It is a basic policy of Raytron Technology Co. Ltd., its subsidiaries, branches and offices (collectively as “Raytron”) to fully comply with applicable export control and economic sanction laws and regulations including but not limited to those of China, the United States and the European Union.
Raytron has initiated and implemented a Trade Compliance Program, with specific requirements as follows:
- All products and technologies shall be classified in accordance with applicable export control laws and regulations before obtaining export control licenses when necessary;
- Strict due diligence and screening shall be performed on clients, suppliers and other business partners in the course of business operations;
- All transactions shall be subject to rules regarding destination countries and regions to which products or technologies are sold;
- Immediate measures shall be taken and transactions shall be terminated, if it is believed the products, technologies and services involved might be used in or for the development or manufacture of mass destruction weapons and delivery systems, unauthorized military equipment, or any other end-uses prohibited or restricted by applicable laws and regulations, which may threaten the peace and stability of certain countries or regions, or be transferred to terrorist organizations.
Raytron has established a compliance management organization to ensure an effective implementation of its Trade Compliance Program. The Risk Control and Compliance Committee oversees trade compliance strategy, which impacts policies, procedures and organization. The Committee also reviews or rules on major trade compliance matters. The Trade Compliance Office formulates specific trade compliance policies and procedures, conducts compliance vetting for any compliance risks or issues, and leads compliance promotion. The Business Compliance Officers and Compliance Representatives in each and all branches take the responsibility for implementing relevant requirements in their respective operations and functions.
Raytron has developed and issued trade compliance management guidelines, improved the record-keeping system, strengthened training for all employees on export control knowledge and skills, incorporated trade compliance into the performance evaluation of both the organization and individuals, and conducted internal assessments and audits of trade compliance as needed.
Raytron requires all employees to comply with trade compliance laws and regulations and Raytron’s compliance program, and to make every endeavor to a realization of Raytron’s trade compliance goals. Raytron has established a reward and penalty system for this purpose. Employees who contribute to its Trade Compliance Program will be rewarded, while those who constitute any violation will be held accountable. Employees suspected of illegal activities will be subject to legal responsibility in accordance with applicable laws and regulations.
Raytron routinely revises this Statement to ensure compliance with the latest legal and regulatory requirements.
Raytron Technology Co. Ltd.
Chief Compliance Officer JIANG Bin
