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civil penalties associated with violations of applicable statutes and noncompliance with the ICP Top management chain of command Designate a high-ranking company officer, such as in-house counsel or vice president, with ultimate responsibility for administering the ICP, says Hilsabeck Compliance officer In addition, a focal compliance officer should be designated, with responsibility to field questions and concerns from employees, she says Hilsabeck advises that the ICP spell out the responsibilities of this individual and his or her scope of authority A backup individual should also be designated Written procedures A company export compliance manual should contain policies and procedures designed to prevent both intentional and unintentional violations of US export laws I recommend a product matrix, says Hilsabeck, to ensure proper classification of exports, since an error here can quickly escalate into compliance violations down the line.

Routine procedures for screening denied or restricted parties and for weapons proliferation should be put in place if applicable Any required export licenses or license exceptions should be spelled out in the manual, along with any and all applicable country policies It s important, says Hilsabeck, that these policies and procedures are clear and easy to understand by all company employees and that they are communicated effectively throughout the organization Training Organize a routine program, Hilsabeck counsels, of comprehensive training on the company s ICP and the relevant laws and regulations Updates to the ICP and news of regulatory changes should be communicated to employees as necessary Send key company personnel to regular export seminars and conferences, Hilsabeck advises Document retention policy The ICP should include an official company policy governing retention of all export transaction records (the legal requirement is five years for exports).

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deviated or diffracted wave (D wave) that becomes scattered in many directions Typically, only a minority of incident waves are diffracted by cellular objects Both S and D waves are collected by the objective lens and focused in the image plane at the site corresponding to the image of the particle, where they undergo interference and generate a resultant particle wave (P wave) The relationship among waves is thus described as P S D Detection of the object image depends on the intensities, and hence on the amplitudes, of the P and S waves Only when the amplitudes of the P and S waves are significantly different in the image plane can we see the object in the microscope.

Also perform periodic audits of the records maintained, says Hilsabeck Internal audits These should be designed to provide reasonable assurance that the company s export ICP objectives are being met, Hilsabeck explains An audit strategy should be developed that detects specific compliance violations and patterns of activity or employee conduct that could result in ongoing or repetitive violations Suspected noncompliance matters It s essential, says Hilsabeck, to create an atmosphere in which employees feel encouraged to report violations of the ICP to the designated compliance administrators Once such a report has been made, it is crucial to follow up by rapidly investigating and when necessary consulting in-house or outside counsel for advice on how to proceed Export process The company s export ICP should flowchart your export process from order entry to the record-retention stage, says Hilsabeck.

The ICP should define and outline all export documentation requirements, including destination control statements on invoices and packing slips and proper execution of Shippers Export Declaration-Automated Export System (SED-.

Before beginning our explanation of the interference mechanism, we should note our earlier discussion of the coherence of light waves in the myriad small beams (wave bundles) illuminating the specimen ( 5) This condition is of great practical importance for phase contrast microscopy, because image formation through constructive and destructive interference requires coherent illumination such that: (1) A definite phase relationship exists between the S and D waves, and (2) the phase relationship must be preserved between the object and the image DEPICTION OF WAVE INTERACTIONS WITH SINE WAVE AND VECTOR DIAGRAMS With this general scheme in mind, let us now examine Figure 7-5a, which shows the S, D, and P waves as sine waves of a given wavelength in the region of the object in the image plane.

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