Convención Nacional 2014 Compliance at Schenker Group
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1 Compliance at Schenker Group SCHENKER LOGISTICS SAU Gert Lehmann 23 de mayo 2014
2 Sumario Basic concepts of Compliance Code of Conduct Business Partner Compliance Export Trade control
3 Compliance at Schenker Group Basic Concepts of Compliance at Schenker Code of Conduct Business Partner Compliance Export Trade Control
4 Code of conduct
5 Code of conduct Code of Conduct Corporate / Social Competitors and Partners Conduct of Employees Responsibility to Owners
6 Code of Conduct Code of Conduct Corporate Social Responsibility Human Rights Child Labor and Forced Labor Equal Opportunities Occupational Health and Safety Environmental Protection Safety Cooperation Conduct toward our Competitors, Public Officials & Business Partners Corruption Behavior towards Public Officials Consultants / Agents / Brokers Competition and Cartel Law Donations / Sponsoring Conduct of all Employees Behavior in Public Confidentiality Avoiding Conflicts of Interest Invitations and Gifts Responsibility to our Owners Protection of Company Property Reporting Insider Trading Data Protection Money Laundering
7 Business Partner Compliance
8 Business Partner Compliance 1 Business Partner Compliance do you know your business partner? is the contact a main business partner? Business Partner done by country organization for main business partners: Integrity Due Dilligence internet research for compliance issues decision to be taken based on Risk Evaluation + info to HO Schenker done together with HO Schenker if YES: 2 if critical: 3 evaluation 4
9 Business Partner Compliance 4 Final Evaluation Low Risk Partner Medium Risk Partner High Risk Partner No additional information required To be performed by Business Owner: Request completion of Compliance Questionnaire by Business Partner Review and send questionnaire to Compliance To be performed by Business Owner: Request completion of Compliance Questionnaire by Business Partner Review and send questionnaire to Compliance To be performed by Compliance: Review questionnaire To be performed by Compliance: Review questionnaire Additional integrity check To be performed by Compliance: Produce Management Summary
10 Export trade Control
11 Export trade Control Foreign Trade and Export Control Prohibitions and Restrictions based on PERSON Prohibitions and Restrictions based on COUNTRY Prohibitions and Restrictions based on ITEMS / GOODS (Sanction/Denied lists) (Embargos and Trade restrictions) + Schenker insurance policy, Schenker own procedures (Dual-use-Goods, end-use)
12 Export Trade Control EUROPEAN UNION SANCTIONS Please use the following link to check if the goods you intend to ship are under embargo (please click on the country to check details): eeas.europa.eu/cfsp/sanctions/docs/measures_en.pdf U.S. RESTRICTIONS: Please click on each country to obtain more information: TOTAL U.S. EMBARGO (Cuba, North Korea, Sudan and Syria): Please be sure that you respect the requirements of the chapter 3. of the «Check-list». Reminder: no transportation, no services in relation with Iran.
13 Export trade Control Country E.U. sanctions U.S. sanctions Country E.U. sanctions U.S. sanctions Afghanistan Iraq Belarus Bosnia and Herzegovina Burma (Myanmar) Central African Republic Cuba China * Cote d Ivoire (Ivory Coast) Democratic Republic of the Congo Egypt Eritrea Republic of Guinea (Conakry) Guinea-Bissau Haiti Iran ** Democratic People s Republic of Korea (North Korea) Lebanon Liberia Libya Moldova Serbia & Montenegro (Yugoslavia) Somalia Sudan South Sudan Syria Tunisia Ukraine Yemen Zimbabwe : E.U. sanctions : U.S. restrictions : Total U.S. embargo Please check if there exist additional local embargos/restrictions *China: Embargo on arms only. ** Iran: NO TRANSPORTATION
14 Export trade Control IRAN: TOTAL INTERDICTION Considering the expanded scope of sanctions against Iran, the Schenker AG Board of Management has decided to refuse all shipments from and to Iran since December FORBIDDEN: transportation to or from Iran FORBIDDEN: services in relation with Iran (customs clearance, logistics services, etc.). FORBIDDEN: transportation transiting via Iran FORBIDDEN: transportation with Iran as ultimate destination (even if the final transportation is not handled by DB Schenker).
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