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Jewett-Cameron Company Trade Compliance Policy

As part of Jewett-Cameron Company’s commitment to professional, ethical, and legal standards of conduct, the Company shall comply with U.S. laws and regulations that serve as a benchmark for integrity in domestic and international trade transactions.  In order to avoid violations of laws and regulations, as well as to promote high standards of personal and corporate conduct, the Company, its officers, directors, and employees commit to abide by the policies and procedures embodied in the U.S. laws and regulations applicable to its domestic and international business operations and transactions.  To the extent that the Company engages in transactions with suppliers, vendors, subcontractors, agents, and other business partners, it also commits to abide by the letter and spirit of the laws and regulations set forth below.  All references herein to the “Company” shall also apply to its directors, officers, employees, duly authorized representatives, and agents to the extent they are directed or controlled by the Company.

 

U.S. Export Control Compliance - It is the Company’s policy to ensure that U.S. products and technology are not knowingly disclosed, exported, or otherwise transferred to recipients and/or a countries that are restricted under U.S. laws or regulations.  As to restricted countries, the Company, its employees and representatives shall ensure that the Company does not transact any business (including products or services) with countries under trade sanctions imposed by the U.S. government and enforced through regulations of the following agencies: the U.S. Department of the Treasury, Office of Foreign Assets Control, the U.S. Department of Commerce, Bureau of Industry and Security, and the U.S. Department of Homeland Security, Customs and Border Protection. 

 

As to restricted recipients, the Company, its employees, and representatives shall ensure that the Company does not transact any business (including products and services) with individuals or business entities who are sanctioned by the U.S. government and listed on any one of many restricted party lists, including the U.S. Consolidated Screening List.  

 

The Company shall maintain commercially reasonable technical and administrative measures designed to comply with this policy.

 

U.S. Anti-Money Laundering Compliance – It is the Company’s policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.  As such, the Company shall not engage in any acts intended to conceal or disguise the true origins of criminally derived funds so that they appear to have derived from legitimate origins or constitute legitimate assets.  Therefore, the Company commits to engage only in lawful transactions with reputable business partners and to accurately record such transactions in accordance with applicable laws, regulations, and accounting principles. The Company shall maintain commercially reasonable technical and administrative measures designed to comply with this policy.

 

U.S. Anti-bribery Compliance – It is the Company’s policy that it shall not make or authorize, directly or indirectly, any offer, promise, payment or gift of any money or anything of value to or for the benefit of any “foreign official,” foreign political party or candidate for foreign political office (as such terms are defined in the U.S. Foreign Corrupt Practices Act of 1977, as amended, for the purpose of (a) influencing any official act or decision of such official, party or candidate, (b) inducing such official, party or candidate to use his, her or its influence to affect any act or decision of a foreign governmental authority, or (c) securing any improper advantage, in the case of provisions (a), (b) and (c) above in order to assist the Company or any of its affiliates in obtaining or retaining business for or with, or directing business to, any Person. The Company shall maintain commercially reasonable technical and administrative measures designed to comply with this policy.

 

U.S. Import and Customs Compliance – It is the Company’s policy to comply with all applicable U.S. laws and regulations governing the importation of goods through any port of entry into the U.S.  Such compliance shall include, but not limited to disclosures of information, and declarations in support of imported goods that are accurate and complete to best of Company’s knowledge to ensure appropriate import duties, charges, and fees are paid and applicable health, safety, labeling, and other standards are satisfied in respect of all imported goods into domestic U.S. commerce and Company operations.  Furthermore, the Company shall not transact business, nor import products from any individual, business entity, or country that is restricted for such activities under the regulations of the U.S. Office of Foreign Assets Control, the U.S. Consolidated Screening List or other U.S. trade sanctions.  The Company shall maintain commercially reasonable technical and administrative measures designed to comply with this policy.

 

U.S. Personal Data Privacy Compliance -  It is the Company’s policy that in connection with its collection, storage, processing and/or disclosure of any information that constitutes “personal information,” “personal data” or “personally identifiable information” as defined in applicable laws (collectively “Personal Information”) by or on behalf of the Company, the Company shall comply with (a) all applicable laws, including but not limited to the General Data Protection Regulation, the California Consumer Privacy Act, pending privacy laws in Colorado and Virginia, and any U.S. federal law that may provide a safe harbor for the preceding laws in all relevant jurisdictions.  The Company shall maintain commercially reasonable technical and administrative measures designed to protect all Personal Information collected, stored, processed, or used by or on behalf of the Company from and against unlawful, accidental, or unauthorized access, destruction, loss, use, modification and/or disclosure.