Shipping policy
The Haines Company LLC. is committed to compliance with all export controls in the Export
Administration Act (EAR) and the Export Administration Regulations.
The Haines Company LLC. acknowledges and expressly agrees that certain laws of the United
States including, but not limited to, the U.S. Export Administration Act, the U.S. Export
Administration Regulations (including the anti-boycott provision), and the laws and regulations
administered by the Office of Foreign Assets Control ("OFAC"), apply to all activities conducted
by or on behalf of The Haines Company or involving The Haines Company products. The
application of such laws may result in the imposition of penalties and sanctions on The Haines
Company and The Haines Company Agents in the event the products supplied by The Haines
Company are distributed in violation of those laws. The Haines Company Agents are required to
agree that they will comply strictly with all such laws.
It is the expectation of The Haines Company that all The Haines Company Agents will comply
with all applicable U.S. laws relating to ethical business practices, including the U.S. Foreign
Corrupt Practices Act. The Haines Company Agents are also expected to comply with the
requirements of the applicable laws of any other country relating to the conduct of ethical
business practices. The Haines Company Agents should understand that The Haines Company is
subject to the laws of the United States that apply to activities carried on outside the United
States, and The Haines Company Agents understand that they will not take or omit to take any
action if such act or omission might cause The Haines Company to be in violation of any such
laws. It is The Haines Company policy that no payments or gifts of any kind will be made to any
government official to obtain any business or business advantage. This policy also prohibits so-
called "facilitation payments," which are payments intended to encourage a government official
to perform a duty the official is already obligated to perform.
THE HAINES COMPANY LLC.
MEMO
2
Upon written request from The Haines Company, The Haines Company Agents will be expected
to promptly provide The Haines Company with any and all such information that The Haines
Company might reasonably consider necessary to verify compliance with this policy. Each
Haines Company Agent is expected to maintain adequate export policies and procedures to
ensure strict compliance with the EAR, the regulations of the Office of Foreign Assets Control,
and any other applicable export regulations.
I ask each of you to take this matter very seriously and to support me in this effort. If you have
any questions concerning the legitimacy of a transaction or potential violations, please contact:
Deric C. Haines, Owner.
Administration Act (EAR) and the Export Administration Regulations.
The Haines Company LLC. acknowledges and expressly agrees that certain laws of the United
States including, but not limited to, the U.S. Export Administration Act, the U.S. Export
Administration Regulations (including the anti-boycott provision), and the laws and regulations
administered by the Office of Foreign Assets Control ("OFAC"), apply to all activities conducted
by or on behalf of The Haines Company or involving The Haines Company products. The
application of such laws may result in the imposition of penalties and sanctions on The Haines
Company and The Haines Company Agents in the event the products supplied by The Haines
Company are distributed in violation of those laws. The Haines Company Agents are required to
agree that they will comply strictly with all such laws.
It is the expectation of The Haines Company that all The Haines Company Agents will comply
with all applicable U.S. laws relating to ethical business practices, including the U.S. Foreign
Corrupt Practices Act. The Haines Company Agents are also expected to comply with the
requirements of the applicable laws of any other country relating to the conduct of ethical
business practices. The Haines Company Agents should understand that The Haines Company is
subject to the laws of the United States that apply to activities carried on outside the United
States, and The Haines Company Agents understand that they will not take or omit to take any
action if such act or omission might cause The Haines Company to be in violation of any such
laws. It is The Haines Company policy that no payments or gifts of any kind will be made to any
government official to obtain any business or business advantage. This policy also prohibits so-
called "facilitation payments," which are payments intended to encourage a government official
to perform a duty the official is already obligated to perform.
THE HAINES COMPANY LLC.
MEMO
2
Upon written request from The Haines Company, The Haines Company Agents will be expected
to promptly provide The Haines Company with any and all such information that The Haines
Company might reasonably consider necessary to verify compliance with this policy. Each
Haines Company Agent is expected to maintain adequate export policies and procedures to
ensure strict compliance with the EAR, the regulations of the Office of Foreign Assets Control,
and any other applicable export regulations.
I ask each of you to take this matter very seriously and to support me in this effort. If you have
any questions concerning the legitimacy of a transaction or potential violations, please contact:
Deric C. Haines, Owner.