Compliance Policies

Export

Greenheck Fan Corporation is dedicated to full and complete compliance with all U.S. Export laws and regulations applicable to the conduct of its business, including the laws, regulations, and procedures of the U.S. Department of Commerce's Export Administration Regulations (EAR), the U.S. Department of State International Traffic in Arms Regulations (ITAR), the Department of Treasury Foreign Assets Control Regulations (FACR), the Department of Census Foreign Trade Statistics Regulations (FTSR), and any other U.S. statute or regulation. Greenheck Fan Corporation will not knowingly engage in any illegal activity under any circumstances and will not condone or support the illegal activity of any party with which it has dealings. In furtherance of its strict export compliance policy, Greenheck Fan Corporation, through its representatives, agents, employees, subsidiaries and independent contractors is dedicated to the development of systems designed to identify the legal requirements applicable to Greenheck activities, the development of programs and internal controls to insure that those requirements are met, and the providing of clear and correct information to applicable enforcement and administration agencies such as the EAR.

Greenheck Fan Corporation will continually strive to strengthen its efforts to assure compliance with its export compliance policy and its standards of conduct. The mechanism's set in place to ensure compliance with these laws, and to ensure that our products are going where and doing what the purchaser claims may take time to carry out.

It is a fact of international business that not all countries are requiring their businesses to follow such strict procedures in export. Our goal is to keep our products out of the hands of those who would use them to harm others regardless of whether or not legal compliance on our end can be proved.

Export laws do allow us to prepare for such instances with larger and regular foreign customers minimizing the time that it takes for approval by the use of multiple end user licenses, which are obtained after receiving letters of intent from end users. We need to anticipate customer's needs before hand and have license approvals as far along in the process as possible to minimize the time that it takes for our products to be released to the customers. But, regardless of the length of the wait involved, the urgency of our distributor's/ customer's, the effect on sales goals, or any other matter, company policy (adherence to the export manual) must be followed.

For guidance on export rules and regulations relating to a sales order please contact your Greenheck sales representative to arrange a discussion with the Compliance Team.

California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act requires companies manufacturing product in California to disclose what efforts they make to address human trafficking and slavery.

The Greenheck Group (Greenheck) is committed to the highest possible standard of corporate integrity, and we hold our suppliers and employees to the same standards.   It is our expectation that all suppliers provide high quality raw materials which are produced within compliance of all applicable laws.

Verification of Supply Chain: At this time Greenheck does not require that our suppliers certify compliance with laws relating to human trafficking and slavery.  Greenheck requires that strategic suppliers sign standard terms and conditions which require compliance with all laws including those related to slavery or human trafficking.

Audits: At this time Greenheck does not conduct audits of its strategic suppliers to evaluate their compliance with human trafficking and slavery.  If evidence of human trafficking or slavery was discovered during on-site visits, by Greenheck personnel, remedial action would be taken.

Supplier Certification:  At this time we do not require that our suppliers certify materials provided comply with laws relating to human trafficking and slavery.

Accountability: All Greenheck personnel, located worldwide, must comply with all applicable laws in order to comply with our Corporate Code of Conduct.   Non-Compliance with our Code of Conduct can result in corrective action or termination of employment depending on the circumstances and severity. Greenheck requires that strategic contractors sign standard terms and conditions which require compliance with all laws including those related to slavery or human trafficking.  Non-Compliance with our standard terms and conditions can result in corrective action or termination of contracts depending on the circumstances and severity.

Employee Training: Greenheck requires employees and management, who have direct responsibility for procurement or sourcing to complete an online training course on Human Trafficking.

While no formal processes are in place to address the steps outlined in the California Transparency in Supply Chains Act of 2010, we believe we have established relationships with the high integrity supply chain partners who are complying with all laws.

This disclosure applies to all of The Greenheck Group subsidiaries.

Should you have any questions regarding this new law as it applies to our suppliers please contact customscomplianceteam@greenheck.com.  

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