Export Control Compliance

Principle Statement from BEA Americas, a Halma Company, regarding Export Control Compliance

BEA Americas complies with all applicable export, import and trade regulations as outlined below and as set forth by the government of the United States of America. This commitment extends to all countries in which, and all employees, customers and agents through whom, we conduct business.

All applicable laws and regulations pertaining to trade embargoes or economic sanctions imposed onto a country will be followed by BEA Americas.

BEA Americas products are intended to be used in the applications for which they were developed. Furthermore, BEA Americas does not conduct business with customers who sell to, or conduct business with, countries currently sanctioned with trade/export embargoes.

BEA Americas adheres to the rules as defined by the European Union regarding export/import regulations. Links are included below and subject to change without notification.

List of Countries Sanctioned by the United States:
https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx

European Union – Import Requirements and Documentation
https://www.export.gov/article?id=European-Union-Import-Requirements-and-Documentation

It is the corporate policy of BEA Americas., and its parent company Halma, to comply fully with the letter and spirit of these controls. Less than full-compliance with these controls will not be permitted, no matter how large the sale or how important the customer.

Governments worldwide control the export of goods, technology and software depending on:

1. The nature of the product or services;
2. The destination of the proposed export;
3. The ultimate end-use of the product or services; and
4. The end-user of the product or services.

• Exports of strategic goods and technology are generally controlled because of national security, foreign policy, international legal obligations, concerns about human rights, internal repression, or terrorism. Most countries now have sophisticated export control and sanction policies, which are updated regularly.
• Penalties for violations of these controls include significant monetary fines, criminal charges and imprisonment, the loss of export privileges, contractual penalties and logistical problems. In addition, negative publicity arising from charges being brought under the relevant regulations may cause long term damage to the reputation of BEA Americas.
• BEA Americas reserves the right to seek, to the fullest-extent possible, recompense for any costs, including but not limited to fines, legal expenses or damage to reputation, incurred as a result of our customers failure to follow the export, import and trade regulations of the United States and the European Union.

Additional Guidance:

The following are the categories of applicable regulations that influence export, import, and trade compliance Policies, Standards, and Procedures:

• Trade embargoes and economic sanctions prohibit or severely restrict business activities with certain countries and their nationals, as well as business activities with specifically-listed entities and persons.
• Export control regulations impose restrictions on the transfer of certain articles and technology to foreign destinations or persons.
• Anti-boycott regulations prohibit U.S. companies and their foreign subsidiaries from participating in unsanctioned boycotts against countries friendly to the United States. Some other countries and jurisdictions also maintain laws that prohibit compliance with unsanctioned foreign boycotts or embargoes.
• Customs regulations generally govern the many aspects involved in the importation of goods into countries. In virtually all countries this includes complex regulations concerning the classification, valuation, country of origin and marking of the imported goods. Customs regulations may also include the enforcement of partner government agencies’ regulations on imported goods, such as health care products, chemicals, or other regulated articles.
• Government procurement and various advertising regulations define rules for making certain country of origin representations.
• Tax regulations influence sales terms and the obligations of parties in transactions.
• Cargo security laws provide minimal security standards for ensuring the physical security of cross-border shipments.
• Free trade agreements are two-country or multi-country international agreements that provide for certain trade preferences and benefits to the participating countries when eligibility and certification requirements are satisfied.