The Thirteen Commandments: No. 5
"Enforce Your ICP"
A. Get Everyone's Support
Directives and policy statements must be generated, approved, and signed by the highest echelons within the company. A commitment to export and import compliance must be communicated conspicuously and regularly within the corporation. However, as a management style, top-down directives are only marginally successful. In addition to having top management support compliance, try to develop your program through inclusion of others besides top management. Line personnel know the nuts and bolts behind exporting and importing, and they will be people who actually carry out your policies.
B. Make Your ICP Self-Policing And Self-Correcting
Having an ICP that is not enforced is worse than no ICP. Provide for periodic monitoring and auditing to find out whether compliance is working. In many instances, this means ensuring that contractors, suppliers, and agents are passing legal muster.
Also, don't discourage reporting of violations. An ICP should allow and encourage your employees to offer constructive criticisms, including the reporting of violations without the fear of retribution. Moreover, you don't want to violate any whistle-blower laws or be sued by an employee who was only trying in good faith to obey the law
C. Spell Out Penalties For Violations
Your ICP should describe penalties (legal sanctions by the Government and disciplinary actions taken by your company) for violating the ICP, corporate policy, and export/import laws. Be honest, but be graphic. For example, violations of import recordkeeping laws may cost your company hundreds of thousands of dollars, or even more!
