EU Code of Conduct - EU Export Compliance Commitment

Organizations and individuals shall:

adopt the European Code for Export Compliance (EU-CEC) as management framework for their import/export and make their commitment to implement the Principles and guidelines  as  guiding  values of their activities.

Export Compliance provides support in compliance risk management, i.e. the risk of legal or administrative sanctions, financial losses or reputation deterioration for failing to comply with EU laws, regulations and legislation, codes of conduct and good practice. The Organizations are committed to comply with all Export laws, regulations and norms in the EU and is a policy for all their employees. 

Any of Organization's employees may not import/ re-route/re-export any commodity, technology, or software unless appropriate authorization has been obtained by the EU Supplier, and this includes foreign-produced items that are the direct product of EU, technology and software.

No activities will be undertaken that are in violation of the EU policies which seek to control nuclear proliferation, missile technology, chemical and biological weapons, untraceable payments or transfer of funds and any other regulated activity without proper authorization or license.

Failure to comply with these regulations may result in the imposition of criminal and/or civil fines, penalties and cancellation from the Register of EU Compliant Organizations and the EIFEC Register Number (ERN) suspended or revoked. 

Organizations will act and communicate in a transparent manner, in their relation with EU and member states Institutions, and all stakeholders  about operating EU Export Compliance policy, and the economic, financial and legal implications of each activity undertaken.

• It is included their commitment to EU transparency Code of Conduct norms where in relations with the EU institutions and their Members, officials and other staff Organizations will always: 
• • identify themselves by name and by the entity or entities they work for or represent; declare the interests, objectives or aims promoted and, where applicable, specify the clients or members whom they represent; 
• • not obtain or try to obtain information, or any decision, dishonestly, or by use of undue pressure or inappropriate behavior; 
• • not claim any formal relationship with the EU or any of its institutions in our dealings with third parties, nor misrepresent the effect of Registration in such a way as to mislead third parties or officials or other staff of the EU except those provided by EU Export Compliance Certification (EU- C/ECO) ; 
• • ensure that, to the best of their knowledge, information which they provide upon this Registration and subsequently in the framework of their activities within the scope of the registration is complete, up-to-date and not misleading; 
• • not induce Members of the EU institutions, officials or other staff of the EU, or assistants or trainees of those Members, to contravene the rules and standards of behavior applicable to them; 
• • if employing former officials or other staff of the EU or assistants or trainees of Members of the EU institutions, respect the obligation of such employees to abide by the rules and confidentiality requirements which apply to them; 
• • observe any rules laid down on the rights and responsibilities of former Members of the European Parliament and the European Commission; 
• • inform whomever they represent of their obligations towards the EU institutions;

Who should register with the EU-ECR?

All Organisations and self employed individuals, irrespective of their legal status, engaged in activities falling within the scope of the EU Export Compliance Register (EU-ECR) are in principle expected to register.

• • ❑ Academic institutions 
• • ❑ EIFEC CHARTER member 
• • ❑ EU National Authorities 
• • ❑ Export Compliance Professionals 
• • ❑ Financial Institutions 
• • ❑ Law Firms 
• • ❑ NGO Non-governmental organisations, platforms and networks and similar 
• • ❑ NON EU Auntorities 
• • ❑ Sovranational Entities 
• • ❑ Standards Organizations 
• • ❑ Think tanks and research institutions

Exceptions or precisions to this principle concerning:

Churches and religious communities, Political parties, Local, regional and municipal authorities as follows:

• Churches are not concerned by the EU-ECR. However their representation offices or legal bodies, offices and networks acting within the scope of the EU-ECR are expected to register.
• Political parties are not concerned by the register. However any organisations which they create or support, engaged in activities falling under the scope of the register, are expected to register. 
• Local, regional and municipal authorities are not concerned by the register. However their representation offices or legal bodies, offices and networks created to represent them towards the European institutions, as well as their associations, are expected to register. 

Under the EU Transparency Register Code has been precised by the following public statement made by VP Sefcovic: "Services forming an integral part of their administration, staffed by local, regional or municipal officials and engaged in activities corresponding to their institutional or constitutional attributions, will thus not be expected to register". Indeed autonomous structures, with a private legal status, which would include subnational public authorities but which would be also shared with private interests, created in order to pursue activities falling within the scope of the Register would be expected to register”.

EU Member States governments, third country governments, international intergovernmental organizations as well as their diplomatic missions are not expected to register

Why register your Organization?

Registering your Organisation in the EU Export Compliance Register (EU-ECR) and committing it to ensure a full respect of the EU Trasparency Code of Conduct and the EU Export Compliance Commitment by yourself, your employees, your members or representatives will be a public indication that your organization or yourself accepts to "play by the rules" and to interact with the EU in full transparency and in compliance with EU export laws and regulations. 

Registering you agree to adopt the EU Code for Export Compliance  (EU-CEC) and implement the EU Export Compliance Framework ( EU-ECF) within your activity.

In addition you will become, after verification / certification process has been positively concluded, a EU Export Compliant Organization (EU-C/ECO)

Agents and Members of the institutions in EU will be able to ensure, when you contact them or when you communicate with them, that they are interacting with an organisation which accepts to"play by the rules" in export and in transparency, certified by third independent accredited parties or authorities.

While Export Compliance programs officially still remain optional for EU exporters, the recent moves by various EU Government in the area of Export Compliance enforcement make it clear that Export Compliance programs are important. Indeed, they are considered in many instances to have a mitigating effect if not a Safe Harbor effect in the case of an export law violation. Against this background, EU exporters or NON EU organization dealing with EU who fail to develop Export Compliance programs appear to be ill-equipped to deal with the steadily increasing number of government- sponsored export compliance initiatives. 

Registering and becoming an EU-C/ECO you will have access to the world’s EU leading source of intelligent information about EU Export Compliance for Organizations and professionals. Innovative technology is deployed to deliver critical information for leading decision makers in the financial, legal, tax and accounting, scientific and healthcare markets.

The EIFEC Export Compliance team delivers the most comprehensive knowledge base designed to connect business transactions, strategy and operations to the regulatory environment. It brings together market-leading global regulatory partners and securities intelligence; business law research; contract and deal-drafting tools; internal policy management; e-learning; anti-money laundering solutions; and audit, filing, board of director and disclosure services.

How to Register with the EU Export Compliance Register 

Today Registration is only for:

• • ❑ Academic institutions
• • ❑ EIFEC CHARTER member 
• • ❑ Export Compliance Professionals 
• • ❑ Financial Institutions 
• • ❑ Law Firms 
• • ❑ NGO Non-governmental organisations, platforms and networks and similar 
• • ❑ NON EU Authorities 
• • ❑ Sovranational Entities 
• • ❑ Standards Organizations 
• • ❑ Think tanks and research institutions 

For NON EU Organization of IRAN or connected to IRAN a special Certification Process has been set up: EU-ECO/267/2012. It is available upon request and invitation.

Example of the registration form (cannot be used for actual registration!) . They are an example how to complete and prepare the online registration.

• Section 1  if you are an EU Organization
• Section 2  if you are an EU Individual or Natural Person
• Section 3  if you are a NON EU Organization
• Organizations 
• Academic Organizations 
• Export Compliance Officers 
• Financial Institutions 
• Law Firms 
• NGO 
• Non Eu Auntorities 
• Sovranational Entities 
• Standards Organizations 
• Think Tank Research Institutions
• Section 4  if you are a NON EU Individual or Natural Person

The following Organizations are de iure registered

• ❑ EU National Auhtorities

Consult the EU Export Compliance Register

Submit a Complaint to the EU Export Compliance Register

Non-compliance with the EU Trasparency Code of Conduct and EU Export Compliance Code (EU-CEC) by registrants/members or by their representatives may lead, following an investigation paying due respect to the principle of proportionality and the right of defence, to the application of measures such as suspension or removal from the EU Export Compliance Register and, if applicable, withdrawal of EIFEC Registration Number (ERN).

A decision to apply such measures may be published on the register's website.

Anyone may lodge a complaint, substantiated by material facts, about suspected non-compliance with the Code of Conduct and EU-CEC.

Procedure for the investigation and treatment of complaints.

EIFEC has specific regulation for Procedure for the investigation and treatment of complain.

The document is available for download here

All efforts are made to keep highest confidentiality on information received and correctness in checking evidence.

Frequently Asked  Questions. FAQs

To prevent overflowing our helpdesk with the most Frequently Asked Questions (FAQs) on the EU Export Compliance Register (EU-ECR) you will find here a document to download for your direct consultation which provides answers to a series of basic questions, as well as to a number of questions which will emerge over time as significant for registrants.

It will also be progressively enhanced as practical cases will lead to the production of interpretative decisions regarding the implementation of EU Export Compliance Framework ( EU-ECF)

Click to download EU-ECR FAQs 

EU Export Compliance Register - EIFEC Charter Member Register - Data protection rules

This privacy statement explains how the EU Export Compliance Register (EU-ECR) / EIFEC Charter Member Register uses any information you give to us, and the way we protect your privacy.

1. The purpose and objective of the  EU-ECR “EIFEC Register"

To enhance the implementation of EU Export Compliance Framework (EU-ECF) best practice a Register (EU-ECR) for organizations and self-employed individuals engaged in EU import/export and policy implementation has been activated.

The EU Export Compliance Register (EU-ECR) has been set up to offer a single EU Code of Conduct and EU Export Compliance Commitment, binding all Organizations and self employed individuals which accept to “play by the rules” in full respect of ethical principles. 

All Organizations that have adopted the EU-ECR and have successfully past the Verification/Certification process are becoming so an EU Certified Export Compliant Organization EU-C/ECO (Charter Member). Becoming a Charter Member means that you voluntarily adopt the European Code for Export Compliance (EU-CEC) and submitted your organization to a verification process and, if it will conclude positively you will become a EU Certified Export Compliant Organization (EU-C/ECO) as set by EIFEC 2010 Code Standards.

In addition will allow organizations and self employed individuals engaged in EU Export activity to get information about the landscape of European policy-making and policy implementation as comprehensively as possible.

The EU-ECR is managed by the EIFEC Register Secretariat. The EU-ECR contains a web-based voluntary registration system. While registering, the organisms will also have to subscribe to the code of conduct and the EU Export Compliance Code available on this same web site.

2. What personal information do we collect and for what purpose?

The registration system entails disclosing facts about who the organisms are and whom they represent, what their mission is. These data are collected via the online subscription form available on this same website. The personal data concerning the contact persons, collected from the web-based registration interface will not be made available for consultation to the any party except those who are entitled as Eu National Authorities or Registered Financial Institutions on the EU-ECR website. The data are solely collected for the specific purposes laid down in this privacy statement and will not be used for any other purpose.

3. Who has access to your information and to whom is it disclosed?

The EU-ECR is available on the Internet for consultation by Registered and Authorized Users only, All information will not be shared with third parties except the EIFEC Number and Certification Expiry date. The mailing list is managed by the authorized webmaster. The authorized webmaster can also delete data if it is found to be out of date or incorrect or if the values, objectives and/or actions of the registered organism are contrary to the principles of the EU as defined in article 6, § 1 and 2 of the Treaty of the European Union. In this case the Registrant will be notified about the procedure followed by the EIFEC Register Secretariat for deleting a record from the database.

4. How do we protect and safeguard your information?

Immediately after the submission of the form, your replies are recorded in a secured and protected database hosted by the Data Centre of EIFEC. Your organisation's identification data are transmitted securely over the network (via Secure Sockets Layer (SSL)) to the EIFEC web server. Inside the institutions the whole database can only be accessed by a limited number of persons using a UserId/Password.

5. How can you verify, modify or delete your information?

The EU-ECR is an opt-in service. Access for modifying submitted data at any moment is only granted to the registered users through a Login/Password. You have to request a modification of your data submitting at Online Support at My EIFEC section. If it is approved, you will be notified by email. You may verify the accuracy of the information and, if necessary, request to correct it by accessing the web interface.

6. How long do we keep your data?

We keep your data for as long as you are registered, or until the data is found to be out of date or incorrect. You must update your data at least once a year. For transparency reasons your data will be kept in the non-public part of the database for 5 years after the last action in relation to the registration.

7. Contact Information

In case you have questions related to this e-Service or concerning any information processed in the context of this service, feel free to contact the EIFEC Register Secretariat, using the contact form available on this website.

Legal Notice and Privacy policy

The Register is part of the policy of honesty endorsed with the EU Export Compliance Framework about the relations with Organisations and self-employed individuals engaged in import /export with the EU. Registering is voluntary and in no way implies that your Organisation or self-employed individual has been given any form of recognition, approval or accreditation by the European Institutions. For those who have voluntarily submitted to the Certification process and to the effects limited by Certification regulations and standards may state that are a EU Certified Export Compliant Organization/Person and use the EIFEC logo/EIFEC Number and seal in their communications. The information in the Register is provided by the registered organisations and is the sole responsibility of those organisations. The EU Export Compliance Register Secretariat reserves the right to remove from the Register any organisation whose values, goals and/or actions are contrary to the principles of the EU as laid down in Article 6(1) and (2) of the EU Treaty and in breach of EIFEC regulations. The Register contains links to external sites which EIFEC have no control over and for which we cannot be held responsible. The fact that these links are provided does not constitute either approval or a guarantee regarding (i) the organisation (or individual) responsible for managing or providing the content on any of the sites, (ii) the services advertised there, (iii) the content on the sites or (iv) any opinions expressed there.

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European Register for Export Compliance: Glossary

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