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Business Ethics and Compliance
This month's partner news section informs readers on AIT's ongoing efforts and procedures in ensuring its staff and extensive network of global partners are conducting themselves in an ethical and compliant manner.
Compliance Overview
Although AIT Worldwide Logistics operates within an agent network in many countries throughout the world, as a United States company, we must comply with the export administration and international economic laws of the United States. Our company policy requires that we conduct all of our air, ocean import and export services in compliance with such laws. There are no exceptions to this policy.
All global locations and subsidiaries under the AIT parent name must operate under the Foreign Corrupt Practices Act (FCPA) and comply with all applicable laws and regulations of each country when conducting business.
Under the FCPA, it is a crime for United States persons and corporations or their representatives to make, or attempt to make, or offer to make payments of money (otherwise known as "bribes") or to give or offer to give gifts or anything of value to foreign governments or officials in order to obtain, retain, or direct business or to secure an improper business advantage anywhere in the world.
AIT has established a comprehensive internal monitoring program to ensure compliance with such laws. Employees with direct tasks related to FCPA issues must adhere in writing to AIT's FCPA Compliance Program, which educates employees and agents of preventions, prohibits foreign payments and other policies, while detecting potential and actual violations of the FCPA.
Applying Compliance with International Partners
Along the same lines, global partners and agents provide a written certification agreeing to comply with a commitment to business integrity and respect as it relates to different cultures and the dignity and rights of individuals in all countries, the law, to not knowingly mislead others and avoid participating in unacceptable business practices.
When high risk prohibited practices become an identified circumstance, the policy requires that a personal interview with the agent occurs prior to finalizing the partnership. The interview is documented and included with the completed certification.
All international agents agree to the FCPA Compliance Program by signing the manual and participating in the correlated training program.
Compliance efforts are carefully documented to include the following: comprehensive records of educational materials, attendance at training sessions, certifications of compliance, due diligence efforts, hotline calls, and regular compliance reviews. Internal investigations will also be documented and preserved.
Entering into international business relationships
AIT frequently enters into strategic business relationships with companies outside U.S. boundaries. While these companies are instrumental in furthering AIT's international business, they must be adequately subject to our system of controls in order to protect assets against unauthorized use.
Because AIT may be held accountable for actions taken by agents and others on its behalf, compliance procedures require a selection process of all parties are subject to appropriate management control and investigation.
The AIT corporate operations team expects a baseline risk assessment and minimum requirements are completed prior to entering into a business relationship in addition to the following documentation:
- Insurance: Requirements will vary depending on country standard: cargo, employer's liability and general liability
- Business License
- Security checklist: Standard based on CTPAT
- FCPA: Training and certification
- Business References: At least three (3) U.S. verified references
- Bank letters: Received from the business partner's bank to confirm account validity
- International Country Profile Reports must be obtained for business partners that are located in high risk countries.
All proposed international agreements establishing such relationships are carefully reviewed by legal, financial and management personnel prior to being signed.
These agreements require that international agents agree to comply with AIT's code of ethics and compliance program when importing and exporting cargo.
Further compliance manuals extend to include export, import and code of ethics programs.
If you have any questions or comments regarding the Partner News eNewsletter,
please contact Larry Georgen, Manager Global Network. |
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