The Trade Compliance Program at Westinghouse ensures adherence to laws and regulations controlling the export and import of goods, software, and technology across all borders. Our employees should comply with the Global Trade Compliance Company Directive, and regional and local policies and laws in countries where we do business. Trade Compliance can be broken into several different subject areas, as follows:
Employees are required to comply with export control laws in all countries in which we do business. As US export control laws continue to apply to exported US goods and technology, all Westinghouse sites globally must comply with both local and applicable US export regulations.
Westinghouse complies with import laws in all countries in which we do business, including classification and marking requirements. Preferential duty programs are utilized to maximize cost savings for our business and our customers.
At any time, a country may decide to restrict trade with certain countries, entities, or individuals. The penalties for violating these restrictions can be very serious. Westinghouse complies with all legally mandated embargoes and sanctions.
Westinghouse and its non-U.S. subsidiaries, offices, and affiliates shall not participate in any economic boycott that is contrary to US anti-boycott laws. Westinghouse reports any such requests to the US government, as required by law.
Contact Global Trade Compliance to seek guidance or report non-compliant trade practices such as:
Yes. All Westinghouse locations globally must comply with US sanctions and embargoes, in addition to local export laws. Contact the Global Trade Compliance group for guidance as needed.
This is a potential problem, and depending on other facts, it may be illegal for the Company to supply such information due to US anti-boycott laws. You should check with the Global Trade Compliance group before proceeding.
Situations like this must be reviewed on a case by-case basis. While the initial transfer under this contract may not require a license, any subsequent re-transfer of the product(s) or technology may require a license. Westinghouse’s standard export control language does not permit the subsequent re-transfer without prior consent so that Westinghouse may review the new transaction to determine if an export license is required.
A refusal to engage in business with another party.
An embargo is the partial or complete prohibition of commerce and trade with a particular country or a group of countries. Embargoes can mean limiting or banning export or import; creating quotas for quantity; imposing special tolls or taxes; banning freight or transport vehicles; freezing or seizing freights, assets, or bank accounts; or limiting the transport of particular technologies or products.
The entity that receives and ultimately uses the exported or re-exported items. The end-user is not an authorized agent or intermediary.
Exports include: (a) physically or electronically sending a good or technology across an international boundary or providing a service to a recipient in another country; or (b) disclosure of information to a person of foreign nationality, which is deemed to be an export to that recipient’s country regardless of his or her location. Deemed exports can be made by physical delivery, email, facsimile, plant tours, demonstrations, on-the-job or other technical training, briefings, teleconferences, provision of technical assistance, or computer access (remote, WAN/LAN) as user or IT administrator, regardless of location.
The authorization by an export agency authority to proceed with a regulated activity (e.g., export, re-export).
An import is a good or technology brought into one country from another. When importing, all Company employees must comply with applicable laws and regulations, which address matters such as classification of goods, marking and labeling of goods, valuation of goods, payment of duties, data filing, and recordkeeping
Sanctions, or trade sanctions, are trade restrictions imposed on certain persons, entities, or industries, or on certain activities.
