Compliance

 

Compliance Principles For Export


 

Principle Statement

MLW intermed Handels- und Consultinggesellschaft für Erzeugnisse und Ausrüstungen des Gesundheits- und Bildungswesens mbH (MLW) is committed to complying with all applicable export and trade compliance laws in all countries in which MLW does business. This includes laws and regulations pertaining to trade embargoes and economic sanctions, export control, anti-corruption, cargo security and free trade agreements. In conducting business across borders, all MLW employees must be aware of and follow these laws and MLW’s trade compliance, Policies, Standards, and Procedures. These laws are complex and change frequently. Employees must engage MLW’s Compliance Officer as needed to ensure compliance. Should MLW’s policies conflict with local law, employees must always obey the law.

 

Purpose

MLW is active internationally. Exports of MLW takes place in different countries. This Principle helps ensure that MLW complies with all export and trade compliance laws in all of its global business activities. This Principle applies globally to all employees.

 

Additional Guidance:

  • Anti-corruption regulations prohibit bribery. MLW acknowledges the directive of the Federal Government to prevent corruption in the federal administration from 30.07.2004 and declared this to be binding, unless there is the organizational structure of MLW as limited liability company. The directive can be found here: http://www.verwaltungsvorschriften-im-internet.de/bsvwvbund_30072004_O4634140151.htm.
  • Employees should be aware that applicable laws and regulations may vary from country to country. Employees in this sense are the employees who are involved in foreign trade.
  • MLW’s policies take into consideration multiple laws and regulations from across many countries, as well as management strategies, organizational structure, and above all, MLW’s values. This often results in MLW’s policies setting a higher standard than a specific law requires. Employees are expected to adhere to MLW’s policies as the standard for behavior.

 

Penalties

Failure to comply with export, import, and trade compliance laws could lead to criminal and civil penalties for MLW and for individual employees, significant business disruptions, and harm to MLW’s reputation. Violations of MLW’s Code of Conduct will result in discipline, up to and including termination of employment.