YTS’ｓ commitment to Security Trade Control

It is an international agreement to control the trade which may jeopardize the maintenance of global peace and security, and in Japan, the trade of the controlled products (and technologies) and trade for the countries, users and applications with security concerns are controlled by the government.

In order to contribute to the maintenance of global peace and security, and to comply with laws and regulations relevant to the security trade control, we, YTS establish a global and group-wide security trade control system where our security trade control activities are promoted under our president as the chief executive of security trade control and the person in charge of security trade control in all departments and group companies.

Also, as there are a number of controlled products in our product line and we have a responsibility to avoid unlawful trade of those products to be carried out by the third parties, we apply our security trade control system to our domestic transactions in addition to our export transactions in line with the intent of the relevant laws and regulations.

YTS’s basic policy of Security Trade Control

We are promoting our security trade control under the following basic policy.

1. We will carry out our export transaction of controlled products and/or international transfer of controlled technology in strict compliance with applicable laws and regulations relevant to security trade control.

2. In order to implement the appropriate security trade control and strict compliance with relevant laws and regulations in all departments throughout the company, CEO, as the chief executive of our overall security trade control system, and the security export control office, as the administrative divisions of security trade control, will aim to develop and enhance our security trade control system to be thorough.

3. We will promote the security trade control in our overseas affiliates in the level equivalent to YTS in consideration of laws and regulations of each country and those of Japan which are established based on the international treaties.

YTS’s practice policy of Security Trade Control

1. Product Classification

“Product Classification” is the judgment if the product is controlled or non-controlled under security trade control laws and regulations.
In order to make reliable judgment of Product Classification under Foreign Exchange and Foreign Trade Law and its relevant laws and regulations in Japan, we check the Product Classification of our product doubly by engineering department and security export control office for assurance.

2. Transaction Screening

In order to detect the controlled transaction of which the destination country, end-user and/or application of the product fall into security concerns, we will conduct transaction screening on both of direct and indirect export transactions including transactions of non-controlled products.

3. License Application

We will apply for an export license from the Japanese government properly for the transaction fall into the conditions stipulated in the security trade control laws and regulations.

4. Shipment Control

In order to prevent inadvertent violation of security trade control laws and regulations, we will verify “Product Classification”, “Result of Transaction Screening”, “Applicable Export License”, and “Contents of Cargo” of each export shipment at the time of shipment out of our facility.

5. Audit

In order to ensure strict compliance with laws and regulations and appropriate self-management of security trade control throughout the company, we will conduct audits of all business departments including overseas affiliates on a regular basis.

6. Training

In order to ensure an appropriate implementation of security trade control throughout the company, we will conduct training to all relevant officers and employees to improve their knowledge and ability of security trade control periodically.

7. Document Control

We will keep the documents and records relating to the export transactions of controlled products properly in accordance with the provisions of security trade control laws and regulations.

8. Report

If we have committed a violation or a possible violation of security trade control laws and regulations, we will make a prompt report to competent authority and take necessary measures for the prevention of recurrence.

Issue of Product Classification Documents

〈To the customers in Japan〉
When you export the controlled product out of Japan and apply for an export license from the Minister of Economy, Trade and Industry in Japan, you need to submit a document showing the Product Classification and its supporting data of said product.

Please contact YTS for Product Classification Document of our products.

Please note that you are required to fill in the contents of your export transaction on our “Product Classification Document Request Form” according to our internal regulation for strict compliance with security trade control laws and regulations.

Request to the customers

We will ask for your understanding and cooperation for the request we may make corresponding to the security trade control laws and regulations.

〈To the customers outside Japan〉
When we made an export contract which requires the export license from the Minister of Economy, Trade and Industry in Japan, we will ask the customer to submit the “End Use Certificate” at the time of contract.

We also may ask the customer to submit the “Confirmation of Installation” after delivery if it is required by the government in the export license.

〈To the customers in Japan〉
1. When we received direct or indirect export inquiry, we may ask the customer to provide us the information regarding destination, end-user, application and installation site of our products to conduct our internal verification in compliance with the security trade control laws and regulations.

2. When we knew that the customer has an intention to export our products out of Japan, we may ask the written confirmation that the customer will comply with the security trade control laws and regulations without fail.

3. When we found that the transaction with the customer fell into possible violation of security trade control laws and regulations, we may decline the transaction with the customer.