To ensure safety by maintaining international peace and security, the export of materials or technology that could be diverted for military purposes requires a license from the Minister of Economy, Trade and Industry in certain cases. This provision is contained in the Foreign Exchange and Foreign Trade Act and other export control laws and regulations.
Basic Policy on Export Control
Kawasaki’s basic policy on export control is to “refrain from transactions that might endanger the maintenance of international peace and security.” Accordingly, Kawasaki is committed to ensuring this through compliance with the Foreign Exchange and Foreign Trade Act and other export control laws and regulations. Moreover, when engaging in transactions that involve materials and technology of U.S. origin, Kawasaki takes account of U.S. reexport regulations in its export control procedures.
Export Control System
To ensure Group-wide compliance with export control laws and regulations, we have formulated a set of corporate export control regulations for goods and technologies relevant to security maintenance and have put in place an export control system in which a representative director acts as Chief Export Control Officer.
As a first measure, we set up the Export Control Laws and Regulations Compliance Screening Committee (hereafter the Screening Committee) at the Head Office chaired by the Chief Export Control Officer. The Screening Committee undertakes final assessment of all export transactions across the Group to confirm compliance with export control laws and regulations, and provides guidance and supervision to our internal companies to help them establish control systems that ensure legal and regulatory compliance. In addition, Trade Compliance Department is set up within the Head Office Risk Management Office to provide secretariat services to the Screening Committee and to function as a Group-wide division to coordinate export control. Next, the Working Level Committee is instituted under the control of the Screening Committee to undertake preliminary screening ahead of the assessment by the Screening Committee, discuss matters delegated to it by the Screening Committee, report to the Screening Committee, and undertake horizontal rollout to internal companies of export control-related information.
Furthermore, each internal company operates an Export Control Committee, which screens all the export transactions of the relevant company and refers the screening results to the Screening Committee for discussion.
Export Control Structure
Export Control Training and Guidance
To provide Group-wide training in export control covering all Group companies, the Head Office Trade Compliance Department organizes Group-Wide Export Control Training Meetings each year at a number of offices throughout Japan, with external lecturers invited from the Center for Information on Security Trade Control (CISTEC). Concurrently, each internal company offers export control training as a separate module in its grade-specific training.
An export control audit is carried out jointly by the Head Office Auditing Department and the Head Office Trade Compliance Department, which perform individual audits once a year of all internal companies and of major Group companies in Japan.
Moreover, overseas Group companies are subject each year to a questionnaire-based survey of their export record and related matters, with appropriate guidance and support on export control provided by the relevant internal company.