Management Commitment Statement
It is A. M. Castle & Co.’s policy to conduct business in compliance with all applicable laws and regulations, including those covering the exportation from the U.S. of controlled information, services, and goods. We are committed to export compliance and encourage awareness regarding U.S. export controls. The A. M. Castle Export Compliance Management Program applies to, and shall be observed by, all domestic and international companies affiliated with A. M. Castle & Co. Our Export Control Policy, which serves as the foundation for this program, is located on our Legal Department Intranet site in the "Policies and Procedures" section or on the external website at www.amcastle.com.
A. M. Castle & Co. is committed to full compliance with controls administered by the U.S. Department of State’s Directorate of Defense Trade controls ("DDTC"), U.S. Department of Commerce’s Bureau of Industry and Security ("BIS"), U.S. Department of Treasury’s Office of Foreign Assets Controls ("OFAC"), and other agencies. It is the Company’s policy that no sales will be made contrary to the International Traffic in Arms ("ITAR"), Export Administration Regulations ("EAR"), and other export control laws. A complete Export Procedures Manual which includes day-to-day operating procedures is available on the International Trade Compliance Intranet (or on the TPI Net) in the "Documents" section. It is important to know that an export includes the transfer or shipment of goods outside the U.S. and the transfer or release of technology or software to a foreign national located in the U.S. or abroad. U.S. law restricts the export of certain goods, including those of a strictly military nature and those that might be used for both a military and commercial application, and related information. The export control laws prohibit doing business in certain countries or with particular individuals; the laws also restrict the export of goods intended to be put to certain end-uses, including those of a nuclear, missile system, or chemical and biological weapon nature. If you have any questions about whether something is subject to export controls or may have been improperly exported, please contact the Trade Compliance Manager at firstname.lastname@example.org.
Violations of U.S. export control laws could subject A. M. Castle & Co. and its employees to severe penalties, including fines, imprisonment, and denial of export privileges. Therefore, the Company commits to provide the training, resources, and internal controls necessary to ensure compliance with U.S. laws.