ORGANIZATION POLICIES

 

Due to the nature of our business, licenses, and registrations DTGruelle (“DTG”) maintains, our policies are internally classified as sensitive information and cannot be released; however, we can provide the following assurances:

  • DTGruelle includes the Foreign Corrupt Practices Act in our initial and annual training regimen.

  • We have embedded anti-retaliation in our organizational ethics. DTGruelle has an “open door” policy to the Managing Director to address team member issues/concerns. DTGruelle also has an “anonymous box” program where team members can maintain their anonymity whilst forwarding their issues/concerns.

  • DTGruelle is trade compliant. We are registered with the Bureau of Industry and Security and State Department. DTG maintains a complex import/export compliance program that encompasses training, SOPs, auditing schedules, and organizational responsibility appointments. DTG’s freight forwarding and customs brokerage software acts as a redundant system for screening OFAC Denied Parties; a hard stop occurs if the system believes a Denied Party is listed in a transaction.

  • To ensure facility and supply chain security, DTG has been a Customs Trade Partners Against Terrorism member since 2003 (CBP reviewed annually) and has maintained the TSA Standard Security Program since its initiation in 2001 (TSA in-person inspection yearly). DTG has been granted the ability to be a Class 3 Customs Bonded Warehouse in 2018, which requires CBP to conduct a thorough review of our facility’s security assets and policies. These examples and others require us to maintain a robust Supply Chain Security Program that incorporates but is not limited to (1) agent vetting, (2) supply chain regional stability examinations, (3) seal/freight security checklists against tampering, (4) 24/7 surveillance, (5) hardened physical security measures, (6) security training, (7) employment venting and TSA clearances, (8) documentation security, (9), etc.

  • DTG has conflict minerals embedded in our organization's ethics program. We understand the importance of humanitarian issues outside our supply chain.

  • We embedded anti-boycott in our import/export compliance program, and it is included in our initial and annual trainings. DTG’s provisions are in accordance with 15 CFR Part 760.

  • To ensure environmental protection, DTG maintains an OSHA program and conducts hazardous material response drills and spill drills. DTG trains employees on hazardous materials to comply with the law and prevent unsafe practices by clients. Hazardous material training includes:

    1. U.S. Department of Transportation’s Hazardous Materials Regulations (“49 CFR 100-185”)

    2. International Maritime Organization’s Dangerous Goods Code (“IMDG”)

    3. International Air Transport Association’s (IATA) Dangerous Good Regulations (“DGR”)

  • DTG includes an employee code of conduct in our 51-page employee handbook received upon hiring.

  • DTG maintains a CMMC cyber security program to ensure the protection of information, data security, and confidentiality. More information is available here: https://dodcio.defense.gov/CMMC/