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EXPORT CONTROL BEST PRACTICES HONEYWELL. OVERVIEW OF HONEYWELL - BUSINESS UNITS AND PRODUCTS HONEYWELL CORPORATE EXPORT CONTROL ORGANIZATION LICENSE STATISTICS HONEYWELL EXPORT COMPLIANCE PROGRAM - SORTING OUT COMPLIANCE REQUIREMENTS

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slide1

EXPORT CONTROL BEST PRACTICES

HONEYWELL

  • OVERVIEW OF HONEYWELL - BUSINESS UNITS
  • AND PRODUCTS
  • HONEYWELL CORPORATE EXPORT CONTROL
  • ORGANIZATION
  • LICENSE STATISTICS
  • HONEYWELL EXPORT COMPLIANCE PROGRAM
  • - SORTING OUT COMPLIANCE REQUIREMENTS
  • - TOOLS USED (A) COMPLIANCE MANUAL / ITC Website
  • (B) ECC DIRECTORY & LOGICAL ACCESS
  • (C) SCREENING SOFTWARE
  • (D) TRAINING AND AUDITS
slide2

HONEYWELL INTERNATIONAL INC.,

  • BUSINESS UNITS
  • YEAR 2001 SALES - $ 23.65 BILLION
  • AEROSPACE (40%)
  • AUTOMATION & CONTROL SOLUTIONS (30%)
  • SPECIALTY MATERIALS (15%)
  • TRANSPORTATION & POWER SYSTEMS (15%)
slide3

PRIMARY TECHNOLOGIES & PRODUCTS

  • AEROSPACE
  • Aerospace Electronic Systems
  • Aircraft Landing Systems
  • Engines, Systems & Services
  • Commercial Market Segment
  • Defense & Space Market Segment
  • PRIMARY TECHNOLOGIES & PRODUCTS
  • Turbofan, turboprop and turbo-shaft propulsion engines
  • Auxiliary power units
  • Integrated avionics systems
  • Com / Nav / Display & Flight Management Systems
  • Flight Safety Systems
  • Environmental Control Systems
  • Aircraft Landing Systems
  • Aircraft and airfield lighting systems
  • Technical Services
slide4

PRIMARY TECHNOLOGIES & PRODUCTS

  • AUTOMATION & CONTROL SOLUTIONS
  • Industrial, Home & Building Control Products
  • Industry Solutions
  • Security & Fire Solutions
  • Service
  • PRIMARY TECHNOLOGIES & PRODUCTS
  • Controls for heating, ventilating, air conditioning equipment
  • Home automation systems
  • Security, video surveillance, access control & fire alarm systems
  • Integrated building automation systems
  • Energy management solutions
  • Advanced systems & software solutions for industrial facilities
  • Process-control instruments, analytical & field instruments
  • Advanced semiconductor-based lasers
  • Sensors, actuators, switches and controller products
slide5

PRIMARY TECHNOLOGIES & PRODUCTS

  • SPECIALTY MATERIALS
  • Nylon System
  • Electronic Materials
  • Fluorine Products
  • Performance Fibers
  • Specialty Chemicals
  • Advanced Circuits
  • Metglas Solutions
  • PRIMARY TECHNOLOGIES & PRODUCTS
  • Wafer fabrication services and solutions; Printed Circuit Boards
  • Amorphous metals
  • Advanced packaging substrates for silicon chips
  • High purity chemicals and Specialty waxes
  • Environmentally safer Fluorines; agricultural fine chemicals
  • Spectra fibers for protective armor
  • Anso carpet fibers; Other high-performance firbers
slide6

PRIMARY TECHNOLOGIES & PRODUCTS

  • TRANSPORTATION & POWER SYSTEMS
  • Garrett Engine Boosting Systems
  • Consumer Products Group
  • Friction Materials
  • PRIMARY TECHNOLGIES & PRODUCTS
  • Turbochargers for passenger cars, trucks & other vehicles
  • Autolite spark plugs
  • Fram oil, air, transmission and fuel filters
  • Prestone antifreeze, fuel additives and car-care products
  • Simoniz waxes and appearance products
  • Disc brake pads, drum brake linings, and other friction materials
slide7

HONEYWELL CORPORATE EXPORT CONTROL ORGANIZATION

  • Part of International Trade Compliance (ITC)
  • organization reporting to Law Department
  • Two Centers of Excellence
  • 1. Washington DC
  • 2. Phoenix
  • Washington DC - U.S. Government Liaison and
  • management for all Honeywell Business Units
  • Phoenix - Responsibility for Engines Systems &
  • Services portion of Aerospace
export licenses obtained by honeywell
Export Licenses Obtained By Honeywell

(*) In addition, 147 licenses processed by AES facilities

slide9

HONEYWELL EXPORT COMPLIANCE PROGRAM

SORTING OUT COMPLIANCE REQUIREMENTS

(A) Facilities with “EAR99” Products

(B) Facilities with “AT” Controlled Products

(C) Facilities with products requiring Licenses from DOC

(D) Facilities with products requiring Licenses from DOS

(E) Facilities with combination of (A) + (B)

(F) Facilities with combination of (A) + (B) + (C)

(G) Facilities with combination of (A) + (B) + (C) + (D)

RISK LEVEL for COMPLIANCE - LOW for (A)

HIGHEST for (G)

Need Different Strokes for Different folks

slide10

TOOLS USED FOR COMPLIANCE

  • HONEYWELL COMPLIANCE MANUAL
  • Manual in two parts
  • Part I used by all HW Business Units and Part II for HW Aerospace
  • Part I includes - Corporate Policy Statement & Policy
  • - Corporate Policy
  • - Functions and responsibilities of various departments
  • - Overview of EAR and ITAR
  • - Export licensing procedures under the EAR
  • - Red Flag Indicators
  • - Screening for proliferation, antiboycott
  • - Examples of various types of DOC licenses
  • - Sample format letters for compliance activity
  • - Export license process flow charts
slide11

TOOLS USED FOR COMPLIANCE

  • HONEYWELL COMPLIANCE MANUAL
  • Part II of Manual includes
  • - Everything pertaining to ITAR
    • - Consolidated list of ITAR exemptions
    • - Electronic license entry procedures
    • - Examples of DOS completed applications
    • - Procedures for handling Agreements
    • - Various form letters used for compliance
    • - Summary of Customs Hand Book Procedure
    • - Commonly asked Q & A
    • - Compliance audit check lists
  • ITC Website - includes Compliance Manual;
  • ECC Directory; Corporate Policy;
  • training modules etc.,
slide12

ECC DIRECTORY AND LOGICAL ACCESS

  • Honeywell Export Control Coordinators (ECC) Directory
  • - Updated regularly
  • - Lists 60 U.S. facilities for Aerospace
  • - Lists 60 U.S. facilities for the three other
  • Business Units
  • - Lists 22 International locations
  • - List has one or more Export Control Coordinators
  • - Many ECCs are part time
  • - Corporate contract with IBM - Logical Access
  • approval process to provide computer
  • access to foreign nationals
  • - No access for foreign nationals without
  • approval from ECC
slide13

SCREENING SOFTWARE

  • U.S. LAW PROHIBITS TRANSACTIONS WITH:
  • - Denied Persons List (Dept. of Commerce)
  • - Debarred Parties List (Dept. of State)
  • - Specially Designated Nationals (Dept.of Treasury)
  • These lists are updated every day more so since 9/11/2001
  • Honeywell uses screening software of a vendor
  • - Most facilities use manual process
  • - Some have automatic interface
  • Minimum required for compliance
    • - Screening for lesser known customers
    • - Obtain end-use/end-user for selected transactions
    • - Provide Shipper’s Letter of Instructions to FF
slide14

TRAINING AND AUDITS

  • EXPORT REGULATIONS TRAINING PROVIDED BY
  • HONEYWELL CORPORATE OFFICE
  • Frequency of training decided upon the risk
  • (Category A or G)
  • Regulations training seminar conducted for facilities
  • under Category G at least once a year. Less frequently
  • for facilities under Category A. Training also provided
  • by ECCs at many locations.
  • Category A training could be using NetMeetings or
  • teleconferences
  • In addition, annual conference for all ECCs held. Also,
  • ECCs are recommended to attend SIA conferences
slide15

TRAINING AND AUDITS

  • AUDITS OR COMPLIANCE PROCEDURES REVIEW
  • Honeywell Corporate office uses Compliance
  • Procedures Review (CPR) Check Lists
  • Reviews done annually for Category G facilities
  • Report of findings from the CPR sent to the
  • the key people and the site leader for taking action