It is BTG’s express policy to fully comply with all applicable export controls, which are summarized in the BTG Export Controls Compliance Manual. Failure to comply could result in civil or criminal penalties, including, but not limited to, fines, imprisonment, loss of export privileges, debarment, revocation of previously approved licenses, seizure and forfeiture of goods. Such penalties may be imposed on BTG, individuals employed by or otherwise affiliated with BTG, or any combination thereof. Because of the fundamental importance of complying with all applicable export controls, employees who knowingly violate such controls or this compliance policy will be subject to appropriate disciplinary action, up to and including possible discharge from employment.
Every employee is encouraged to communicate any compliance questions or concerns to their manager or to the Export Controls Compliance Officer. For its part, BTG has an obligation to investigate and address reported concerns. BTG does not retaliate against individuals for asking questions, raising concerns about compliance issues, or reporting possible misconduct.
Sound export control practices underscore our commitment to ethical business behavior and compliance with applicable laws and regulations. Thank you for your shared commitment to BTG’s compliance efforts.
Eclépens, March 25th, 2010.
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