Strengthening Global Export Control System
Exports to several countries are subject to strict controls under relevant Japanese and U.S. laws. If our export control compliance were lax, this could result in situations that threaten the basis of our existence as a corporation. In the worst case, the company would be subject to penalties such as an export ban due to violations of applicable laws and regulations. For this reason, as a global company, the Topcon Group is committed to activities related to maintaining and bolstering the global system of export controls.
Conducting export control audits
We conduct annual internal audit on all departments involved in export. Then, measures for improvement which was requested during audit are discussed with departments audited for one to three months after audit to correct nonconformities at an early stage. The next year's audit conducts follow-up to check if such measures are carried out on a continuous basis. It also checks for missing items and inadvertent errors such as in administration procedures in the entire process. In addition, domestic and overseas group companies are audited according to an annual plan to strengthen global export control system.
Since FY2012, we have started field audit of overseas group companies jointly with in-house lawyers of a U.S. group company specialized in U.S. laws. In FY2015, export control staffs from Japan and the U.S. companies conducted audit on group companies located in the Germany, Republic of Singapore. and the China to reinforce the export control system.
Providing export control educations
To raise employees' awareness about compliance, we provided 23 training sessions for new employees, mid-career employees and others engaged in export control in FY2015 and 162 employees in total participated in the sessions. We put some thought in training materials to make them easy to understand for employees. Furthermore, we provide mandate training for employees who will be assigned to overseas companies to raise their awareness of their leadership role in administrating export control in a region where they will work in order to "enhance a global export control system."
Developing export control specialists
To improve expertise of employees engaged in export control, Topcon Group recommends them to take a "certification exam on export control" held by the Center of Information on Security Trade Control (CISTEC).
Periodically holding export control promotion meetings
To share information on global trends and situations of export control in Topcon Group, we periodically hold export control promotion meetings to raise the awareness of employees within the group. In the FY2015, there has been of a significant change in world affairs, such as the restoration of diplomatic relations between the US and Cuba, relaxation of Iran sanctions and regulations in response to the arrival date of JCPOA, and diplomatic ties between Iran and Saudi Arabia. To thoroughly practice export control in line with these changes, the information is shared and fed back internally.
Regions requiring special control
Topcon Group designates six countries including Iran, Iraq, Cuba, Syria,(Northern) Sudan and North Korea which are subject to special regulations under the Foreign Exchange and Foreign Trade Act of Japan and relevant U.S. laws as "regions requiring special control" and applies the most stringent procedures for screening for trade and administration in the Topcon export control program. We will further strengthen our export control system to achieve the highest quality of the system.