Toray Advanced Materials Korea Inc. formed an autonomous compliance management organization to manage all internal and external security trade control activities, e.g. export and domestic trading of strategic items, more effectively according to the security trade control policy of Toray Group. As a result, we established the security trade control processes, e.g. organic division of works in consideration of the attributes of each organization, strategic items and technologies Y/N, customer approval, transaction approval and shipment management, and we are systematically operating them all.

Autonomous compliance management organization

In July 2012, according to Article 74 of Public Notice on Trade of Strategic Items, we installed an enterprise-wide autonomous compliance management organization headed by the CEO/president in Corporate Strategic Planning Division, which is independent from the sales division. Also, we installed a secretariat at each business division separate from the enterprise-wide organization, and ensure that the head of the business division will be responsible for performing the primary security trade control function, and clarify the role and responsibility of each person in charge by means of a power of attorney and a certificate of appointment.

Strategic items and technologies Y/N (non-applicability assessment)

Non-applicability judgment is the starting point of strategic items management. It is a process of checking if the product or technology to be traded is subject to control. Aside from the national strategic items assessment system, Toray Advanced Materials Korea Inc. is operating the internal assessment committee system for going through a certain internal procedure, and determining whether they are strategic items. Also, we developed a professional training program for improving our own assessment competency, and we are systematically training in-house assessment experts at each business division.

Customer approval

Customer approval is the core function of security trade control, which finally determines whether to trade strategic items and technologies by verifying consumers of domestic and overseas transactions and checking the usage. We conduct customer review for all people and institutions related to the distribution channels until products or technologies arrive at end users. Customer approval will be re-approved every year after the new approval, and certain customers will need to be approved by the Toray Security Trade Control Office. In addition, for domestic customers, the sales department is evaluating customer adequacy through on-site visits.

Transaction approval

Transaction approval is the final verification procedure for customers who completed customer review to prevent strategic items from being delivered to denied persons or being used for denied purposes. Not only exports, but also domestic transactions are subject to transaction review. All screenings are carried out through the Security Trade Control System, re-approved on a yearly basis after the new approval, and certain transactions must be approved by the Toray Security Trade Control Office.

Shipment management

Shipment management is the final procedure for checking export license information, customs clearance information and loading information of transactions which acquired export licenses, and preventing strategic items from being delivered to denied persons or being used for denied purposes. To minimize all errors likely to occur in the shipment process, we are managing them through the Security Trade Control System.