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Hilsabeck notes that just a partial list of the laws and regulations most exporters need to take into account in designing an ICP should include the following: Export Administration Regulations (EAR), antiboycott laws and regulations, Customs and Border Protection (CBP) laws and regulations governing exports and imports, Foreign Corrupt Practices Act, Arms Export Control Act, International Traffic in Arms Regulations (ITAR), Foreign Trade Statistics Regulations (FTSR), other industryspecific laws and regulations, and foreign laws and regulations To meet such a complex and demanding set of compliance requirements, Hilsabeck presents four fundamental rules for establishing and maintaining an effective ICP: 1 Flexible The ICP should be structured to adhere to changes in applicable laws and regulations governing the export transaction and be able to rectify weaknesses or deficiencies 2 Customized Your program should be individually tailored to meet the special needs of your company and industry nothing more, nothing less 3.



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lives a system of ethical rules and goals Some of these may be intentional, largely unitary, and, hopefully, operate in a functional manner to advance the interests of the organization and its members in a manner acceptable to the larger society of which it is a part Others believe they espouse and promote one set of ethical constructs but permit or allow one or more others to operate Remember, if you will, Leuci s comments about what he saw and experienced in the NYPD of the 1970s One need not envision a system of tyrannical psychological lock-step to acknowledge that within most organizations, while there may be differences of opinion and competing schools of thought, there tends to be an overriding ethical flavor that reflects what the organization is, or hopes to be, about Organizations typically share a common language with their members, be it technical, trade, or field based.





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Practical The ICP should be structured with a practical focus on the exporter s routine daily operations and activities 4 Channeled All ICP functions and responsibilities should be channeled to one central contact individual or department Core Elements of Successful Internal Compliance Program Setting up an internal compliance program requires a commitment from the top and an understanding of where and how the program interfaces with regulations like Sarbanes-Oxley Buy-in from upper management This means board-of-director level, says Hilsabeck It s vital that top management fully support and endorse the export ICP objectives and that this commitment be evidenced by a statement of corporate policy, she adds Hilsabeck has detailed advice regarding this statement: First, the statement should manifest the company s complete commitment to full compliance with all US.

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One need only sample the breadth of organizational archetypes to quickly learn that the language of employees in one construction company will have much more in common with another construction company across the country than it will with an insurance company that may be in the next building So, too, do individual organizations often seek to create a language that is unique to them, even against competitors in the same field Disney, for example, may refer to employees as cast, even though they are not in the direct entertainment part of that business Vanguard, the huge investment and financial services company located outside of Philadelphia, names its buildings after famous ships and refers to its employees as crew to advance the nautical motive it has adopted to differentiate itself So, too, do most organizations, consciously or otherwise, tend to develop a language that is in some way unique to them.

H ong Kong Telecom Interactive Multimedia Services have built a video-on-demand service using distributed objects. In this system, the client components that are used to display videos and the server components that load and transmit videos are considered as objects. They are distributed: clients are hosted by set-top boxes in the homes of the customers of the service and several video-on-demand servers were needed in order to make the system scale to its current 90,000 subscribers.

and foreign laws governing export transactions; second, it should identify the responsible in-house compliance personnel and oversight departments; and third, it should list the criminal and.

Organizations are about power and politics For many, this is one of the more unpleasant aspects of organizational life, but it is a reality nonetheless One need not only think of the petty bickering, backstabbing, and oneupsmanship when considering the role of politics and power in organizational life Like neighborhoods, organizations are groupings of social control with many facets important to their members Milton Kotler, in discussing the motivations for the student takeovers of some colleges and universities in the 1960s and 1970s has observed that these young people had developed a sense of neighborhood and community in the brief space of the several years they were in school They therefore came to believe they had a legitimate voice in the governance of their community Kotler makes the significant point that the power of one s group need not be controlling or absolute to be real.

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