Blackberry 2015 Annual Report Download - page 184

34 BlackBerry Code of Business Standards and Principles Contents
BS&P SECTION CONTACT(S) (Click to view)
Comply with International Trade Control
Laws and Regulations
For the info of each team in this chapter
• International Trade Controls
BlackBerry is a global company with operations
around the world that engage in a wide variety
of activities including sales, marketing, research
and development, and manufacturing. We deliver
hardware, software, services and technology to
business partners and customers in dozens of
countries. As a result of this global presence, our
Company is subject to and abides by numerous
trade control laws and regulations governing the
export and import of hardware, software, services
and technology, as well as trade embargos and
other sanctions and restrictions.
If your work involves transactions or business
activities that cross borders or involve foreign
parties, you need to understand how these laws,
rules and regulations might apply.
Export and Import Activities
An “export” can occur through physical delivery,
e-mail, download or other transmission of a product,
software or technology from one country to another. It
may also be considered an export when you disclose
or provide software, services or technology to a citizen
of another country, regardless of where the person is
located. Such “deemed exports” can occur via written,
oral or visual means, including activities such as site
visits, in-person meetings or even telephone calls. In
some instances, BlackBerry must obtain a license
or a permit or other export authorization before it
can export certain items or information to certain
countries or recipients.
An “import” is the transfer of goods into a country
through physical or intangible means from a foreign
or external source, which can include another
BlackBerry location. Imports may require the payment
of duties and taxes, as well as the submission of
certain filings and receipt of import authorizations
such as a license, permit or other approval.
Before engaging in an export or import activity, you
must verify the eligibility of both the location of
delivery and the recipient, ensure that all required
licenses, permits or authorizations are in place,
and ensure that all necessary submissions have
been completed. You must understand which
party to the transaction is responsible for the
accuracy, completion and submission of relevant
documentation, and the securing or relevant licenses,
permits or other authorizations. Ensure that all
documents or submissions for which BlackBerry
or its agents are responsible are accurate and
complete, and that all information provided by
BlackBerry to other responsible parties is similarly
accurate and complete.
Sanctions, Embargoes, Anti-Boycott and Other
Trade Restrictions
From time to time, governments use economic
sanctions and trade embargoes to further various
foreign policy and national security objectives. In
order to ensure BlackBerry’s compliance with any
applicable restrictions, you must ensure that all
international transactions are screened against
involvement of countries, persons or entities subject
to applicable sanction, embargo or other trade
restriction. You must also refuse to cooperate with
restrictive trade practices or boycotts prohibited
under U.S. anti-boycott law, and alert your manager or
the Legal Department to any boycott-related requests.
At times, the trade control laws of multiple countries
or regions may be implicated by a transaction and
may be in conflict with one another in whole or part.
In the event such a conflict arises, consult with your
manager or the Legal Department.