NORINCO holds firmly the position that any kind of proliferation, including that of Weapons of Mass Destruction (WMD), their components, means of delivery, and technologies, are conducive neither to world peace and stability nor to China's security, and is absolutely in contrary to NORINCO’s belief of being a corporation that is responsible for the benefit of all mankind. Over the years, NORINCO has always played an active role in non-proliferation in the international community and decided its core values as pursuing sustainable growth, maintaining corporate reputation, and assuming social responsibility.
NORINCO affirms its unequivocal and emphatic support for the Chinese government’s non-proliferation and strategic trade control policies, which NORINCO commits to abiding by fully and uncompromisingly, and resolutely supports the Chinese government’s international commitments and obligations, the United Nations Security Council’s resolutions, and the best practices in international strategic trade management and non-proliferation.
Effective strategic trade management requires joint efforts between the government and the company. In order to ensure the fulfillment of its non-proliferation and strategic trade control obligations, NORINCO has established and implemented a multi-faceted Internal Compliance Program (ICP) and continually works to further develop and enhance that program, as well as its overall compliance efforts to prevent the proliferation of WMD and their means of delivery and control the proliferation risks of conventional defense products and technologies, dual-use goods and technologies, intangible technology transfers (ITT) and deemed exports.
By adopting a “catch-all” approach to export control and compliance, NORINCO places the goals of non-proliferation, peace, and stability above its commercial interests. In practice, NORINCO, in accordance with its corporate policy, will voluntarily apply the most stringent rule in trade control, and neither directly nor indirectly supply products, technologies or services if NORINCO knows or has reason to believe that such items could be used by its customer or the ultimate end-user for the development or production of WMD and their means of delivery, or such exports may undermine international, regional or the recipient country’s security and stability, or such exports may pose end-user or end-use risks such as falling in the hands of terrorist organizations or terrorists, even if the deal is legal according to export control laws and regulations. In addition, NORINCO will endeavour to make sure that all of its dual-use products and technologies go only to their authorized end-use and end-user.
In order to ascertain what products, technology and services, as well as which customer and end-user, should be regarded as sensitive, NORINCO has established and maintained close relationship with Chinese government, relevant NGOs and non-proliferation and export control experts for information, instruction and advice. Additionally, NORINCO is committed to carefully screening all countries, customers, end-users, end-uses, and controlled military and dual-use products to ensure that all transactions comply with NORINCO’s regulations and norms, domestic laws and international obligations.
To ensure the effective implementation of its ICP, NORINCO established the ICP Council and ICP Office, which are authorized to veto any order in question. The ICP has been institutionalized by the issuance of non-proliferation and export control guidance and regulations; establishment and implementation of an automated, fully integrated order screening system that includes three screening databases – one for sensitive countries, one for sensitive end-users and the other for controlled products; execution of comprehensive record keeping rules for export control-related documentation; passage of regulations on education; implementation of a multi-tiered training program; use of scheduled and random internal audits; close cooperation with related parties; correctional measures to regulate staff behavior; and signing of a non-proliferation and export control letter of responsibility between corporate executives and managers of operational departments and subsidiaries.
The NORINCO ICP Council is the principle body on company export control related matters. Mr. Cheng Hong, vice president of NORINCO, is appointed as the chairman of the ICP Council, and other vice presidents, including Mr. Liu Jinkui, Mr. Qiang Wenyu, Mr. Xu Hongyu and Mr. Wang Chuan, as the vice chairmen of the ICP Council. The ICP Council is also comprised of representatives from business units and management divisions. The NORINCO ICP Office deals with the daily work of the company’s export control policies and procedures, The director of the ICP Office is Mr. Zhong Xiaoping. In addition to these two established ICP bodies, each NORINCO unit and subsidiary have a designated ICP Officer or representative, who will work with the ICP Council and ICP Office and help coordinate the export control compliance work for that particular unit or subsidiary.
All NORINCO employees will actively work to achieve the corporate goal of non-proliferation by participating in training and strictly abiding by corporate policy. NORINCO has established regulations on incentives and punishments, which will encourage compliance efforts and punish violations or failures. Any violator will face serious consequences and will be prosecuted according to law if he or she commits a criminal offense. Any violation again company internal compliance regulation can be reported to the ICP Office by E-mail (norinco-icp@norinco.cn), and the informants’ identity will be kept strictly confidential.
This policy applies to all divisions and subsidiaries of NORINCO worldwide. This policy will be reviewed and revised on an annual basis in order to incorporate the latest developments of non-proliferation and export control.
President Mr. Chen Defang
China North Industries Corporation