Export Control & Sanctions

I. Purpose

The purpose of this policy is to ensure compliance by the Company with respect to applicable export and import control laws, antiboycott laws and trade and commercial embargoes.

II. Policy

A) The Company will abide by import and export laws applicable to it in its worldwide operations. Export of U.S. origin products, services or technology will comply with U.S. export laws which take into account the nature of the item, the country of destination, the identity of the end user and the proposed end use. The applicable laws in each country the Company does business must be followed, but there are some U.S. Laws that apply to subsidiary companies located outside the U.S. as the parent company, Alamo Group Inc., is a U.S. Company.

B) The Company will not participate in any transactions with U.S. embargoed countries or entities known to be owned, controlled or organized in such countries.  Certain countries are subject to U.S. sanctions which restrict but do not halt trade with those countries. 

As of February 15. 2011, Cuba, Iran and the Sudan are subject to comprehensive U.S. embargoes.  Burma/Myanmar, the Balkans, Belarus, Liberia, the Sudan, North Korea, Syria and Zimbabwe are also subject to various sanctions and recent events in Libya may have resulted in embargoes on exports to the Ghadafi family and governmetn.  Iraq is no longer subject to a comprehensive embargo, but to export certain sensitive items may require a license from the U.S. Government.

C) The Office of Foreign Assets Control also maintains a list of “specially designated nationals,” individuals or companies with whom US companies and their subsidiaries may not do business.  Most of these individuals or companies are in sanctioned countries, but not all of them.  The Legal Department can run a check on any individuals or companies that may concern you.

D) No employee of the Company shall refuse to do business with any country, entity or person for boycott-related purposes such as the Arab League boycott of Israel.  Any Agreements with boycott language in them should be reported to the Legal Department for reporting to the U.S. government as required.

III. Procedure

Sales to any countries discussed in this policy must be cleared in advance by the Legal Department. If you have any concerns that a buyer may be planning to sell equipment to one of the sanctioned countries or that the buyer could be on the specially designated national list, contact the Legal Department.  Exports (or imports) that violate US sanctions, export, or customs laws and regulations can result in significant fines to the company and, in some cases, loss or export privileges and criminal charges.

Last updated 09 March 2011

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