The Foreign Exchange and Foreign Trade Act was established based on international agreements controlling exports of goods and transfer of technology with the aim of maintaining international peace and security.
In order to comply with this act and other related laws and regulations, and to prevent involvement in activities that may raise concerns, we established the compliance program (CP) regarding export-related laws and regulations in 1988 as an internal rule that specifies a series of procedures related to export and technology provision and also registered it with the Ministry of Economy, Trade and Industry.
Based on this CP, the Compliance Section of manages export operations, provides education and training, and conducts internal audits.
We have also established detailed regulations on specific procedures for departments that are subject to export control operations, and conduct business operations in accordance with these regulations.
In addition, we have an operation manual and provide education on how to comply with the U.S. Export Administration Regulations (EAR), which are administered by the U.S. Department of Commerce as regulations that may be applied extraterritorially outside of the U.S.
The Compliance Section of the Legal Department oversees company-wide export control.
Under the direction of this section, export control managers in each export-related division perform export control operations to strengthen the control system.
The training on export controls is provided to new employees training as the basic training course so that they can grasp the basic knowledge of export controls. Furthermore, all the engineers who have finished the above basic course are required to take the special training course in order to have knowledge necessary for the determination of the classification for goods and technologies as to whether they shall be subject to export licenses.
Investigation and Classification
Based on the above mentioned CP, the examination or investigation on the export managements are performed as follows:
• Business development departments investigate the end-users conditions
• Procurement departments investigate the vendors and subcontractors conditions
• Project teams and supporting departments perform the classification in accordance with the export control manuals which are corresponding to the Japanese and U.S. requirements respectively.
No items should be shipped out unless the required screening has been completed.
Based on the CP, the Compliance Section, Corporate Services Department is to annually audit the relevant documentations and the implementation situations on the export controls in each organization.