to international trade, including export controls, sanctions, and customs regulations.

1. Export Controls and Sanctions

AQUALON must comply with all applicable export control laws and regulations, including but not limited to:

  • U.S. Export Administration Regulations (EAR)
  • International Traffic in Arms Regulations (ITAR)
  • European Union Dual-Use Regulations
  • Sanctions imposed by the Office of Foreign Assets Control (OFAC)
  • United Nations and European Union sanctions

Procedures:

  • Screening: All international transactions must be screened against the relevant export control and sanctions lists before proceeding.
  • Licensing: Obtain all necessary export licenses before shipping controlled items, software, or technology.
  • Recordkeeping: Maintain records of all export transactions, including documentation of licenses and screening results, for at least five years.
  • Training: Regularly train employees on export control regulations and company policies.

2. Import Compliance

AQUALON must ensure compliance with all import regulations in the countries where it operates, including:

  • Correct Classification: Use the Harmonized System (HS) codes to classify goods accurately.
  • Valuation: Ensure that the value of imported goods is declared accurately and that all applicable duties and taxes are paid.
  • Country of Origin: Verify and document the country of origin of all imported goods.
  • Documentation: Prepare and maintain all necessary import documentation, including commercial invoices, packing lists, and bills of lading.

Procedures:

  • Customs Declarations: Ensure accurate and complete customs declarations for all imports.
  • Audits: Conduct regular audits of import transactions to verify compliance.
  • Broker Management: Work closely with customs brokers to ensure compliance with import regulations.

3. Internal Compliance Program

AQUALON must maintain a robust internal compliance program to ensure adherence to all trade laws and regulations.

Components:

  • Compliance Team: Establish a dedicated trade compliance team responsible for overseeing the company’s compliance efforts.
  • Compliance Officer: Appoint a Compliance Officer to lead the compliance team and serve as the primary point of contact for all trade compliance matters.
  • Policy Documentation: Maintain up-to-date documentation of all compliance policies and procedures.
  • Risk Assessment: Conduct regular risk assessments to identify and mitigate potential compliance risks.
  • Internal Audits: Perform regular internal audits to ensure compliance with trade regulations and company policies.
  • Reporting: Establish a system for reporting and addressing potential compliance violations.

4. Due Diligence and Partner Screening

AQUALON must conduct due diligence on all partners, including customers, suppliers, and intermediaries, to ensure they comply with applicable trade laws and regulations.

Procedures:

  • Screening: Screen all partners against relevant sanctions and restricted party lists.
  • Risk Assessment: Evaluate the risk associated with each partner and conduct additional due diligence as necessary.
  • Agreements: Include compliance clauses in all contracts and agreements with partners.

5. Training and Awareness

AQUALON must provide regular training to employees to ensure they understand and comply with trade compliance regulations and company policies.

Training Programs:

  • New Employees: Provide comprehensive trade compliance training as part of the onboarding process.
  • Ongoing Training: Conduct regular refresher training sessions for all employees involved in international trade activities.
  • Specialized Training: Offer specialized training for employees in high-risk roles or regions.

6. Communication and Reporting

AQUALON must maintain clear communication channels for reporting and addressing compliance issues.

Procedures:

  • Reporting System: Establish a confidential reporting system for employees to report potential compliance violations.
  • Incident Response: Develop and implement procedures for investigating and responding to reported compliance issues.
  • Management Reporting: Regularly report compliance activities and issues to senior management.

7. Continuous Improvement

AQUALON is committed to continuously improving its trade compliance program to adapt to changing regulations and business needs.

Actions:

  • Monitoring: Stay informed about changes in trade regulations and update policies and procedures accordingly.
  • Feedback: Collect and act on feedback from employees and partners to improve the compliance program.
  • Benchmarking: Regularly benchmark the compliance program against industry best practices.

Conclusion

Adherence to this Trade Compliance Policy is mandatory for all AQUALON employees and partners. By following these guidelines, AQUALON ensures that it operates within the bounds of international trade laws, maintains its reputation, and avoids legal and financial penalties.