EU CODE OF CONDUCT - EU EXPORT COMPLIANCE COMMITMENT

Organizations and individuals shall:

adopt the European Code for Export Compliance (EU-CEC) as management framework for their import/export and make their commitment to implement the Principles and guidelines  as  guiding  values of their activities.

Export Compliance provides support in compliance risk management, i.e. the risk of legal or administrative sanctions, financial losses or reputation deterioration for failing to comply with EU laws, regulations and legislation, codes of conduct and good practice. The Organizations are committed to comply with all Export laws, regulations and norms in the EU and is a policy for all their employees. 

Any of Organization's employees may not import/ re-route/re-export any commodity, technology, or software unless appropriate authorization has been obtained by the EU Supplier, and this includes foreign-produced items that are the direct product of EU, technology and software.

No activities will be undertaken that are in violation of the EU policies which seek to control nuclear proliferation, missile technology, chemical and biological weapons, untraceable payments or transfer of funds and any other regulated activity without proper authorization or license.

Failure to comply with these regulations may result in the imposition of criminal and/or civil fines, penalties and cancellation from the Register of EU Compliant Organizations and the EIFEC Register Number (ERN) suspended or revoked. 

Organizations will act and communicate in a transparent manner, in their relation with EU and member states Institutions, and all stakeholders  about operating EU Export Compliance policy, and the economic, financial and legal implications of each activity undertaken.
It is included their commitment to EU transparency Code of Conduct norms where in relations with the EU institutions and their Members, officials and other staff Organizations will always:

• identify themselves by name and by the entity or entities they work for or represent; declare the interests, objectives or aims promoted and, where applicable, specify the clients or members whom they represent; 

• not obtain or try to obtain information, or any decision, dishonestly, or by use of undue pressure or inappropriate behavior; 

• not claim any formal relationship with the EU or any of its institutions in our dealings with third parties, nor misrepresent the effect of Registration in such a way as to mislead third parties or officials or other staff of the EU except those provided by EU Export Compliance Certification (EU- C/ECO); 

• ensure that, to the best of their knowledge, information which they provide upon this Registration and subsequently in the framework of their activities within the scope of the registration is complete, up-to-date and not misleading; 

• not induce Members of the EU institutions, officials or other staff of the EU, or assistants or trainees of those Members, to contravene the rules and standards of behavior applicable to them; 

• if employing former officials or other staff of the EU or assistants or trainees of Members of the EU institutions, respect the obligation of such employees to abide by the rules and confidentiality requirements which apply to them; 

• observe any rules laid down on the rights and responsibilities of former Members of the European Parliament and the European Commission; 

• inform whomever they represent of their obligations towards the EU institutions.

All Organisations and self employed individuals, irrespective of their legal status, engaged in activities falling within the scope of the EU Export Compliance Register (EU-ECR) are in principle expected to register.

• Academic institutions

• EIFEC member

• EU National Authorities

• Export Compliance Professionals

• Financial Institutions

• Law Firms

• NGO Non-governmental organisations, platforms and networks and similar

• NON EU Authorities, Sovranational Entities

• Standards Organizations

• Think tanks and research institutions

Exceptions or precisions to this principle concerning:

Churches and religious communities, Political parties, Local, regional and municipal authorities as follows:

• Churches are not concerned by the EU-ECR. However their representation offices or legal bodies, offices and networks acting within the scope of the EU-ECR are expected to register.

• Political parties are not concerned by the register. However any organisations which they create or support, engaged in activities falling under the scope of the register, are expected to register. 

• Local, regional and municipal authorities are not concerned by the register. However their representation offices or legal bodies, offices and networks created to represent them towards the European institutions, as well as their associations, are expected to register. 

Under the EU Transparency Register Code has been precised by the following public statement made by VP Sefcovic: "Services forming an integral part of their administration, staffed by local, regional or municipal officials and engaged in activities corresponding to their institutional or constitutional attributions, will thus not be expected to register". Indeed autonomous structures, with a private legal status, which would include subnational public authorities but which would be also shared with private interests, created in order to pursue activities falling within the scope of the Register would be expected to register”.

EU Member States governments, third country governments, international intergovernmental organizations as well as their diplomatic missions are not expected to register

HOW TO REGISTER YOUR ORGANIZATION

Today Registration is only for natural person  or orgzniations:

• Academic institutions

• EIFEC member

• EU National Authorities

• Export Compliance Professionals

• Financial Institutions

• Law Firms

• NGO Non-governmental organisations, platforms and networks and similar

• NON EU Authorities, Sovranational Entities

• Standards Organizations

• Think tanks and research institutions

• For Profit Organizations

The following Organizations are de iure registered:
EU National Auhtorities

TO REGISTER GO HERE AND CHOOSE THE APPROPRIATE SECTION

TO LOGIN GO HERE AND CHOOSE THE APPROPRIATE SECTION

SUBMIT A COMPLAINT TO THE EU EXPORT COMPLIANCE REGISTER

Non-compliance with the EU Trasparency Code of Conduct and EU Export Compliance Code (EU-CEC) by registrants/members or by their representatives may lead, following an investigation paying due respect to the principle of proportionality and the right of defence, to the application of measures such as suspension or removal from the EU Export Compliance Register and, if applicable, withdrawal of EIFEC Registration Number (ERN).

A decision to apply such measures may be published on the register's website.

Anyone may lodge a complaint, substantiated by material facts, about suspected non-compliance with the Code of Conduct and EU-CEC.

Procedure for the investigation and treatment of complaints.

EIFEC has specific regulation for Procedure for the investigation and treatment of complain.

The document is available for download here 

All efforts are made to keep highest confidentiality on information received and correctness in checking evidence.

TO SUBMIT THE COMPLAINT GO HERE AND CHOOSE THE APPROPRIATE SECTION 

FREQUENTLY ASKED QUESTIONS FAQS

To prevent overflowing our helpdesk with the most Frequently Asked Questions (FAQs) on the EU Export Compliance Register (EU-ECR) you will find here a document to download for your direct consultation which provides answers to a series of basic questions, as well as to a number of questions which will emerge over time as significant for registrants. 

It will also be progressively enhanced as practical cases will lead to the production of interpretative decisions regarding the implementation of EU Export Compliance Framework ( EU-ECF)

DOWNLOAD HERE 

EU EXPORT COMPLIANCE REGISTER - EIFEC CHARTER MEMBER REGISTER - DATA PROTECTION

This privacy statement explains how the EU Export Compliance Register (EU-ECR) / EIFEC Charter Member Register uses any information you give to us, and the way we protect your privacy.

1. The purpose and objective of the  EU-ECR “EIFEC Register"

To enhance the implementation of EU Export Compliance Framework (EU-ECF) best practice a Register (EU-ECR) for organizations and self-employed individuals engaged in EU import/export and policy implementation has been activated.

The EU Export Compliance Register (EU-ECR) has been set up to offer a single EU Code of Conduct and EU Export Compliance Commitment, binding all Organizations and self employed individuals which accept to “play by the rules” in full respect of ethical principles. 

All Organizations that have adopted the EU-ECR and have successfully past the Verification/Certification process are becoming so an EU Certified Export Compliant Organization EU-C/ECO (Charter Member). Becoming a Charter Member means that you voluntarily adopt the European Code for Export Compliance (EU-CEC) and submitted your organization to a verification process and, if it will conclude positively you will become a EU Certified Export Compliant Organization (EU-C/ECO) as set by EIFEC 2018 Code Standards.

In addition will allow organizations and self employed individuals engaged in EU Export activity to get information about the landscape of European policy-making and policy implementation as comprehensively as possible.

The EU-ECR is managed by the EIFEC Register Secretariat. The EU-ECR contains a web-based voluntary registration system. While registering, the organisms will also have to subscribe to the code of conduct and the EU Export Compliance Code available on this same web site.

2. What personal information do we collect and for what purpose?

The registration system entails disclosing facts about who the organisms are and whom they represent, what their mission is. These data are collected via the online subscription form available on this same website. The personal data concerning the contact persons, collected from the web-based registration interface will not be made available for consultation to the any party except those who are entitled as Eu National Authorities or Registered Financial Institutions on the EU-ECR website. The data are solely collected for the specific purposes laid down in this privacy statement and will not be used for any other purpose.

3. Who has access to your information and to whom is it disclosed?

The EU-ECR is available on the Internet for consultation by Registered and Authorized Users only, All information will not be shared with third parties except the EIFEC Number and Certification Expiry date. The mailing list is managed by the authorized webmaster. The authorized webmaster can also delete data if it is found to be out of date or incorrect or if the values, objectives and/or actions of the registered organism are contrary to the principles of the EU as defined in article 6, § 1 and 2 of the Treaty of the European Union. In this case the Registrant will be notified about the procedure followed by the EIFEC Register Secretariat for deleting a record from the database.

4. How do we protect and safeguard your information?

Immediately after the submission of the form, your replies are recorded in a secured and protected database hosted by the Data Centre of EIFEC. Your organisation's identification data are transmitted securely over the network (via Secure Sockets Layer (SSL)) to the EIFEC web server. Inside the institutions the whole database can only be accessed by a limited number of persons using a UserId/Password.

5. How can you verify, modify or delete your information?

The EU-ECR is an opt-in service. Access for modifying submitted data at any moment is only granted to the registered users through a Login/Password. You have to request a modification of your data submitting at Online Support at My EIFEC section. If it is approved, you will be notified by email. You may verify the accuracy of the information and, if necessary, request to correct it by accessing the web interface.

6. How long do we keep your data?

We keep your data for as long as you are registered, or until the data is found to be out of date or incorrect. You must update your data at least once a year. For transparency reasons your data will be kept in the non-public part of the database for 5 years after the last action in relation to the registration.

7. Contact Information

In case you have questions related to this e-Service or concerning any information processed in the context of this service, feel free to contact the EIFEC Register Secretariat, using the contact form available on this website.

GO HERE FOR FULL LEGAL NOTICES AND GENERAL CONDITIONS 

EU EXPORT COMPLIANCE REGISTER LEGA NOITICES AND PRIVACY POLICY

The Register is part of the policy of honesty endorsed with the EU Export Compliance Framework about the relations with Organisations and self-employed individuals engaged in import /export with the EU. Registering is voluntary and in no way implies that your Organisation or self-employed individual has been given any form of recognition, approval or accreditation by the European Institutions. For those who have voluntarily submitted to the Certification process and to the effects limited by Certification regulations and standards may state that are a EU Certified Export Compliant Organization/Person and use the EIFEC logo/EIFEC Number and seal in their communications. The information in the Register is provided by the registered organisations and is the sole responsibility of those organisations. The EU Export Compliance Register Secretariat reserves the right to remove from the Register any organisation whose values, goals and/or actions are contrary to the principles of the EU as laid down in Article 6(1) and (2) of the EU Treaty and in breach of EIFEC regulations. The Register contains links to external sites which EIFEC have no control over and for which we cannot be held responsible. The fact that these links are provided does not constitute either approval or a guarantee regarding (i) the organisation (or individual) responsible for managing or providing the content on any of the sites, (ii) the services advertised there, (iii) the content on the sites or (iv) any opinions expressed there.

European Institute For Export Compliance (“Institute”), an European organization, requires that all the visitors to our site adhere to the following rules and regulations. By accessing the Site you indicate your acknowledgment and acceptance of these terms and conditions.

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Transmission of personal data user acknowledges and agrees that by providing the Institute with any personal or proprietary user information through the site, user consents to the transmission of such personal or proprietary user information as necessary for processing in accordance with the Institute’s standard business practices. User should be aware that linked sites may contain transmission of personal data provisions that differ from the provisions provided herein. The Institute is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.

Press releases all press releases and other materials presented or released to the international trade community that are contained on the site were, to the best of the Institute’s knowledge, timely and accurate when issued. However, the passage of time can render information stale, and you should not rely on the continued accuracy of any such material beyond the date of issuance. The Institute has no responsibility to update any information contained in any such material. All viewers should carefully check the dates of issuance of the material contained in the Site.

POSTINGS The Institute from time to time monitors the Postings on the Site and may decline to accept and/or remove any Postings that contain:

Any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, profane, hateful, racially, ethnically or otherwise objectionable material of any kind, including, but not limited to, any material which encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national or international law.

Advertisements or solicitations of any kind. Messages posted by users impersonating others.

Personal information such as messages which state phone numbers, social security numbers, account numbers, addresses, or employer references.

Messages by non-spokesperson employees of the Institute purporting to speak on behalf of the Institute or containing confidential information or expressing opinions concerning the Institute.

Messages that offer unauthorized downloads of any copyrighted or private information.

Multiple messages placed within individual folders by the same user restating the same point.

Chain letters of any kind.

CHANGES TO RULES AND REGULATIONS The Institute reserves the right to revise these Rules and Regulations at any time and users are deemed to be apprised of and bound by any changes to these Rules and Regulations.

VIOLATIONS OF RULES AND REGULATIONS The Institute reserves the right to seek all remedies available at law and in equity for violations of these Rules and Regulations, including the right to block access from a particular Internet address to the Site.

ACCESS TO PASSWORD PROTECTED/SECURE AREAS Access to and use of password protected and/or secure areas of the Site is restricted to authorized users only. Unauthorized individuals attempting to access these areas of the Site may be subject to prosecution.

GO HERE FOR FULL LEGAL NOTICES AND GENERAL CONDITIONS