Trade Compliance - How it works - ExportManager · that the Supply Chain Management department will take over responsibilities to set-up and provide worldwide Trade Compliance Management

Trade Compliance Management

How it works!

A practice sharing by Burkhard Ballmann,

Export Control Officer of Redknee Inc.

© Copyright Redknee Inc. 2015

Largest independent provider of next-gen real-time converged billing, customer care & analytics software for service providers

250+customers across100 countriessupporting 2,2B+ subscribers

< 2 >< 2 >

WHAT WE DO

(On-premise & cloud-based solutions)

Charging & policy for all transactions (Social media, data,

messaging, voice, etc.)

Rating, charging & customer care for subscriber types across any communication platform:(Mobile, fixed, broadband, cable &

satellite)

149+Patents granted with 37+ filed

1900employees

The beginning

2013 - Aquisition of NSN BSS by Redknee

Redknee (Germany) founded

< 3 >

The beginning

NSN Trade Compliance Team

Redknee take care of TCM!

< 4 >

The beginning

Basic training

Legal actions (BAFA, IHK, Customs)

ECO announcement

< 5 >

ECO Announcement

›All,

› In reference to the announcement of …. as of 2013-29-07 I am pleased to announce that the Supply Chain Management department will take over responsibilities to set-up and provide worldwide Trade Compliance Management at Redknee.

›

›The following responsibilities have been added to the department Supply Chain Services and are effective immediately:

› Supply Chain Services – Trade Compliance Management: Responsible for the management of all activities associated with Trade Compliance (including Export Control)

› This group will be built up and led by Burkhard Ballmann, supported directly by me. Burkhard is also technically nominated to take the role and responsibility of the Export Control Officer of Redknee Inc. and all its affiliates. In this role Burkhard will also report to Sabine Domes, Managing Director of Redknee (Germany) GmbH, in her official role and responsibility as Export Officer of Redknee (Germany) GmbH.

› …….

< 6 >

Export Control Legal Framework

Redknee Inc. and all its affiliates must comply in all corporate processes

to national and international Export Control Legislation!

Redknee Export Control Processes

Redknee Interpretation and Commitment

Multilateral Export Control Regime and intergovernmental

organizations

Wassenaar Arrangement, UN ,

OSCE

EU Dual Use Regulation, EU

Embargoes

Process for EU and Germany

US (EAR/BIS/OFAC)

Process for US and Canada

Other national legislation

Processes e.g. for India, Poland,…

< 7 >

Customs Compliance Legal Framework

Redknee Inc. and all its affiliates must comply in all corporate processes

to national and international Customs Compliance Legislation!

Redknee Export Control Processes

Redknee Interpretation and Commitment

Multilateral Customs and Trade organization

WTO, WCO

EU Customs Code

Process for EU and Germany

Canada Border Services Agency

Process for Canada

Indian Central Board of Excise

and Customs

Process for India

Other national legislation

Processes e.g. for Poland,

USA, ...

< 8 >

Goals

1. Implementation of Trade Compliance in all operative business units of Redknee.

2. Installation of a Corporate Trade Compliance Process (perpetual & audit safe).

3. Organizational set-up and definition of MoO

4. Make Redknee independent from NSN asap.

< 9 >

Time table

1) Ramp Up

• Legal actions

• ECO-substitute

• Cross-corporate team

• EC-consultant

2) Implement

• Implement ECO Project Plan

• Draft Trade Compliance Process, Corporate MoO and Training Plan approval

3) Operate

• tbd as per results of Phase 2)

Trade Compliance Management @ Redknee

< 10 >

Redknee Export Control Interfaces

< 11 >

Export Control

Finance(Incoming

and Outgoing

Payments)

SCM Logistics

(Transaction checks)

SCM Procurement

(Contract T&Cs, Export

License issues)

R&D, Product

Management

(ECCN)R&D

(Product offering)

Sales operations

(end use/user

validation)

HR(screening of personnel)

COO Operations& Support

(ECCN)

Compliance to national and international Trade Legislation is not limited to Supply Chain related operations, but must be ensured company wide on all trade related operations!

A company wide, integrated and comprehensive action through out all Redknee business units is inevitable!

A company wide task force under the lead of Redknee‘s Export Control Officer has worked-out the respective requirements.

TCM-Task Force – Timeline

2010 201108/13

E09/13

E11/13

E02/14

E12/13

09/13 10/13 02/1401/1412/1311/13

Kickoff

Development of process model, MoO, training plan

Preparation of internal training material

Employee training

Establish processes (rollout, publishing)

Analyze impacted roles/processes and departments

E02/14

Approval of process model, MoO and training plan by Management

E12/13

M09/13

< 12 >


2010 201108/13

E09/13

E11/13

E02/14

E12/13

09/13 10/13 02/1401/1412/1311/13

Kickoff



Employee training



E02/14


E12/13

M09/13

< 13 >

Finance:

Outgoing payments - to be checked against sanctioned parties

Logistics/ Supply Chain:

Transaction checks – all conditions fulfilled before shipment

Procurement:

Contract Terms & Conditions

Screening of suppliers / partners

< 14 >

Roles in Export Control

Product Management:

Target Countries for product (US content calculations if

necessary)

Decision on Country of Origin (CoO)

R&D:

ECC Statement for Product

Classification of own and 3rd products incl OSSW

< 15 >


COO Operations

Detection of end use violations (usage of product by customer

as originally confirmed; prevent malpractice )

Update of ECC Statement for Customer projects

US content calculations for Customer projects

COO Support (incl. Service):

Detection of end use violations (usage of product by customer

as originally confirmed; prevent malpractice )

SW-provisioning (incl TransactionCheck)

Maintenance Licenses

< 16 >


Sales:

Product offering – check end users and end use

Sanction party screening

Transfer of technology (conferences with foreigners or in foreign

countries, presentations, trainings)

Require export licenses from TCM

HR:

Screening of own employees

< 17 >


Trade Compliance (TC) team:

Implementation of TC processes at all Redknee entities

Rollout of TC processes at Redknee incl. continuous trainings

Supervision of compliance (audits, regular checks)

Ensuring the company complies with export control and

customs

Single point of contact to legal TC authorities (reports, applying

for licenses)

Scanning of laws and regulations with respect to TC

Responsible for export and customs classification for products

< 18 >


Trade Compliance (TC) team:

Implementation of TC processes at all Redknee entities

Rollout of TC processes at Redknee incl. continuous trainings

Supervision of compliance (audits, regular checks)

Ensuring the company complies with export control and

customs

Single point of contact to legal TC authorities (reports, applying

for licenses)

Scanning of laws and regulations with respect to TC

Responsible for export and customs classification for products

< 19 >


TCM – Roles and Responsbilities

Roles involved in Trade compliance: Overview

SCM Operations

SCM Services

COO Operations

COO Support COO Sales R&D Others

Product Structure Manager (PSM)

Export Control Officer (ECO)

Project Manager (PM)

Product Manager Support (PMS)

Account Manager (AM)

ECC Support Manager (ECSupM)

Central Export Control Officer (CECO)

Delivery Capability Manager (DCM)

Export Control Manager (ECM)

Care Program Manager(CarePM)

Software Delivery Responsible

Sales Engineer (SLE)

Program Manager (ProgM)

Product Manager (ProdM)

Supply Chain Project Manager

Customer Solutions Architect (CSA)

Service Engineer

Developer, Technical Specialist

Procurement Responsible

Technical System Configurator (TSC)

CustomerDocumentation Manager

Finance-Staff

Human Resources

20

BISBAFAAV / CECO

ECO ECMHead SCM-S

1.

2.3.

8. 4.

5.

7. 6.

SCM

Other departments

HR Sales

Product ManagementSCM Operations

SCM Procurement

9.

ECSupM

R&D

COO Support

COO Operations

1. Official Authority in contact

to BAFA (= AV)

2. License Applications,

sending reports to BAFA

3. Substituting AV;

Dotted report,

Escalations

4. Direct report;

Escalation,

Substituting ECO

5. License Applications, Info

Requests,

6. EC-Classification;

Preparation of ECC

Statement for Approval

7. Approval of ECC Statement

8. Direct report

9. Information and Support

< 21 >

Export control main roles – Germany

9.

9

BISLocal legal authority

Country Director

ECO ECM

ECSupM

R&D

Head SCM-S

1.

2.3.

8. 4.

5.

7. 6.

SCM

Other departments

HR Sales

Product ManagementSCM Operations

SCM Procurement Others …

9.

1. Official RedKnee contact to

local legal authorities

2. Reporting

3. Support

4. Direct report;

Escalation,

Substituting ECO

5. License Applications, Info

Requests,

6. EC-Classification;

Preparation of ECC

Statement for Approval

7. Approval of ECC Statement

8. Direct report

9. Information and Support

< 22 >

Export control main roles – in general

9

Purpose of the role:

• Offers programs expert knowledge about and assistance in ECC issues

• Review and approve of ECC statement

Role: Export Control Officer

Reporting lines: ECC, CECO and BU Support head

Additional Notes (e.g., guidelines, etc):

• n/a

Role Description: Export Control Officer

Key responsibilities / tasks (including key areas or activities and work products)

• Giving answers to specific questions

• Gives company wide guidelines for export control and customs compliance

• Approves ECC statement

• Takes care of sending applications towards authorities

• Is the main contact towards authorities and to CECO

• Supervision of all export and import related activities

• Checks which export licenses for the R&D phase are missing and performed license application towards

authorities

• Defines trainings for trade compliances

23

Purpose of the role:

• Offers programs expert knowledge about and assistance in ECC issues

• Review and approve of ECC statement

Role: Export Control Manager

Reporting lines: Export Control Officer

Additional Notes (e.g., guidelines, etc):

• n/a

Role Description: Export Control Manager

Key responsibilities / tasks (including key areas or activities and work products)

• Giving answers to specific questions

• Gives company wide guidelines for export control and customs compliance

• Approves ECC statement and releases Sales Items

• Takes care of sending applications towards authorities

• Is a contact towards authorities (main contact is ECO)

• Supervision of all export and import related activities

• Checks which export licenses for the R&D phase are missing and performs license application towards

authorities

• Defines trainings for trade compliance

• Monitoring validity period of licenses in maintenance phase; contact CarePM to agree to license

prolongation

24

© Copyright Redknee Inc. 2014 < 25 >

Customs: Main tasks and responsibilities

Sales

Incoterms (agreements

with customers)

Contractual conditions

Import restrictions

on customer side

Delivery

Customs clearance (ATLAS,

documents)

Tracking of delivieries

and related statistics

Incoterms (practical handling)

Finance

Turnover taxes, tolls

Invoices

Mainte-nance of financial

data

Development

Origins and preferences

of own products

Tariff numbers

(HS code)

Procurement

Certificates of Origin

from suppliers

Import procedures

and conditions

Trade Compliance

Prohibitions and

restrictions

Redknee Customs Interfaces


2010 201108/13

E09/13

E11/13

E02/14

E12/13

09/13 10/13 02/1401/1412/1311/13

Kickoff



Employee training



E02/14


E12/13

M09/13

< 26 >

What on earth is Export Control ?

< 27 >

8-2

28

Internal Compliance Program – detailed

Audits andMonitoring

Ongoing trainingand information

Organization andMoO

Sufficientresources

Compliance violations

End User Statement (EUS)

End use screening

End userscreening

Destination screening

Classification ofproduct

Writtenprocedures

Record keeping

Scan laws andregulations

LicenseApplication (IVL)

Screening

Embargoe listsSanctioned party

listsProduct lists

Laws andregulations

Embargoes

Transaction check

Management commitment

Authority

Management representative

Sanctioned Party screening

ECC Process

ECC Statement

Supplier screening(Sub)Contractor

screening

Update ofprocesses

Redknee‘s Processes, Guidelines, Templates …

publish

Visitor screening

Personal/Staffscreening

Customerscreening

delivery

Supplier, (Sub-) contractor

screening

LicenseApplication

Training plans, material

End User Information

Compliance Manual

delivery

Information on laws/regulations

Audit plans, Guidelines

TC Policy Record guideline

BAFA (Germany)

Others …

SCOMET (India) BIS (USA)Ministerstwo

gospodarski (Poland)

European UnionGuidelines for

compliance

provides

End User Statement (EUS)

ECC Statement

SW-Guideline forprovisioning

SEMA (Canada) Legal authorities

How classification occurs

< 29 >

Redknee components

Creation of components by specialists (e.g. R&D, Maintenance

team)

First classification by creator, TCM supporting

Finally release of classification by TCM

Item together with classification (ECCN) added to ERP-system

Bought components (OEM)

Selection of components by specialists (e.g. Product

Management, R&D)

Supplier provides classification, tracked by specialist, TCM

supporting.



Open Source Components (OSS)

Selection of OSS component by specialists (e.g. R&D, Maintenance

team)

Supplier provides classification, followed up by specialist, TCM

supporting.



Handling of OEM-list during sprint

< 30 >

Sprint n

OEML taken from

sprint n-1

Continuous update of

OEML

Freeze OEML at sprint end

Adding new entries

Requested by R&D; checked by R&D-responsible, added to OEML with mark „new“;

Modifying existing entry

Requested by R&D; checked by R&D-responsible, added to OEML with mark „change “ or „delete“;

Continuous involvement by ECM, Procurement,

security, ...

OEML:

OEM-list

ECM:

Export

Control

Manager

Old version of OEML taken, all change marks from former version removed

OEML taken from

sprint n

Sprint n + 1

Review and release of

OEML

Same procedure as sprint n .....

Continuous update of

OEML

ECC statementcreated by

TCM

ECC-statement and OEML

published on release page

Embargo is political-commercial sanction against the country or entity.

Embargo is a prohibition or limitation on exporting.

As embargoed destinations are regarded as those countries which are embargoed, totally or partially, by the UN, multilaterally by the EU and the OSCE or unilaterally by any of the controlling countries.

Separate embargoes rules specifically for:

1. Items (products)

2. Destination countries

3. Customers

4. Persons (individuals and entities)

Present embargos affecting Redknee’s exports:

1. EU embargoes

2. US sanctioned countries

Subject of regulation – Sanctions & Embargoes

< 31 >

http://eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf

http://www.bis.doc.gov/index.php/policy-guidance/country-guidance/sanctioned-destinations

It is planned to introduce a Screening-tool at Redknee. As long as this tool is not available TCM will perform all screening on demand

How screening occurs – no screening tool

< 32 >

New customer, screening ordered by Sales

New supplier, screening ordered by

Procurement

Other new contact, Screening ordered by

specialists

TCM performs screening

No match, proceed as planned

Match, TCM decides about further handling

In case a screening tool is available stakeholders can do it by themselves.

How screening occurs – screening tool

< 33 >

New customer, screening performed by Sales

New supplier, screening performed

by Procurement

Other new contact, Screening performed

by specialists

Stakeholders perform

screening

No match, proceed as planned

Match, inform TCM, they

decide about further

handling

Most control is exercised via the export licensing procedure. Basic rule is that whenever controlled products are subject of a planned export, export authorization is always needed in advance.

The ultimate requirement for an export license is based on:

o Trade policy of the exporting country regarding the country of destination

o Export classification of the products (ECCN)

o End user and end use of the goods

Authorization can be a general license or an individually applied license

Licenses are approved by authorities of country where export occurs

Export Control Licensing

< 34 >

US Embargo EU Arms Embargo Excluded from AG 16

Cuba Armenia Afghanistan

Iran Aserbaidschan Angola

North Korea Belarus Burundi

Sudan Central African Republic Egypt

Syria Congo, Democratic Republic Ethiopia

Cote d'Ivoire Mozambique

Eritrea Nigeria

Iran Pakistan

Irak Syria

Lebanon Tanzania

Liberia Thailand

Libya Uganda

Myanmar Ukraine

North Korea Usbekistan

Russian Federation Venezuela

Somalia Yemen

South Sudan

Sudan

Syria

Zimbabwe

Country chart

TCM 35

Last change of country

list: 8.4.2015 (see history)

US Embargo:

No export

possible

Individual Export License needed.

Application needs up to 3 months!

1) For Crimea and Sevastopol please

refer to slide 7 for more information.

1)

1)

Controlling the spread of weapons or terrorist uses may be the most important reason for export controls.

Redknee is not a weapons manufacturer. However we need only read about cellular communications being used anywhere to detonate improvised explosive devices to understand that the end use is important to be checked.

In case an export license has to be applied for we have to provide an „end-user-statement“ written by the customer on their own official paper.

Who takes care of the End User statement

TCM• Provides prepared EUS

and hands over to Sales

Sales• Requests completed

EUS from customer

Customer• Finalizes EUS

and sends to Sales

Authoritity

• Uses EUS for license application

TCM

Sales• Hands

over EUS to TCM

< 36 >

Export Licenses – General licenses

There are different type of licenses valid for Redknee: General licenses and individual licenses.

General Licenses (EU) or License Exceptions (US) - may be used by all exporters, pre-registration with authorities may be required. The requirements are set by the individual country, and are ECCN, product, and/or destination specific.o Sample 1: EU001 (Europe): Export to following countries normally does not require an

individual license: Australia, Canada, Japan, New Zealand, Norway, Switzerland, United States of America

o Sample 2: AG 16 (Germany): Export of most telecommunication items does not require an individual license if

• the end use is clarified without any doubts and

• the destination country is not subject of an arms embargo and

• the destination country is not Afghanistan, Yemen, Pakistan, Syria or Uzbekistan.

So for an export from Germany to Yemen neither EU001 nor AG 16 can be used –an individual validated export license is needed.

< 37 >

Export Licenses – Individual Licenses 1

An Individual Validated Export License (IVL) is a document authorizing the export of commodities for which written export authorization is required by law (US, European or any other).

If a general license can’t be used the application for an IVL must be made by the exporter and approved by the appropriate authorities prior (!) to export.

The application for an IVL is always done by TCM. TCM also decides whether an IVL is needed or a general license can be used instead.

< 38 >

• End User Statement• Bill of Material• Purchase Order or

contract from customer

• Technical descriptions

Project• Collects all needed

documents• Creates and sends

the license application to authority

• Informs project

TCM• Decides on license

application and informs TCM

Authority

Export Licenses – Individual Licenses 2

Take care of the following:

o Application for an individual validated export license (IVL) needs up to 3 months or longer!

o Inform TCM as early as possible about planned exports and clarify with us which licenses are needed.

o Give all support to TCM which is needed to apply for an IVL by providing the needed documents (End user statement, contract or purchase order, bill of material, technical description.

o Incomplete document delivery causes delay in license application.

o Export without the IVL is forbidden by law! We have to wait for the license before we are allowed to deliver any listed good.

< 39 >

Export Licenses – IVL timeline

< 40 >

Preparation of documents

Start project

Apply for IVL

Result of application

Get needed documents:

1. End User statement (EUS)

2. Customer contract / PO

3. Final Material list (BoM)

Customer

weeks - months

Authority is working on application

Up to 3 months

No delivery before this

point!!!

41

IVL Process Overview / Flowchart - 1

Export License Application processSubmissionPreparation


TCMExport Control



Supply Chain PM

COO Support SW delivery

0.2 Pre-check, if IVL is needed

0.3 Check if IVL is needed

1.1. Fill in IVL application request template

1.0. Provide IVL application request template

1.2. Prepare needed documents

1.3. Provide technical documents

2.0. Send application request template to TCM

2.2. Send original EUS to TCM via courier if needed

2.1. Review IVL application request template / documents

3.0. Submit IVL to relevant authorities

3.1. Handle requests from authority

License handling by authorities

1.4. Provide material list (BoM)

0.0 Screening

0.1 Check screening result

1)

2)

1) Stop activity in case screening provides sanctioned party2) Proceed in case IVL is needed with 1.1, otherwise

continue with 5.0.3) See description; in this case there are activities needed in

step „delivery“ (see 6.4)

CarePM

PMS

0.4 Check if BAFA-report is affected

3)

42

IVL Process Overview / Flowchart - 2

Export License Application processValidation Delivery


TCMExport Control



Supply Chain PM

COO Support SW delivery

4.1. Check and confirm license riders and conditions

4.0. Inform AM about license riders and conditions


Maintenance

CarePM

4.2. Inform AM about license validation

o.k. to order

5.0. Ordering

6.0 Transaction check

6.3 Securing the needed export customs clearance

6.1. Project-specific ECC-Statement

7.0, License riders and conditions fulfillment

8.0. Submit provided documents to authorities

9.0 Supervise License validation period

9.1 Agree with TCM about needed license prolongations



9.2 Start with 0.0 in case of new contracts

PMS

9.3 Supervise needed support contract prolongations

9.3 Supervise needed support contract prolongations

Back to 0.0 in case of new licenses are needed

4)

5)

6.4. Prepare data for BAFA-report

6.4. Prepare data for BAFA-report


5)

5)

6.2 check, if new IVL is needed

6)

6)

4) Proceed in case license validation by TCM is ok; otherwise further clarification is needed dependent on validaton result; worst case is to stop delivery

5) Responsibilities for Transaction Check depends on different cirumstances; see explanation at related slide below

6) Optional step: In the very rare cases of ECC-relevant changes by development a new license might become necessary. See description of 6.2.

The US government claims exterritorial application of all US export control regulations for items which have US content. They call it „the goods are subject to the EAR“ (the US Export Administration Regulation).

„Subject to EAR“ are goods which have US origin, whereever there actually are located or

have been created outside the US but contain a certain percentage of US goods (so called „de minimis“) or

were created by using US-technology and is used in certain countries or

are located in the US.

In practice this means that, if export is planned for goods which have controlled US-content, a license from the US authorities is needed, even when the export occures from e.g. Germany, India, Poland or Canada. The US authorities call this a „re-export“.

US law

< 43 >

Transaction Checking

Prior to any delivery an export control transaction check has to be performed. This check covers all single topics of a planned delivery and checks them in combination, i.e.

Content of delivery (listed goods?)

Sanctioned Party List and Embargo screening

Export license needed & available?

In case the check indicates any violation TCM will block the export for non-approved sales orders/deliveries.

Transaction check has to be done for deliveries including HW as well as for any pure SW delivery. In scope are first deliveries and all updates, i.e. SW Updates, HW spare parts etc.

In future transaction check will be performed automatically by the ERP-system in combination with the transaction check tool EoD by Amberroad. Currently each delivery has to be checked manually by TCM on demand.

< 44 >

3rd

PartiesGoods

45

TCM-Task Force – Overview on Results

Redknee Inc. Operational Processes

Accordance to TCM Manual

(Internal Compliance Program ICP)

Transaction check on all goods to be

delivered

Screening of any 3rd party

prior to contracting

RESULTS


2010 201108/13

E09/13

E11/13

E02/14

E12/13

09/13 10/13 02/1401/1412/1311/13

Kickoff



Employee training



E02/14


E12/13

M09/13

< 47 >

48

To be approved – 1) TCM Manual

TCM Manual and TCM-process definition

1) Reviewed by TCM Task Force, Ready for Approval

2) Commitment to BAFA-recommended guidelines for „Internal Compliance Programs ICP“

3) TCM process definitions are embadded within TCM Manual

Approved

49

To be approved – 2) Authorizations of ECO

Authorizations of ECO in terms of Trade Compliance and Export Control1) Sole and exclusive Instance to all other departments

2) Creation of work instructions and organizational instructions

3) Check and organize admissibility of export operations in (customs and) foreign trade law terms in daily business by using of appropriate IT systems

4) Continuous training in order to implement the constant changes in the customs and foreign trade regulations at Redknee. This includes basic training and refresher periodically update training as well as specific courses for material master data classification regarding export list and possibly U.S. Export Control

5) Permanent training for TCM staff and all employees

6) Acquisition and updating of customs and foreign trade of relevant literature

7) Organization, adaptation and ensuring compliance with contractual export control clauses in the contract design

8) Development, construction and integration of customs and foreign trade processes as well as auditing the Trade Compliance processes internally on a regular basis in all Redknee organizations at all Redknee legal entities (internal export control audit)

9) Checking of all export documents

10) Control and organization of compliance with regulations and subsidiary regulations as end-use certificates, importing certificates, transfer certificates

11) Inter-departmental, subject-related authority to stop deliveries and to give instructions

Approved

50

To be approved – 3) Tools

Tools selected by ECO to be purchased for

Screening

Transaction check connected to ERP

Electronic handling of customs

Approved

51

To be approved – 4) Training Plan

Training plan for Redknee employees

Approved

52

To be approved – 5) Action Items for Approvers

Action Items to Approvers

Written commitment to TCM Manual

Change of Code of Conduct

Nominate contact person for Trade Compliance in relevant countries (local ECM)

Install customs specialist

Annual TCM Budget

Approved

53

To be approved – 6) Next steps

Next steps

Investigation on potential certification needs (Authorized Exporter, AEO Certificate)

Process Implementation with assistance of legal (contractual clauses for procurement and sales, policy, disclaimer, Code of Conduct)

Selection of tools by ECO

Create TCM intranet portal

Create training material and perform trainings

Approved


2010 201108/13

E09/13

E11/13

E02/14

E12/13

09/13 10/13 02/1401/1412/1311/13

Kickoff



Employee training



E02/14


E12/13

M09/13

< 54 >

Trade Compliance Management (TCM)

Trade Compliance Management (TCM) is not established to control your work but to protect Redknee against the potential consequences of any violation of Export Control laws.

o Delays in project deliveries

o Get fined

o Disruption of business

o bad reputation by press release: “Redknee violates export laws”?

o Partners stop cooperation with Redknee

o Governmental export restrictions for Redknee

< 55 >

Trade Compliance Management (TCM) – Main tasks

Main tasks driven by TCM:

• Support in product classification (ECCN & HS Code)

• Support in people and organization screening

• Export license application

• BAFA report provision

• Single point of contact to legal authorities

• Provide legalized documents for customs clearance CoO, Invoices, CoC, customs invoice (Zoll-& Konsulatsfaktura)

• Regular monitoring of legal requirements

• Contact for Redknee employees in any trade compliance related problem

• Publish Newsletter

< 56 >

Trade Compliance Management (TCM) – next steps

Next steps:

• Establish EoD

• Track changes on laws and regulations and adapt processesif necessary

• Develop legal conditions for Cloud Computing

• Perform internal audits

• Ramp-up Trade compliance for Canada and India

• ATLAS

< 57 >

Trade Compliance Management (TCM)

Export control is a complicated topic and it is hard to know all the details existing around it. In case of any question, doubt or trouble please contact [email protected]

All needed information can be found for Redknee employees at the TCM-portal in Sharepoint:https://redknee.sharepoint.com/sites/Team_CFO/SCM/SCMS/TCM/Ptl/SitePages/Home.aspx

› Burkhard BallmannExport Control OfficerTel: +49 30 9210 24573E-mail: [email protected]

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Thank you

mailto:[email protected]

https://redknee.sharepoint.com/sites/Team_CFO/SCM/SCMS/TCM/Ptl/SitePages/Home.aspx

mailto:[email protected]

Documents

Trade Compliance - How it works - ExportManager · that the Supply Chain Management department will take over responsibilities to set-up and provide worldwide Trade Compliance Management