Aeris is committed to complying with all applicable local, national and international laws and regulations wherever it does business.
- At Aeris, we understand that economic, reputational and other consequences of non-compliance to both our business and that of our customers, suppliers and partners. Compliance with all applicable laws and regulations is critically important to the success of our business worldwide.
- Aeris managers are trained to be familiar with the basic laws, regulations and corporate policies that are relevant to their areas of responsibility. Comprehensive knowledge of applicable laws and corporate policy is especially important for those managers who, because of their specific functions or appointed positions, have a special responsibility for ensuring compliance
- In specific jurisdictions, countries, industries or markets as well as with specific business partners, more specific rules than those described here may exist. In such cases, Aeris assumes that the stricter standard applies.
Global Compliance
1. Anti-Money Laundering
2. Anti-bribery and Anti-corruption
Every business transaction should be carried out in full transparency and precisely recorded in the supplier’s accounts and records. To ensure compliance with anti-corruption legislation, including but not limited to the OECD Anti-Bribery Convention, the United Kingdom Bribery Act of 2010, and the United States Foreign Corrupt Practices Act of 1977, Aeris suppliers are required to ensure that appropriate controls are in place.
Aeris also requires that its suppliers and partners agree that they shall not promise, authorize or make any payment to, or otherwise contribute any item of value to, directly or indirectly, to any government official, in each case, in violation of the U.S. Foreign Corrupt Practices Act (“FCPA”) or any other applicable anti-bribery or anticorruption law. .
Aeris is proud to be an equal opportunity organization which walks the walk on diversity. We are a brilliant mix of varying ethnicities, backgrounds, religions, cultures, sexual orientations, gender identities, ages and professional/personal/military experiences – and that’s by design. Different perspectives are essential to our culture, innovative process and competitive edge. Aeris respects the dignity, diversity and human rights of all of its employees and third parties and is committed to fostering a workplace which is free from discrimination, bullying or harassment of any kind. We strongly condemn forced or child labor and any form of exploitation or discrimination and strictly comply with applicable laws.
We comply with legal requirements for the protection of fair working conditions, including those regulating compensation, working hours, and privacy.
3. Human Rights including Modern Slavery etc.
We do not tolerate the exploitation of children or workers and are committed to providing a workplace that is free of intimidation and any type of workplace violence. We expect the suppliers and contractors with whom we do business to comply with these standards.
4. Export Control
Exports
Export laws do not just apply to selling and shipping products or services directly to customers beyond the borders of the country of origin. They also apply to selling or shipping products or services to someone who will ship or provide the product or service to another country. In some instances, just providing access to technical data without money changing hands, such as allowing a potential customer test access, or allowing non-U.S. nationals (even employees) regardless of location to have access to technology, may be considered an export subject to regulation. Some export regulations apply equally to exports, re-exports and these “deemed” exports (all referred to for simplicity as “exports”).
In particular, Aeris acknowledges that some of its products may be subject to US, UK and EU export control regulations such as the Export Administration Regulations administered by the U.S. Department of Commerce and the Foreign Asset Control Regulations and other related sanctions programs administered by the U.S. Department of the Treasury. In addition, Aeris recognizes that additional sanction and export control programs may apply to its international operations.
Doing business with prohibited persons
The U.S. as well as other jurisdictions, such as the U.N. and the European Union, have adopted laws and regulations prohibiting doing business with persons or entities (“restricted parties”) who have been denied export privileges or who are believed to be engaged in terrorism, weapons proliferation, money laundering, drug trafficking or other criminal activity, and the U.S. and these other organizations maintain a number of trade sanctions lists, which are updated regularly (“restricted party lists”), listing all restricted parties. Aeris prohibits doing business with any person or entity who is identified on any of these restricted party lists. Aeris personnel are responsible for ensuring that Aeris does not do business with any restricted parties. Please see “Restricted Party Screening” below for more information about how Aeris complies with this prohibition.
Exports to persons in prohibited countries
Aeris products may not be exported or re-exported to sanctioned jurisdictions: Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions. Aeris personnel are responsible for ensuring that Aeris does not export any product or provide any service to anyone located in any prohibited countries. Aeris will screen all shipments and customers to ensure that it does not violate this prohibition. If Aeris personnel are aware that any persons are intending to re-export to any of these countries, the transaction cannot be approved.
Supporting boycotts not approved by the U.S.
U.S. export laws also prohibit U.S. companies and their non-U.S. affiliates from engaging in activities to support boycotts called by certain countries and not supported by the U.S. Aeris is committed to complying with such laws. ea).
Dual Use and other Export Regulations
U.S. laws regulate the export of products, services or technical data that can be used for military or defense purposes or for applications relating to nuclear power or weapons. A special license is required for the export of these types of products. In addition, any products, services or technical data that can be used for both regular commercial purposes as well as for defense or nuclear purposes are considered “dual use” products, and their export may require a license.
Aeris believes that all of its products, services or technical data are eligible for export without a license, but Aeris personnel are aware of these regulations in order to be able to complete export documentation for products or services that are being shipped to a final destination outside the U.S.
ECCN. BIS is also responsible for assigning more detailed identifying numbers to products called Export Control Classification Numbers (ECCNS). Many shipping documents often ask for the ECCN associated with the product. The only physical product sold by Aeris is SIM cards, and the correct ECCN for these SIM Cards is EAR99.
Restricted Party Screening
Aeris complies with export control laws by ensuring that all transactions undergo a screening check to ensure that none of the parties to an order are listed on any applicable sanction or denied entity list, including the U.S. Bureau of Industry and Security Lists of Parties of Concern, and the Consolidated list of persons, groups and entities subject to EU financial sanctions, the UK Sanctions List and any other applicable sanctioned, denied or other restricted party lists.
No Aeris products are regulated by the International Traffic in Arms Regulations (ITAR) or EU or UK military export controls.
Aeris Supply Chain
Aeris requires that its suppliers and other business partners comply with all applicable export control regulations and in particular that such business partners agree not to export any products, services or technical data to any country for which an export license or governmental approval is necessary without first obtaining the license or approval. Aeris further requires its partners agree (i) that the business partner is not located in, organized under the laws of, or controlled by a person or entity located in any country subject to a U.S. or E.U. trade embargo, (ii) that the business partner does not violate any applicable sanction or embargo laws and regulations, including trade and economic sanctions maintained by the United State Treasury Department’s Office of Foreign Assets Control, and (iii) that the business partner is not listed on, or owned or controlled by any entity or person on, the U.S. Department of Treasury list of Specially Designated Nationals or any similar list in place in any jurisdiction where partner conducts business.