Export Administration and International Economic Sanctions
KBR, Inc. and Subsidiary Companies
Corporate Policy
Date: November 10, 2006
Index No.: 3-0010
Purpose:
This Policy provides guidelines for compliance with the requirements of United States export administration and international economic sanctions Laws and regulations, the requirements of export licenses issued by the United States Department of Commerce, the United States Department of State, the United States Department of the Treasury and other agencies, that require the Company to have an effective and comprehensive internal control program to monitor compliance with the applicable regulations.
Policy:
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The Company will comply with the United States Export Administration Act ("EAA") and the Export Administration Regulations promulgated thereunder ("EAR"); the Arms Export Control Act ("AECA") and the International Traffic in Arms Regulations promulgated thereunder (the "ITARS"); regulations to implement international economic sanctions programs involving particular countries, including regulations promulgated by the Office of Foreign Assets Control of the Department of the Treasury; any subsequent Laws and regulations of similar effect to the foregoing; any other export Laws and regulations as from time to time may be in force; and the terms and conditions of any license issued pursuant thereto. No business will be transacted nor item exported in contravention of the foregoing.
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Each Director, Employee and agent of the Company shall comply with the EAA and the EAR, the AECA and ITARS, international economic sanctions and all other export administration Laws and regulations, and all applicable rules, systems and procedures issued and established to comply with this Policy. There shall be no exception to this Policy, nor shall it be compromised or qualified by anyone acting for or on behalf of the Company.
Procedure:
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The Company shall establish and maintain a comprehensive internal control program ("Program") to ensure compliance with the Laws and regulations described above and licenses issued thereunder, and shall appoint a manager responsible for export control matters. Such manager shall report to the General Counsel who shall be responsible for operating such Program.
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The export control manager shall operate the Program so that it meets the applicable compliance requirements of applicable Law. The export control manager shall monitor compliance with the Program and shall report any failures to the General Counsel or his or her designee. The Program shall include rules, systems and procedures that will ensure compliance with the applicable Laws and regulations and the terms and conditions of all licenses issued to the Company thereunder.
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The Company shall maintain a continuing program to keep its Employees and agents advised of the applicable provisions of the export control and international economic sanctions Laws and regulations and the requirements of the Program. Any Employee or agent having a question on matters having possible implications under such Laws and regulations shall refer the question to the export control manager or the General Counsel.
Other References:
1. Corporate Policy No. 3-0011 (Boycotts) should be consulted.
Approved: Board of Directors
November 10, 2006