Corporate principles governing internal export control on Non-proliferation of WMD and their means of delivery
NORINCO 2006
NORINCO holds firmly the position that proliferation of WMD and their means of delivery is conducive neither to world peace and stability nor to China¡¯s security, and is absolutely in contrary to its value of a responsible corporation for the benefit of international community.
NORINCO affirms its unequivocal and emphatic support for Chinese government¡¯s policies regarding non-proliferation of Weapons of Mass destruction (WMD) and their means of delivery. As an authorized defense products and services supplier, in recognition of the sensitive nature of its core business, its responsibility of non-proliferation and its obligation of export control compliance, NORINCO commits to abide by Chinese government¡¯s non-proliferation and export control laws and relevant law enforcement fully and uncompromisingly.
Effective export controls must be a combined effort between governments and companies. In response to Chinese government¡¯s endeavor to strengthen non-proliferation and export control law enforcement, NORINCO chooses to take the lead of non-proliferation and export control compliance on corporate level. Under the guidance of Chinese government agencies, specifically Ministry of Foreign Affairs, Commission of Science, Technology and Industry for National defense (COSTIND) and Ministry of Commerce (MOFCOM), by adopting international best practice, NORINCO actively pursues a sound internal compliance program (ICP), which proves to be a major improvement for corporate internal control in compliance with Chinese government¡¯s law enforcement requirements, such as export registration, license, end-user and end-use certification, control list and relevant export control examination and approval.
All NORINCO employees will actively assist in the achievement of the corporate goal of export compliance. In particular, NORINCO employees involved in the export of the company¡¯s products, technology, and services will be familiar with, and strictly abide by, all applicable provisions of export control laws and regulations. NORINCO holds all executives of export-related divisions and subsidiaries account for the responsibility of non-proliferation and export control compliance.
By taking catch-all principal for export control, NORINCO attaches clear-cut and unambiguous priority to the goal of non-proliferation of WMD and their means of delivery over commercial interests. In practice, this means that even if a particular export transaction is legal according to export control laws and regulations, NORINCO ¨C in accordance with its corporate policy of voluntary self-restraint in export matters ¨C will neither directly nor indirectly supply products, technology or services if NORINCO has reason be believe that such items could be used by its customer or end-user for the development or production of WMD and their means of delivery.
In order to ascertain what products, technology and services, as well as which customer and end-user, should be regarded as sensitive, NORINCO will establish and maintain contact with all responsible Chinese government agencies, relevant NGOs and non-proliferation and export control experts for information, instruction and advice.
Proliferation of WMD and their means of delivery represents a global challenge, NORINCO deems it a necessity to confront the challenge through international cooperation. International community should enhance mutual understanding through confidence building. NORINCO attaches importance to and actively participates in international best practice sharing and cooperation on non-proliferation. For the purpose of continuous improvement of its internal compliance program, NORINCO is open to cooperate and share compliance knowledge with its international peers, non-proliferation research institutes as well as foreign government agencies.
This policy applies to all divisions and subsidiaries of NORINCO worldwide. The principles incorporated herein have been fully implemented within the framework of NORINCO¡¯s existing internal compliance program. This policy will continuously be reviewed and audited in order to incorporate the latest development of non-proliferation and export control.
