A. Business Partner relationships
B. International Trade Controls (ITC) laws
C. Money laundering prevention
D. Privacy
1A. Business Partner relationships
GS Group’s relationships with suppliers are based on lawful and fair practices. We expect our suppliers to meet high labor standards for their employees, treat them fairly, provide safe and healthy working conditions and uphold environmental standards. This is to ensure that our business partner relationships will not damage our reputation and its long-term business sustainability. We also require our business partners to sign an agreement/undertaking not to bribe our employees.
What does it mean for me?
DO
- Comply with applicable laws and government regulations covering business partner relationships.
- Ensure you are familiar with and follow government acquisition regulations when purchasing materials and services for fulfilling government contracts.
- Choose business partners who comply with local requirements relating to labor standards, the environment, and health and safety through open and competitive bidding.
- Safeguard “personal data” obtained from business partners.
- Safeguard GS Group’s confidential and proprietary information with a confidentiality agreement; safeguard any business partner-provided information protected by a confidentiality agreement.
DON’T
- Engage in direct business with a business partner owned or managed by a relative or close friend without disclosing it to management.
- Place orders with a business partner if you believe they may need to breach existing laws or supply standards to complete it.
- Enter into any supplier agreement or contract if there are potential conflicts in business partner selection such as accepting improper gifts or other items of value.
- Accept business with a business partner whose facility’s conditions are unsafe or those who ignore environmental standards.
- Entrust “personal data” or confidential information to business partners without ensuring that they have appropriate technical, physical and organizational measures to prevent unauthorized access or use.
1B. International Trade Control (ITC) laws?
International Trade Control (ITC) laws affect the transfer of goods, services and technology across national borders. These laws apply to GS Group’s operations beyond the shipping of products. Exchanges of information across national boundaries, including e-mail and web access, are subject to trade controls.
What does it mean for me?
DO
- Follow relevant ITC regulations in the area in which you operate, along with your business’s own ITC procedures, as they relate to the import and export of goods, technology, software, services and financial transactions.
- Report all relevant information to your import manager to ensure accurate and complete import declarations.
- Check the export classification of the product, software or technology prior to export to determine whether special authorization is required.
- Screen your transactions against all applicable rules that restrict transactions with certain sanctioned countries, persons and prohibited end-users.
- Screen all of your business partners, suppliers and parties involved in your international transactions against government provided watch lists.
DON’T
- Cooperate with any restrictive trade practice or boycott that is prohibited or penalized under foreign or applicable local laws.
- Ignore or take for granted any acts that suggest your customer may be attempting to evade ITC laws.
- Accept evasive, reluctant or otherwise unsatisfactory answers from a customer to questions about end-use, end-user, delivery dates or delivery locations.
- Get involved with parties or activities suspected of any connection with the development of biological, chemical or nuclear weapons, or ballistic missiles.
- Conduct transactions involving an embargoed country, a citizen or representative of an embargoed country or an individual or entity subject to government sanction.
- Accept an invoice on imported goods where the price shown does not reflect the full value, the description of the goods is not complete, or the country of origin is not correctly identified.
- Accept or process any payment to the exporter or benefit the exporter in a way that is not stipulated in the invoice price or otherwise reported.
- Take or accept transfer pricing between related parties that fail to cover appropriate costs and profits.
- Use an import tariff classification that does not accurately describe the imported goods.
- Accept or allow the designation of GS Group as the importer of record (party responsible for an importation) without maintaining necessary processes to comply with import laws.
- Allow the entry of goods under a preferential duty program (North American Free Trade Agreement [NAFTA], etc.) without supportive procedures assuring compliance with the program’s requirements.
1C. Money laundering prevention?
People involved in criminal activity – e.g., terrorism, narcotics, bribery and fraud – may attempt to “launder” the proceeds of their crimes to hide them or make them appear legitimate. GS Group is committed to complying with all anti-money laundering and anti-terrorism laws worldwide. It will conduct business only with reputable customers involved in legitimate business activities and with funds derived from legitimate sources.
What does it mean for me?
DO
- Follow your business’s rules concerning acceptable forms of payment.
- Comply with all applicable laws and regulations that prohibit money laundering, the support and financing of terrorism, and that require the reporting of cash or suspicious transactions.
- Collect and understand documentation about prospective customers, agents and business partners to ensure that they are involved in legitimate business activities and that their funds come from legitimate sources.
- Learn the types of payments that have become associated with money laundering (for example, multiple money orders or travelers checks, or checks on behalf of a customer from an unknown third party).
DON’T
- Deal with a customer, agent or proposed business partner who is reluctant to provide information, provides insufficient, false or suspicious information, or is anxious to avoid reporting on recordkeeping requirements.
- Accept payments using monetary instruments that appear to have no identifiable link to the customer or have been identified as money laundering mechanisms.
- Accept payments or early repayments of a loan in cash or cash equivalents by a customer or proposed business partner if there is suspicion that the fund is from money laundering-related activities.
- Process orders, purchases or payments that are unusual or inconsistent with the customer’s trade or business.
- Get involved in unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favorable payment terms.
- Allow unusual fund transfers to or from countries unrelated to the transaction or those that are not logical for the customer.
- Participate in transactions involving locations identified as secrecy havens or areas of known terrorist activity, narcotics trafficking or money laundering activity.
- Get involved in transactions involving foreign shell or offshore banks, unlicensed money remitters or currency exchangers, or nonbank financial intermediaries.
- Allow the structuring of transactions to evade recordkeeping or reporting requirements (for example, multiple transactions below the reportable threshold amounts).
- Grant requests to transfer money or return deposits to a third party or an unknown/unrecognized account.
1D. Privacy
A growing number of countries are regulating the collection and use of consumers’ “personal data” (names, home and office contact information, etc.). Additionally, many countries regulate the personal data of company representatives in business-to-business transactions. GS Group is committed to handling personal data responsibly and in compliance with applicable privacy laws.
What does it mean for me?
DO
- Obtain/process and use personal data for legitimate business purposes only.
- Limit access to personal data to individuals who need it for a legitimate business purpose.
- Use “anonymous” data (names removed) or “aggregated” data (summarized so as not to be identifiable) instead of personal
data where appropriate or required. - Use care to prevent unauthorized access in the processing of personal data or accidental loss or destruction of personal data
- Learn and comply with the applicable laws and regulations of jurisdictions from which the personal data is collected and in which it is processed or used.
DON’T
- Store or keep personal data where there is inadequate access or security control, such as e-mailing or otherwise distributing personal data to a larger group than needed, or leaving printouts with personal data at a printer, copy machine or fax machine for others to see.
- Allow the sharing of personal data with unaffiliated third parties such as vendors or suppliers who lack appropriate security safeguards or restrictions.