Policies & Compliances Details

BidChip is a global company. BidChip warehouses are located in several countries. This Principle helps ensure that BidChip complies with all export, import, and trade compliance laws in all of its global business activities.
This Principle applies globally to all traders (buyer/ seller) and may apply to those acting on behalf of BidChip.

Trade Control Laws Generally

• Follow BidChip trade compliance policies and standards, and engage BidChip’s Global Trade Compliance Department as directed by those policies and standards.
• BidChip’s Global Trade Compliance Department in NJ, after review by BidChip Legal Affairs in NJ, must assess any potential violations and direct all correspondence and submit any trade compliance-related disclosures related to an actual or potential violation of any trade compliance laws to the Canadian & U.S. governments or any government entity located in the United States. The trader (buyer/ seller) must contact their assigned BidChip counsel to discuss any matter of concern and communicate appropriate issues to BidChip’s Global Trade Compliance Department in NJ or BidChip Legal Affairs in NJ.

• Comply with all applicable U.S. export control laws and regulations, as well as those of the countries in which BidChip conducts business. Export control laws can apply to the transfer of products, technology, technical data, services, software, spare parts, samples, and equipment physically across borders, as well as the sharing of export-controlled technology and technical data within a single country to persons who are not citizens or unillegible to have access to such information.
• Consult with BidChip’s Global Trade Compliance Department in NJ, your subsidiary’s Export Control Coordinator (ECC), or your assigned BidChip legal counsel prior to engaging in business activity of any kind in countries subject to embargoes or other trade sanctions, or with government officials, businesses, financial institutions, or citizens of those countries. Additional information on this topic can be found in the BidChip Trade Embargo and Trade Sanctions Policy.
• Engage BidChip’s Global Trade Compliance Department in NJ in the early stages of New Technology or Product Introduction (NTI/NPI) projects, to determine the proper export classification and licensing requirements. Only BidChip’s Global Trade Compliance Department in NJ and those it expressly designates are authorized to determine export classifications, licensing requirements, and apply to government agencies for the purpose of securing export licenses or other authorizations.
• Comply with all conditions, restrictions, and reporting requirements of export licenses and authorizations, as well as export control plans established by your Export Control Coordinator.
• Consult with BidChip’s Global Trade Compliance Department, Information Technology, Security, as well as your Export Control Coordinator, to develop and sustain effective technology and deemed export control plans.
• Follow all applicable local country export reporting laws and regulations for all transfers of goods, including but not limited to products, materials, sales samples, demonstration units, equipment, and temporary exports.
• Do not transfer any export-controlled items or technology or services without the required export authorization.
• Do not approve or make any U.S. export control representations or certifications in any type of agreement or other documents without prior review of BidChip Legal Affairs in NJ.
• Do not store export-controlled technology on electronic databases or in other locations without access controls.
• Do not establish BidChip company as a non-resident exporter unless expressly authorized by BidChip Global Trade Compliance Department in NJ.
• Because numerous BidChip products are subject to export control and related regulations, BidChip should be the exporter of record on all export shipments. BidChip-designated freight forwarders must be used to clear export formalities. Any deviation from this must be approved by the BidChip Global Trade Compliance Department in NJ.
• The BidChip Global Trade Compliance Department in NJ is primarily managing compliance and control plans with respect to existing regulations. Any changes to control plans or strategies introduced by business opportunities, acquisitions, or functional initiatives, must be approved by BidChip’s Global Trade Compliance Department to ensure continued compliance.
• When establishing new suppliers, partners, brokers, agents, financial institutions, freight forwarders, and customers, contact your BidChip Logistics department to conduct a “restricted party review” to ensure BidChip is not interacting with money-launders, terrorists, drug dealers, or export control violators.
• Review with BidChip Global Trade Compliance in NJ of any known or suspected use of BidChip products or services for nuclear, biological/chemical warfare, missile development or stockpiling, or unmanned aircraft.

• Never cooperate with any restrictive trade practice or boycott that is prohibited by the U.S. or applicable local laws. An “illegal boycott request” under U.S. law is any request from a third party to take any of the following described actions against countries friendly to the U.S., including but not limited to Israel:
  • Refusal to do business with or in Israel, or with other persons or entities that do business in or with Israel, or other countries friendly to the U.S.
  • Furnishing information about business relationships with or in Israel;
  • Discriminating against someone based on race, religion, sex, national origin, except in cases where such information is related to valid government documents such as visas;
  • Executing business documents such as contracts, letters of credit, and warranties that contain illegal boycott requests (such as prohibiting Israeli product content, product content, product delivery through Israel, Israeli business dealings, etc.).
• To comply with the time-sensitive U.S. required boycott reporting regulations, all boycott requests received by BidChip must be immediately reported to the business unit’s assigned export control/anti-boycott coordinator or to BidChip’s Trade Compliance Department in NJ.

Do not alter country of origin claims, move to manufacture, or otherwise change business practices to comply with an illegal boycott request.

• Follow all applicable U.S. and local country customs and import laws and regulations, including those requiring accurate documentation, country of origin markings, classification of the goods, and proper valuation declarations, including those of non-cash value (sample components).
• Seek the advice and guidance of the local assigned import manager or BidChip’s Global Trade Compliance Department in NJ when participating in any special duty reduction programs, such as those under free trade agreements (NAFTA, CAFTA, etc.), bonded warehouses, temporary importations under bond, bonded books, or duty drawbacks. Only BidChip’s Global Trade Compliance Department is authorized to approve any claims of the country of origin or eligibility for free trade agreements that involve a trade agreement with the U.S., or U.S. government contract.
• Use the only BidChipTrade Compliance designated Customs brokers.
• Instruct and work with suppliers to provide accurate trade compliance data and documentation.
• Establish required cargo security controls at all applicable facilities that ship or receive products internationally and instruct international suppliers to also establish security controls.
• Do not establish a BidChip company or supplier as a non-resident importer unless expressly authorized by BidChip Global Trade Compliance Department in NJ.
• Do not establish a program or process that introduces the risk of non-compliance to the established trade compliance controls or existing regulations without the approval of BidChip’s Global Trade Compliance Department. Any such approval will require the implementation of necessary compensating controls to ensure continued compliance.
• Direct all correspondence with local Customs authorities through the local BidChip Import manager or BidChip’s Global Trade Compliance Department in NJ.
• Do not provide any certifications or representations of the country of origin of a product without prior written approval from BidChip’s Trade Compliance Department.
• Do not provide inaccurate, incomplete, or unsubstantiated invoice or import documentation, including those related to product description, classification, valuation, country of origin, or quantity.
• Do not complete Free Trade Agreement Country of Origin certifications without proper backup documentation and complete analysis.
• Report to the local Trade Compliance manager all amendments to Customs declarations for pricing adjustments, indirect payments, or credits received.

Penalties:
Failure to comply with the export, import, and trade compliance laws could lead to criminal and civil penalties for you personally, significant business disruptions, and harm to BidChip’s reputation. Violations of BidChip’s Trade Compliance Principle will result in discipline, up to and including termination from trading on the site.