Shimadzu Group Security Trade Controls
The Shimadzu Group has established the Security Trade Control Policy described below to ensure appropriate import/export controls are implemented, from a perspective of maintaining international peace and security.
1. Shimadzu Corporation Security Trade Control Policy
Given a profound awareness that Shimadzu Group products, services, or technologies could potentially be used for researching, developing, or other purposes related to military technologies, the Shimadzu Group shall:
1) Not engage in transactions that involve supplying Shimadzu Group products, services, or technologies to any party (customer) that intends to develop, manufacture, or otherwise contribute to weapons of mass destruction or conventional weapons that could potentially threaten international peace and security, or to parties for whom there is concern they might do so.
2) Maintain a thorough understanding of and manage information about all parties (customers) and applications for all transactions that involve supplying Shimadzu Group products, services, or technologies.
3) In order to achieve the above, comply with the Foreign Exchange and Foreign Trade Act and other Japanese laws and regulations, United Nations Security Council resolutions, related international treaties, and international export control regimes, and also make a sincere effort to comply with all import and export-related laws and regulations in countries and regions where the Shimadzu Group conducts business.
2. Export Control Organization
The President is appointed as the chief officer responsible for export controls, and internal export control regulations (compliance program, abbreviated "CP") is created and implemented to ensure the above Security Trade Control Policy is implemented.
As a general rule, a classification is made regarding the applicability of list controls for exporting Shimadzu products, and so on, before products are released to market. That classification is made jointly by the relevant R&D and export control group.
Documentation providing evidence of such classification results for clearing customs, for example, are provided to customers via sales personnel.
4. Transaction Examination
Transaction examination is conducted for exporting Shimadzu products or providing technologies to non-residents of Japan to ensure the products or technologies are not used for military applications or to development weapons of mass destruction, for example.
Transactions involving list-controlled items, delivery to regions of concern specified in Japan's Export Trade Control Order, or applications of concern shall be reviewed by the export control departments.
For transactions not involving list-controlled items, delivery to regions of concern specified in Japan's Export Trade Control Order, or applications of concern, sales or other personnel involved in exporting such shipments shall confirm the end user and application.
5. Export Control Audits
Export control audits are periodically conducted by the Export Controls Committee to confirm export controls are being implemented appropriately in accordance with compliance programs. Group companies are also subject to export control audits and obligated to submit corrective action reports to the Export Controls Committee for any non-conformities identified by the audits.
6. Export Controls Training and Guidance
To notify the importance of the security trade export controls throughout the organization, we conduct new employee training, export controls training for respective departments, attend presentations on security trade controls by the Ministry of Economy, Trade and Industry. And we notify R&D departments about revisions when list control revisions are issued, and review how such revisions will affect Shimadzu products, for example.
7. Document Control
We establish document control regulations to ensure export-related documents are saved and managed appropriately in accordance with applicable laws and regulations.
We promptly report any violations, or suspected violations, of export control-related laws or regulations to the Japanese Minister of Economy, Trade and Industry and implement any corrective measures necessary to prevent recurrence.