# Presentation: 056166

## 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

##  BUSINESS UNITS

-  _BUSINESS UNITS_
- YEAR 2001 SALES - $ 23.65 BILLION
-   AEROSPACE  (40%)
-   AUTOMATION & CONTROL SOLUTIONS  (30%)
-   SPECIALTY MATERIALS  (15%)
-   TRANSPORTATION & POWER SYSTEMS  (15%)

## 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

## 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_	_

## SPECIALTY MATERIALS

- _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

- PRIMARY TECHNOLOGIES & PRODUCTS

## TRANSPORTATION & POWER SYSTEMS

- _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

- PRIMARY TECHNOLOGIES & PRODUCTS

## 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

## 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*

## 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

## 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.,

## 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

## 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

## 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

## 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