MANAGEMENT STATEMENT OF POLICY AND COMMITMENT
We acknowledge the importance of compliance with the rules and regulation including the risks involved of export control (to prevent goods from falling into the wrong hands), responsible business conduct and the consequences of violating the law. The dedication from all our personnel is expected when it comes to compliance.
It is therefore the policy of A.I. Armaments and all its subsidiaries and affiliates (hereafter ‘AIA’) to comply with all export control laws and regulations pertaining to its operations. Compliance with U.S., EU, and NL export controls is seen as a fundamental condition for the successful participation by AIA in all its (inter)national programs. Violation of any export controls may result in serious consequences for AIA. Administrative or criminal penalties, substantial fines, exclusion from participation in a program, and great harm to the AIA’s reputation can be the result of such a violation. Therefore, AIA will not facilitate sales that violate U.S., EU and Dutch export control regulations.
AIA is therefore committed to provide sufficient resources to prevent violations from taking place and to comply with applicable U.S. export control requirements (both ITAR and EAR). AIA will conduct all of its export-related activities, including sales, brokering (as per defined regulations), shipments, disposal of products, (re)transfers and (re)exports of technology, articles, and defense services in a manner intended to satisfy its obligations under the export laws and regulations of the United States, the European Union, and the Netherlands.
AIA is committed to complying with these laws and regulations not only because it is the right thing to do for national security and other reasons, but also because our business depends on it. Failure to comply with all the export control laws and regulations will jeopardize our ability to export or handle controlled products, could tarnish our reputation for ethical and responsible conduct and could also trigger the U.S. government to impose (financial) penalties on our company.
We are committed to knowing how our products, technology, and services are treated for U.S., EU, and NL export control purposes, including knowing which laws govern their respective exports. We also are committed to knowing which countries and parties are involved in a proposed export transaction because certain U.S., EU, and NL export laws prohibit transactions involving certain countries, entities, or individuals even if the transaction would otherwise be permissible based on the nature of the product, technology, or service. We must therefore be diligent and aware of the scope of proposed transactions to ensure all export control laws are complied with.
We are committed to dedicating the resources necessary to have a robust internal controls program. To that end, we are committed to having an export compliance staff designated as point persons for any internal queries as to best practices and ensuring compliance.
In summary, our commitment to trade compliance includes (but is not limited to):
– Compliance with all applicable laws and regulations governing international trade, including but not limited to import and export controls, sanctions, anti-boycot regulations, and anti-corruption laws.
– Conducting due diligence on our partners, including suppliers, agents, distributors, and costumers, to ensure they comply with applicable trade laws and regulations.
– Providing training and resources to our employees and partners to promote awareness and understanding of trade compliance requirements, regarding strategic and dual-use items.
– Maintaining accurate and complete records of all transactions and activities related to international trade, as required by law.
– Promptly reporting any suspected violations of trade laws or regulations to the appropriate authorities and taking apportionment corrective action.
We expect all of our employees and partners to uphold these standards of trade compliance and to act with integrity and ethical behaviour in all their business dealings. We recognise that trade compliance is a shared responsibility, and we are committed to collaboratively with our partners to ensure that we all comply with applicable laws and regulations.
Reporting export compliance risks, violations or mistakes in good faith by our employees is encouraged and rewarded but never retailed with punishment or dismissal. Intentionally violating the export control regulations will result in dismissal from this company.
If you have any questions related to AIA’s Export Compliance Program or if you have doubts concerning the legitimacy of a transaction or if you want to report a potential violation, please contact our Export Compliance Officer at compliance@ai-armaments.com.
Questions about AIA’s Compliance Program?
Contact our Compliance Director at: compliance@ai-armaments.com
