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Toshiba Group, based on its Export Policy, aims to comply with all applicable export control laws and regulations of the countries and regions where it operates, including Foreign Exchange and Foreign Trade Law in case of Japan and US export control laws and regulations with respect to transactions involving items of US origin. The Group also maintains a basic policy of not engaging in any transaction that could potentially undermine international peace and security.
In accordance with this policy, Toshiba Group has established export control programs. Based on these programs, the necessity of export licenses for goods and technology is determined and transactions are strictly screened. In addition to periodic export control audits and education for all executives and employees, in-house companies provide instructions and support to the group companies they supervise.
Toshiba Export Control Compliance Program
The program stipulates the following provisions to ensure compliance with Japan's Foreign Exchange and Foreign Trade Control Law and U.S. export control laws.
- Chapter 1 Statement of Corporate Policy
- Chapter 2 Definition of Terms
- Chapter 3 Export Control Organizations
- Chapter 4 Control Procedures
- Chapter 5 Education
- Chapter 6 Compliance Reviews
- Chapter 7 Notification of Violation and Corporate Sanctions
- Chapter 8 Group Companies
Toshiba's export control system is organized under the Chief Export Control Officer who has ultimate responsibility for the corporation's export control. The Chief Export Control Officer must be a representative director or an executive officer corresponding thereto. Under the Chief Export Control Officer, the Export Control Division is responsible for overseeing the export control implemented pursuant to the Toshiba Export Control Compliance Program (ECCP). Each Toshiba in-house company and corporate staff division has its own export control infrastructure led by the Export Control Officer who is in charge of the division. The Export Control Officer must be the president or executive vice president of the same in-house company or the general manager of the same corporate staff division.
Toshiba Group Export Control System  |
The purpose of product classification is to determine whether or not an export license from the Minister for Economy, Trade and Industry (METI) would be required for products to be exported. In Toshiba, product classification is conducted in individual divisions by qualified engineers who are familiar with technical background of products. The Export Control Administrator in charge makes review of classification results at each in-house company or corporate staff division. This review ensures that all classification results are consistent with the relevant laws and regulations.
The purpose of the transaction review is to ensure that our products are not destined for end-uses or end-users of concern, regardless of whether they are restricted or not restricted under the relevant laws and regulations. Sales sections at in-house companies and corporate staff division are required to carry out this transaction review for each transaction. Review results must be double-checked and approved by the Export Control Administrator in charge. In addition, transactions requiring an export license from minister of economy, trade and industry or destined for a country or region of concern are subject to thorough review and approval by the Export Control Division.
The division conducts the transaction only after receiving export license from minister of economy, trade and industry or the US Government, where necessary.
To ensure that group companies are appropriately implementing their export controls in compliance with the relevant laws and regulations, the Export Control Division conducts periodic export control audits of in-house companies and group companies supervised by corporate staff divisions. In-house companies conduct similar periodic audits of group companies they supervise. Group companies that were determined to require corrective measures would be required to develop and submit their corrective action plans. Effectiveness of each corrective measure will be evaluated by the Export Control Division or the supervising in-house company.
Training courses on export controls (regular and specialized courses) are conducted at in-house companies and group companies to educate employees on the importance of export control and to raise awareness and knowledge of the Toshiba Export Control Compliance Program (ECCP) and related internal regulations.
In fiscal 2008, following the introduction of conventional arms catch-all regulations, Toshiba provided export control education through an e-learning system.
Export controls at group companies including those located overseas are modeled after that of Toshiba, which is implemented under the Toshiba Export Control Compliance Program (ECCP). Export control audits are conducted periodically to evaluate their performances.
The Export Control Division convenes a monthly meeting with the in-house companies and key group companies. Besides providing information on relevant international situations and regulatory trends, or advices on specific issues, this meeting also provides a forum for exchanging related information and opinions. In-house companies provide guidance on export controls and related support to group companies they supervise.
In addition, in order to reinforce the support to overseas group companies, we have been conducting workshops for the persons-in charge of export control in South-east Asia and China since 2006. In 2008, we extended such workshop to Europe.
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