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Introduction

AquaJet Technik Swiss GmbH is committed to maintaining the highest standards of trade and export compliance in all its international business activities.
This policy sets out the principles and procedures that ensure all business operations of the company are conducted in accordance with the applicable laws and regulations governing international trade, export controls, sanctions, and customs requirements.

1. Export Controls and Sanctions

AquaJet Technik Swiss GmbH complies with all applicable export control laws and sanctions regulations, including but not limited to:
  • EU Dual-Use Regulation
  • Swiss Goods Control Ordinance (GKV)
  • U.S. Export Administration Regulations (EAR)
  • U.S. International Traffic in Arms Regulations (ITAR)
  • Sanctions issued by the Office of Foreign Assets Control (OFAC)
  • Sanctions imposed by the United Nations (UN) and the European Union (EU)
Procedures:
  • Screening: All international transactions must be screened against the relevant sanctions and export control lists prior to processing.
  • Licensing: Necessary export licenses must be obtained before shipping controlled goods, software, or technology.
  • Documentation: All export documentation, including licenses and screening results, must be retained for at least five years.
  • Training: Employees are to be trained regularly on export control regulations and internal company policies.

2. Import Compliance

AquaJet Technik Swiss GmbH ensures full compliance with import regulations in all countries where the company operates.
Obligations:
  • Accurate Classification: All goods must be correctly classified according to the Harmonized System (HS Code).
  • Valuation: The declared value of goods must be accurate, and all applicable customs duties and taxes must be paid.
  • Country of Origin: The origin of each imported product must be verified and documented.
  • Documentation: Commercial invoices, packing lists, and shipping documents must be complete and accurate.
Procedures:
  • Customs Declarations: All imports must be properly and fully declared to customs.
  • Audits: Regular audits of import transactions are conducted to verify compliance.
  • Customs Agents: The company cooperates with trusted customs brokers to ensure compliance with import regulations.

3. Internal Compliance Program

AquaJet Technik Swiss GmbH maintains a strong internal compliance program to ensure adherence to all trade laws and regulations.
Components:
  • Compliance Team: Establishment of a dedicated team to oversee all trade compliance activities.
  • Compliance Officer: Appointment of a responsible officer as the main contact person for all compliance matters.
  • Policy Documentation: Ongoing maintenance of all relevant compliance documentation and procedures.
  • Risk Assessment: Regular evaluations to identify and minimize potential compliance risks.
  • Internal Audits: Performance of regular internal audits to ensure compliance.
  • Reporting System: Implementation of a confidential reporting system for potential compliance violations.

4. Due Diligence and Partner Screening

AquaJet Technik Swiss GmbH conducts appropriate due diligence on all business partners — including customers, suppliers, and intermediaries.
Procedures:
  • Screening: All partners are screened against sanctions and restricted party lists.
  • Risk Assessment: Each partner’s risk level is evaluated, and enhanced due diligence is performed if necessary.
  • Contracts: All agreements include mandatory clauses requiring compliance with trade and export control laws.

5. Training and Awareness

AquaJet Technik Swiss GmbH ensures that all employees are informed about relevant trade regulations and company compliance policies.
Training Programs:
  • New Employees: Basic compliance training is provided during onboarding.
  • Ongoing Training: Regular refresher sessions are held for all employees involved in international trade activities.
  • Specialized Training: Targeted training is offered to employees in high-risk areas or regions.
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6. Communication and Reporting

The company maintains clear communication channels for reporting and handling compliance-related issues.
Procedures:
  • Reporting System: A confidential reporting channel is established for employees to report potential violations.
  • Investigations: Procedures are in place to investigate and address reported compliance issues.
  • Management Reporting: Regular reports on compliance activities are submitted to senior management.

7. Continuous Improvement

AquaJet Technik Swiss GmbH is committed to the continuous improvement of its trade compliance program.
Actions:
  • Monitoring: Continuous monitoring of legal and regulatory changes and updating internal policies accordingly.
  • Feedback: Gathering feedback from employees and partners to enhance compliance processes.
  • Benchmarking: Regular comparison of compliance practices with industry standards and best practices.

Final Provision

Compliance with this Trade Compliance Policy is mandatory for all employees, suppliers, and business partners of AquaJet Technik Swiss GmbH.
By implementing this policy, the company ensures that all international trade activities are conducted lawfully, its integrity is maintained, and legal or financial risks are minimized.
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