BBNC Code of Ethics Code of Ethics_JooMag | Page 36

EXPORT CONTROL RESTRICTIONS
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:
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 industry-wide
conference where foreign nationals
are present.
as part of a task order to complete
work on the installations.
Your Responsibilities
Contact the BBNC Compliance
Department 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.
ANTI-BOYCOTT LAWS
United States anti-boycott laws and
regulations discourage and, in some
cases, prohibit U.S. companies from
furthering or supporting foreign
boycotts that the United States does not
sanction. This has particular application
to dealing with Arab countries and
others who may participate in a boycott
of Israel. U.S. companies are required to
report requests they have received to
take actions to comply with, further, or
support unsanctioned foreign boycotts.
Sending defense parts to United
States military installations abroad
34
BBNC Code of Ethics | Ethics Hotline: [phone] | Effective May 17, 2019 | www.bbnc.net
Operating with
Export Controls
Q: My subsidiary recently
obtained a contract where
we are responsible for
transporting electronic records
to the Middle East. Do I need
to seek guidance from the
Compliance Department?
A: Yes, an export occurs
when there is a transfer to
any location outside of the
United States or to a non-
U.S.person, whether within
or outside of the U.S., of
controlled commodities,
including technology by
physical, electronic, oral,
or visual means.
BBNC subsidiaries that
engage in the export of
controlled commodities,
including technology, must
seek guidance from the BBNC
Compliance Department to
ensure that the proper license
or exemptions are obtained.