Objectives:

To comply with the applicable trade compliance laws, regulations and regimes in the jurisdictions where Kerry Logistics Network operates, including the Wassenaar Arrangement, Export Control Regulations of the United States of America and Export Control Law of the People’s Republic of China.

Measures:

This policy sets out the minimum standard which Kerry Logistics Network must comply with to meet the above obligations.  All Business Unit Heads shall ensure that their teams strive to:

• prevent any failure to meet trade compliance requirements that will lead to serious consequences for Kerry Logistics Network in terms of reputational damages, monetary penalties, and suspension/revocation of the rights or the authorisations to export and/or import;
• and adhere to the Internal Trade Compliance Programme and ensure the implementation, maintenance and continued review of its trade compliance with the domestic or national and international regimes relevant to the business processes through the following actions:

• Export Compliance

All exports are to be accurately declared as applicable under the national customs/trade laws. Shipping documentation shall accurately describe item(s) being shipped as well as the applicable export classification.

• Import Compliance

All imports are to be accurately described as applicable under the national customs/trade laws. All customs entries shall accurately state all required information, including the importer of record’s name and address, importer number, quantity, value, classification, duty preference eligibility, and country of origin for the imported items.  

All imported dutiable products handled by the Company shall be documented, packaged and distributed in strict compliance with all relevant applicable laws.

• Sanctions Compliance

Screening customers and transactions against global sanctions lists according to Kerry Logistics Network’s Sanctions Policy.

Prohibiting or restricting business activities or transactions or commencing customer relationships that we believe may violate the applicable sanction laws, whether directly or indirectly; or involve individuals, entities or vessels listed on an official sanctions list;

Blocking or rejecting business activities or transactions where we are obligated to do so under the applicable sanctions laws and regulations.

Avoiding participation in transactions in which the destination, end-use, or end-user is subject to a sanctions programme, including, but not limited to, those programmes of UN, EU, US and PRC sanctions lists.

We will prohibit or restrict business activities or transactions or commencing customer relationships that we believe may violate the applicable trade compliance laws, whether directly or indirectly; or involve individuals, entities or carriers listed on an official sanctions list, dual use goods list, munitions list, including, but not limited to, Commerce Control List of United States of America and List of Dual-Use Goods and Technologies and Munitions List under the Wassenaar Arrangement.

We do not tolerate any breach of this policy that could jeopardise the soundness and integrity of Kerry Logistics Network. Any suspicious transactions should be reported to the designated manager of the local office, and if applicable, regional and global management office. Where necessary, we will also report breaches of trade compliance laws to the relevant regulatory authorities.

The effectiveness of this policy will be monitored regularly. Procedures and practices will be reviewed and further practical guidelines may be issued with a view to ensure trade compliance.