It is the policy of Ipswitch, Inc. to fully comply with all laws and regulations governing the export of its products, services, software and technical data. Each employee must be dedicated to ensure such compliance. All sales, service, shipping, accounting and other personnel that may be involved in export shall be familiar with and review regularly the Ipswitch, Inc. Export Management System (EMS) to ensure compliance with government regulations. Particular attention should be taken when releasing technical information to foreign nationals, whether abroad or in the United States, in electronic transmission of data/software and when hand carrying exports.
Under no circumstances shall Ipswitch, Inc. personnel sell or ship any product contrary to United States export laws or shall these laws be compromised for personal gain. Neither sales nor shipments are to be made to any individual or firm appearing in the Denied Parties Lists or to any firms owned by or associated with the individuals of firms therein listed. Also, no orders or shipments are to be made to any country subject to economic or trade sanctions imposed by the U.S. unless otherwise authorized by U.S. law. Failure to comply with these regulations may result in the imposition of criminal and/or civil fines and penalties, including incarceration for individuals and suspension of export privileges for Ipswitch, Inc.
In addition, regulations are in effect that place emphasis on the end-use and/or end-user of exported items (see 15 CFR 744.1 General Prohibition 4). As a result, we need to be vigilant in screening our customers and transactions. It is, therefore, more important than ever that the “Know Your Customer” guidelines (available from the Export Compliance Manager) are understood and implemented in order that Ipswitch, Inc. can meet the required “know” standard.
In particular, no transaction can be made when dealing with individuals, companies and countries involved with the proliferation of nuclear missile and chemical/biological related processes and/or weapons without a license from the Department of Commerce.
All questions concerning whether a proposed sale, shipment or other transaction, domestic or international, complies with the export laws shall be immediately referred to Melissa Mack (781-676-5718) who is managing our Divisional Import/Export functions.
Non-compliance or possible non-compliance with any of the export laws and regulations that becomes known to any Ipswitch, Inc. employee shall be immediately reported to the Export Compliance manager or Chief Financial Officer.
Ipswitch, Inc.’s EMS summarizes and refers to the applicable laws and regulations (which will be updated as appropriate) that are excerpted from the U.S. Export Administration Regulations. The Export Compliance Manager has a complete set of the foregoing regulations.