EXPORT LAMCOR. Joint Industry Outreach on Strategic Trade Management. Bernadette B. Alitagtag. March 15, 2012 Dusit Thani Hotel Manila
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1 SECURITY EXPORT CONTROL Bernadette B. Alitagtag Sr. Specialist Corporate Export Control & Manager, Customer Service Joint Industry Outreach on Strategic Trade Management March 15, 2012 Dusit Thani Hotel Manila Ayala Center, Makati City 1
2 :: Outline of Presentation :: 1. Company Background 2. Background of Export Control in LAMCOR 3. Internal Compliance Program (ICP) 3.1 Objectives es Defined 3.2 Philippine Laws Related to Export Control 3.3 Organization for Export Control 3.4 Procedure (Export Control Flow) 4. Other Activities in the ICP 4.1 Transaction Screening 4.2 Order Control 4.3 Export and Sales Control 4.4 Education and Training 4.5 Formation of Core Team 5. Support from Mitsubishi Electric 6. Corporate Responsibility 6.1 Compliance to Other Philippine Laws 6.2 Certificates and Awards 6.3 Philanthropic Activities 2
3 :: 1. Company Background :: Laguna Auto-Parts Manufacturing CORporation (LAMCOR) Subsidiary of MITSUBISHI ELECTRIC CORPORATION of Japan Established in August of 1991 Located at Laguna Technopark, Don Jose, Santa Rosa City 35km south of Manila 200 operating companies inside Laguna Technopark Manufacturer of automotive parts PEZA-registered company No. of employees - 1,811 as of end of Dec
4 (Location) Manila Airport 35Km LAMCOR 4
5 in USD Amount :: 1. Company Background :: Sales Performance 2004 ~ ,000, ,000,000 80,000,000 60,000,000 40,000,000 20,000, * 2012* Total Domestic Export 5
6 :: 1. Company Background :: Main Products STATOR of ALTERNATOR (electricity it generator of STATOR automobile) 6.0 million pcs / year (FY 2012) 167mm ALTERNATOR 6
7 :: 1. Company Background :: Main Products Giant Magneto Resistance (engine rotation sensor) Length 60mm 3.0 million pcs / year (FY 2012) 7
8 :: 2. Background of Export Control in LAMCOR :: Export Control was introduced by Mitsubishi Electric in LAMCOR in LAMCOR committed to comply with all domestic export laws and implement internal export control. In 1997, the 1st Internal t l Compliance Program (ICP) was formulated for LAMCOR by Mitsubishi Electric. Since then, verifications and audits were conducted by Mitsubishi Electric on our implementation of the ICP. In 2003, our ICP formed part of our Quality System which we regularly update and maintain. 8
9 3. Internal Compliance Program (ICP) :: 3.1 Objectives :: 1. Defines our Objectives for Export Control as follows: To comply with the laws and regulations established as a means to contribute to the preservation of international peace and security. To implement appropriate controls over export or domestic transactions should the products or technologies be used in relation to weapons of mass destruction or conventional arms. To comply with the requirements of Mitsubishi Electric, being our parent company and a valued customer. 9
10 :: Philippine Laws related to Export Control :: 3. Internal Compliance Program 2. Enumerates the laws we have to know and comply with which includes among others: 2.1 *RA 6969 An Act to Control Toxic Substances and Hazardous and Nuclear Wastes, Providing Penalties for Violations Thereof, and for other purposes. 2.2 *PD 930 Promulgation of Rules and Regulations Further Simplifying Export Procedures and Documentation (EO 1016 Revised list of products that are prohibited and regulated for exports) 10
11 3. Internal Compliance Program :: 3.2 Philippine Laws Related to Export Control :: 2.3 *EO 39 Designating the Anti-Terrorism Council as the Philippine National Authority on the Chemical Weapons Convention (CWC) and Other Disarmament Laws of the Philippines 2.4 *EO 522 Prescribing Rules and Regulations for the control and Supervision of the Importation, Sale and Possession of Chemicals Used as Ingredients in the Manufacture of Explosives, and for their Purposes * These are just examples of laws we requested our corporate lawyer to provide to us. We are eagerly awaiting for the pending bills in the Senate to be passed into law which are An Act to Prevent the Proliferation of Chemical, Biological, Radiological and Nuclear Weapons and An Act to Prevent the Proliferation of Weapons of Mass Destruction 11
12 :: 3.2 Organization for Export Control :: 3. Identifies Responsibility/Authority President (Overall In-charge of Export Control) Export Control Administrator (ECA) (Implements the Corporate Export Control) 3. Internal Compliance Program Administration Finance / MIS Security Human Resources Training Consumable Storage Import/Export MIS Accounting Support Group Production Engineering & Maintenance Sales Planning Purchasing Warehouse Delivery Customer Service Manufacturing Packaging Engineering Maintenance Facilities Capital Equipment Quality Assurance/ Quality System QC (per line) Incoming Quality Dock Audit Calibration ISO/TS/EMS 12
13 3. Internal Compliance Program :: Procedure :: 4. Defines the Procedure we follow for each and every transaction of our operations (Export Control Flow shown on next page). 13
14 :: 3.4 Export Control Flow :: 3. Internal Compliance Program Inquiries / New Orders Repeat Orders Other Requirements 1 st Screening Classification of products or technologies Destination Customer End-Use Transaction Conditions Transaction 2nd Screening / Manufacturing Feasibility / Product Development Contract Review For New Orders Brief Checklist List of Product Matrix Destination List Denied Persons List Customer Screening Form Transaction Screening Form Team Mfg Feasibility Commitment Follow Procedure on Contract t Review (Both for New Orders and Repeat Orders) Decision on OrderAcceptance Consult as necessary 14
15 :: 3.4 Export Control Flow :: 3. Internal Compliance Program New Orders Order Acceptance Repeat Orders Other Requirements Advanced Product Quality Planning Documentation & Export Approval Application (direct export) Shipment Documentation MASS PRODUCTION CHECKLIST Philippine Export Zone Authority (PEZA) Requirements Verification of the contents of shipment Verification of the contents of shipment Checking of Actual Item vs. Documents Protective Measures against Illegal Exports and Improper Resale and Diversions Protective Measures against Illegal Exports and Improper Resale and Diversions LETTER OF ASSURANCE (Check validity of LOA for Repeat Orders) Shipment or Supply Record Keeping Shipment or Supply Record Keeping Indication of warning notice as necessary. 15
16 :: 4.1 Transaction Screening :: 4. Other Activities in the ICP 1 st Screening using the Five Key Elements Classification Determine if item is controlled or not Destination Check Export Destination Customer / End User Confirm if end use is WMD-related End Use Confirm if end use is WMD-related Overall transaction conditions Consult as necessary 16
17 4. Other Activities in the ICP :: 4.1 Transaction Screening :: 2 nd Screening by Export Control Administrator Accomplishment of Team Manufacturing Feasibility Commitment Evaluation of Transaction Screening (1 st Screening) Assistance of Mitsubishi Electric Group (as necessary) As a domestic manufacturing company engaged in the importation and exportation from and to Japan and other countries, LAMCOR follows both Philippine laws and the regulations of Japan and other countries related to Export Control o thru Mitsubishi s Electric c Group. Therefore, when in doubt we refer the matter to Mitsubishi Electric Group for advice. 17
18 4. Other Activities in the ICP :: 4.2 Order Control :: Before Mass Production, we ensure that the proper screening for Security Export Control was conducted. Export Approval Application with concerned government agencies is obtained. We ensure appropriate and correct documentation of our transactions. 18
19 4. Other Activities in the ICP :: 4.3 Export & Sales Control :: We also follow the Foreign Exchange and Foreign Trade Law of Japan and therefore: We do not sell components/parts for vehicles to be used for military applications. We do not transfer technology or software that can be used for military applications. We do not produce specially-designed products for military applications. We do not transfer or resell machineries and equipment for the use in relation to weapons of mass destruction or conventional arms. 19
20 4. Other Activities in the ICP :: 4.4 Education & Training :: LAMCOR ensures that t employees have undergone proper orientation and training on Security Export Control. An internal audit is conducted at least once a year. We have also included the suppliers in our progran on Export Control and dto enhance their knowledge we intend dto hold a seminar for them to be held within the middle of this year. The ECA goes to the site from time to time to check the Export Control activities and to remind the employees about the importance of consistent implementation of the ICP. 20
21 4. Other Activities in the ICP :: 4.5 Formation of Core Team :: Each Management Committee member is a member of the Core Team to ensure compliance of the ICP in each Department/Section. The Core Team meets regularly every other month to discuss each department s concerns and activities and also it is the venue for the ECA to give updates. 21
22 :: 5. Support from Mitsubishi Electric :: Export Control Manual Mitsubishi Electric provides updated manual to LAMCOR for use as our reference. Education and Training i To upgrade our skills on Export Control, Mitsubishi Electric continually conducts training to LAMCOR Core Team. Verification and Audit The Automotive Equipment Group of Mitsubishi Electric Headquarters conducts regular verification and audit on LAMCOR Export Control activities to ensure compliance to our ICP. 22
23 6. Corporate Responsibility :: 6.1 Compliance to Other Philippine Laws :: As a Corporate Responsibility, LAMCOR respects other Philippine laws such as: Corporation Code of the Philippines Philippine Special Economic Zone Act The Labor Code of the Philippines Environmental Management laws etc. LAMCOR has designated Representatives (Vice-President or General Manager level) to ensure compliance of the above laws and institute controls to maintain our corporate ethical standard. These are: - CEO (Chief Compliance Officer) - ECA (Export Control Administrator - ICFT (Internal Control over Financial i Reporting) - Internal Control - Security Control - EMR (Environmental Management Representative) ti LAMCOR has self-check and self-audit system and submit report to the President. 23
24 :: 6.2 Certificates & Awards :: 6. Corporate Responsibility ISO/TS16949 ISO14001 since May 2006 since Aug 2005 EXEMPLARY PARTICIPATION & CONTRIBUTION TO ENVIRONMENTAL PROJECTS LTI RECOGNITION November 2010 OUTSTANDING ENVIRONMENTAL PERFORMER PEZA AWARD April 2007 and March 2011 Company President received the award from President Aquino & PEZA Director General Lilia De Lima 24
25 :: 6.3 Philanthropic Activities :: 6. Corporate Responsibility School Donations Charitable Donations Environmental awareness programs 25
26 LAMCOR is a Japanese company but our operation is in the Philippines. So we will keep and uphold Philippine laws and we will continue to do our share to improve the quality of life of the Filipino people. Thank You! 26
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