Global Trade Compliance
It is the policy of Curtiss-Wright Corporation, its subsidiaries, and affiliates to comply with all applicable global export and import control laws and regulations that may affect the purchase, sale, or shipment of goods, software, or technology, enacted by a country in which Curtiss-Wright operates including without limitation:
The types of export/import controls include but are not limited to the following:
US export and import control laws and regulations include, but are not limited to, the Department of Commerce’s Export Administration Regulations (EAR) and Foreign Trade Regulations (FTR), the Department of State’s International Traffic in Arms Regulations (ITAR), the Department of Treasury’s Foreign Asset Controls, the Department of Energy’s Nuclear Regulatory Commission (NRC) Regulations, and the Department of Homeland Security’s (DHS) Customs Regulations as well as other regulations administered by the US government. The European Union laws and regulations include but are not limited to the Council Regulation (EC) no. 1061/2009 for exports and Council Regulation (EC) no. 260/2009 for imports administered by member country organizations. The Canada laws and regulations include but are not limited to the Canadian Controlled Goods Program administered by the Department of Foreign Affairs, Trade and Development Canada (DFATD).
Common activities that are subject to the global export and import regulations include but are not limited to the following:
It is the corporate policy of Curtiss-Wright, its subsidiaries, and affiliates worldwide to comply fully with these laws and regulations when exporting or importing products, services and technology. Violations of applicable export and import control laws could result in substantial penalties for both Curtiss-Wright and the individual(s) involved and could potentially jeopardize national security. Penalties could include suspension or denial of Curtiss-Wright’s export privileges, debarment of the company from US Government procurements, heavy fines, and imprisonment.
PROCEDURE
All Curtiss-Wright employees must be familiar with and abide by this Policy. Business Unit Managers are responsible for implementing this Policy. Employees should seek guidance from Global Trade Compliance Group in the Legal Department (1) prior to engaging, directly or indirectly, in any transaction involving controlled exports or re-exports; (2) if they become aware of any potential violation of export or import control compliance; or (3) if they are contacted by the US or any other governments concerning export or import control matters.
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