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.

Human Trafficking Compliance Policy

It is Greenheck Fan’s corporate policy to comply with all applicable local, state, federal and international laws.  We expect and depend on our employees and suppliers to help us respect and observe applicable laws. On 9-30-10 the Governor of California signed a new law designed to combat Human Trafficking.  The law takes effect January 1, 2012.  It imposes various obligations on retailers and manufacturers who meet various sales or ownership thresholds by selling products, paying employees or owning property in California. Greenheck Fan and many other companies are subject to this new law and as our supplier we need your help to make sure we both comply with the law. The law requires that each company subject to the requirements post a link on our website explaining our efforts to comply with the law, list steps we have taken to prevent human trafficking with our supply chain including requiring supplier certifications and auditing compliance in addition to training employees about the new requirements. The new law will be enforced by the Attorney General for the State of California. The purpose for the new law is to help prevent human trafficking in California and in other countries. A recent US Department of Labor report indicated that as many as 122 goods from 58 countries were believed to have been produced using forced labor or child labor. We think it is possible that other states may also enact similar legislation in the coming year. Greenheck Fan supports this law and will make efforts to ensure the goods we purchase are not produced using forced or child labor.

Greenheck Fan requires each supplier to verify compliance with all applicable laws including this one. We have written each supplier to make sure they are aware of the new law and to have them certify they comply with it.  Our Purchasing Department conducts periodic audits and maintains a supplier scorecard for each vendor. In that process the Purchasing Team will monitor the supplier’s compliance with all applicable laws including this one addressing human trafficking. Should you have any questions regarding this new law as it applies to our suppliers please contact customscomplianceteam@greenheck.com.  

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