ICP Control Level of PTI Significantly Improved

2014 was a record year for Poly Technologies, Inc. (PTI) marked by double-digit growth in all major economic areas to include operating revenue, pre-tax profit, and economic value added.  At the same time, PTI continued to demonstrate its role as a responsible global partner by working to improve its Internal Compliance Program (ICP).  Staying abreast of the latest updates on international non-proliferation, PTI has implemented better non-proliferation export controls, and has achieved a higher level of non-proliferation export management.  Some of PTI’s efforts include the following::

1. PTI has implemented intense project reviews to ensure compliance.  The ability to veto any project has been given to every level of management if it is thought the project is not in strict conformance with applicable international non-proliferation standards.  The Internal Compliance  Committee (ICC) and Internal Compliance Office(ICO) effectively communicates requirements for review throughout the organization.

2. PTI management encourages regular review and revisions to the Internal Compliance Program Manual regarding compliance in accordance with recommendations by the compliance program experts at the University of Georgia.

3. PTI has integrated Enterprise Resource Planning (ERP) into the ICP making effective use of updated IT capabilities and programs to guarantee greater effectiveness of export control.

4. PTI has revised and improved its contract review procedures ensuring the effective correlation of internal and comprehensive risk management.  Databases have been added to better prioritize the review of contracts according to value and types.

5. PTI has increased corporate internal ICP training. PTI has held several ICP training sessions with guest experts from the Monterey Institute of International Studies and the University of Georgia, which all PTI staff has attended.  In addition, ICP and Non-proliferation Export Control training has been integrated into the employee orientation program and annual employee training sessions, ensuring effective ICP training coverage for each and every employee.

6. International non-proliferation seminars and workshops have provided opportunities for PTI senior executives to expand their exposure to fresh ideas to further enhance PTI’s ICP. Training programs at the University of Georgia, the Annual Conference of the Global Trade Controls and Compliance in Great Britain, and the EU-China Non-proliferation Cooperation Joint Export Control Handbook Workshop allowed PTI attendees to share first-rate conference topics with other PTI employees.  In addition, selected employees from PTI attended meetings and training sessions held by the Ministry of Foreign Affairs, Ministry of Commerce, and the China Arms Control and Disarmament Association.  Information obtained at those conferences shaped continued improvement in policy and processes, demonstrating PTI management’s commitment to a robust ICP.

As a responsible corporate citizen, PTI will continue to fully abide by all laws and regulations relating to Internal Compliance Program.  It will honor the Chinese government's international commitment to carry out its non-proliferation export duty in accordance with all international obligations and related UN Security Council resolutions. PTI will continue to further improve its Internal Compliance Program mechanisms in every aspect.  Training programs will be continually developed and improved upon, and ICP principles will be a part of each employee’s performance.   Strict adherence to the accepted policies and procedures of a dynamic ICP will be demanded, and employees will be held accountable for any deviation.  PTI will be tireless to ensure a good record of non-proliferation export showcasing efforts to safeguard world peace and promote regional economic and social development for a harmonious world.