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Conducting International Trade Legally

Our Commitment

We recognize it is a privilege to have our products used around the world. We value that privilege and understand that it comes with the responsibility to comply with applicable laws and regulations governing international trade, such as import and export controls.

How We Act with Integrity

  • Follow the international trade controls that apply to Hexcel.
  • Properly classify imported goods under relevant tariff codes.
  • Declare the correct country of origin for preferential tariff treatment when applicable.
  • Obtain the proper license for the export or resale of goods, services or technology.
  • Contact the Law Department or the International Trade Compliance team if you have questions about trade regulations.
  • Market or distribute anything across international borders without understanding the regulations that may apply.
  • Fail to comply with export laws or policies—including the Hexcel Technology Control Plan—which can result in severe financial and legal penalties.

Integrity in Action

What is considered an “export” of U.S.-origin technology?

An activity as simple as emailing data to another Hexcel employee who is a foreign national within the U.S. can meet the definition of an export of U.S.-origin technology. The Hexcel Technology Control Plan requires that we protect U.S.-origin technology against unlawful disclosure or “deemed exports” of this type.

Integrity in Action

When negotiating a contract with a potential customer, I learned that the products Hexcel is exporting would be shipped to a subsequent location in a sanctioned country. Can I proceed with this contract negotiation?

No. This practice is known as “re-exporting,” which refers to exporting products that were previously imported into a country without undergoing any significant alteration or transformation. If you are aware of this transfer and do not take steps to prevent it, Hexcel could be held liable. You should immediately contact the Law Department for guidance.

Resources

Compliance with Export Control Regulations (CP 3.3)
Technology Control Plan (CP 3.4)
Regional (U.S. and Europe) Trade Compliance Policies and Procedures

Keep Reading

Working with Third Parties and Preventing Bribery and Corruption

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