Export Management and Compliance Policy
The United States has a statutory and regulatory system for controlling and monitoring the movement of certain goods, information, and technologies. Among other things, the system is designed to minimize the risk of diverting such items to locations which, are not in the best interests of the United States.
It is of the utmost importance to Deep Hole Specialists that the laws and regulations governing the movement of these goods, information and technologies be followed. This will allow Deep Hole Specialists to maintain its good corporate citizenship status, avoid inadvertent violations, costly errors, and the possible disruption of business.
It is the policy of Deep Hole Specialists to fully comply with all laws and regulations governing the export of its products, services, software and technical data. Each employee, therefore, must be dedicated to ensuring such compliance with government regulations. All sales, service, shipping, engineering, accounting and other personnel are required to be familiar with, and review regularly, the Deep Hole Specialists Export Management and Compliance Program. In addition, all contractors and consultants are required to be familiar with, and review, the Deep Hole Specialists Export Management and Compliance Program. Take particular attention when releasing technical information to foreign nationals, electronic transmission of data and/or software, and the shipment of products outside the United States.
No transactions are to be conducted by or on behalf of Deep Hole Specialists contrary to U.S. export control laws and regulations, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). Under no circumstances shall these laws and regulations be compromised for commercial gain. Neither sales nor shipments are to be made to any individual or firm appearing on any of the Denied Parties Lists, or to any firms owned by or associated with the individuals or firms therein listed.
Some of Deep Hole Specialists goods, information, and technologies can be adapted or used for military purposes. Other goods, information, and technologies have both civilian and military applications. The U.S. export regulations govern many of these items. These regulations are in place to prevent the distribution of goods, information, and technologies that can compromise national security. In some cases, even the unauthorized transfer of low-level goods, information, or technology can potentially jeopardize national security or further the development of weapons of mass destruction.
The regulations are very precise, and compliance with them is mandatory, not voluntary. No employee, consultant, or contractor has the authority to act contrary to this program, nor direct, authorize, or condone violations of the program by any other employee, consultant, or contractor.
Export compliance is a daily exercise. Noncompliance is very costly. All Deep Hole Specialists employees, consultants and contractors are required to comply with the policies and procedures outlined in this Export Management and Compliance Program. Any employee, consultant or contractor who has knowledge of facts or incidents, which he or she believes may violate U.S. export regulations or this program, whether intentional or accidental, is required to report the matter promptly to the Export Compliance Officer.
Violations of U.S. export laws can subject Deep Hole Specialists and its employees, consultants and contractors individually to severe penalties, including fines, denial of export privileges, and even imprisonment. Any employee, consultant, or contractor who violates such laws, or who knowingly permits a subordinate to violate such laws, will be subject to appropriate disciplinary action, up to and including termination.
It is important to recognize that terms like “classification” and “classified,” when used in conjunction with this program do not refer to military designations for Classified, Secret, or Top Secret work. Instead, “classification” in this program is used to describe the process by which Deep Hole Specialists identifies the status of work being performed, relative to U.S. export regulations. Take separate controls and precautions when handling Classified, Secret or Top Secret work.
All questions regarding export compliance and how it impacts your job, as well as any question concerning the legitimacy of any transaction, violation, or potential violation should be immediately referred to the Export Compliance Officer.
