Exclusive Networks // Sustainability Report 2022
Ethics, fair practices, compliance and security Export control
called the Internal Compliance Programme (ICP), which it constantly adapts to control these risks. In this context, the position of Export Control Manager was created in 2022, reporting to the Group’s Director of Operations, to strengthen the existing organisation.
Organisation of export control in the Exclusive Networks Group
In order to face these challenges together with a of strong international expansion, the Group has set up an organisation and an internal compliance programme
Chairman and CEO
GROUP LEVEL
LOCAL LEVEL: COUNTRY
AMERICAS 1
Group General Counsel Compliance Director
APAC 2
Regional Senior Vice-President
Group Chief Financial Officer *
EMEA 3
Internal Audit Director
Group Chief Operations Officer
Country Directors **
Export control champions (Operations, Finance or Sales Managers)
Head of Group Export Control
Function in charge of export control reporting to the CEO. Other stakeholders in the Group export control organisation. * Function with legal responsibility for export control by delegation from the CEO. ** Function with legal responsibility for export control of local entity.
Local operational entities: (1) AMERICAS: Canada, USA.
(2) APAC: Australia, Hong Kong, India, Indonesia, Malaysia, New Zealand & Pacific Islands, Philippines, Singapore, Thailand, Vietnam. (3) EMEA: Austria, Belgium, Bosnia, Bulgaria, Croatia, Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Israel, Italy, Kenya, Mauritius, Norway, Netherlands, Northern Africa, Poland, Portugal, Romania, Saudi Arabia, Serbia, Slovakia, Slovenia, Southern Africa, Spain, Sweden, Switzerland, Turkey, United Arab Emirates, United Kingdom.
The first line of risk control consists of the Country Managers and Export Control Champions of the Group’s main subsidiaries. The second line of risk control is provided by the Group Export Control Manager, who defines the export control strategy and associated procedures, and ensures regulatory monitoring, which is particularly critical given the geopolitical situation and the speed with which sanction regimes change. Internal Compliance Programme: is the bible of procedures to be followed by the Group and its subsidiaries to comply with regulations, such as the procedure for establishing the declaration of final destination and end use; includes training components;
refers to other internal Group procedures, such as the third party screening system (see section 6.2). In addition, the Group regularly conducts audits, either by the Internal Audit Department or by independent firms. The main improvements that will be undertaken in 2023 are to overhaul the Internal Compliance Programme, to strengthen coordination between the Export Control Champions, and to make the training modules available on the Group’s e-learning platform, in order to accelerate their deployment to all employees. [GRI 3-3-c]
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Exclusive Networks
Sustainability Report 2022
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