2022 Code of Ethics - Page 46

EXPORT COMPLAINCE
BBNC must comply with export control restrictions established by the U . S . State Department and U . S . Commerce Department ’ s Bureau of Industry and Security , established to prevent sensitive goods , information , technology , and software from being used contrary to the foreign policy and national security goals of the United States .
“ Export ” is broadly defined and includes any method of conveying or transferring data to foreign individuals , companies , or locations including sales , training and consulting , product promotion and casual conversation , even if these activities occur in the United States .
Examples of “ exports ” that might arise include :
Sending defense parts to United States military installations abroad as part of a task order to complete work on the installations .
Your Responsibilities
Read the BBNC Export Compliance Policy .
Contact the BBNC Compliance Department and BBNC ’ s Empowered Official prior to the possible “ export ” of information , goods , products or services to foreign countries or foreign individuals to determine if a license or exemption for license should be obtained .
Conversations with a foreign owned company regarding entering into a subcontract with them to perform work on military installations .
Presenting a paper containing technical data at an industrywide conference where foreign nationals are present .
43