ICP Lam Research Singapore
22 January 2016
Ong Choo Poh
Lam Research Corp.
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Agenda
Welcome
Company Background & Overview
Internal Control Plan (ICP)
Conclusion
Lam Research Corp.
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Lam Research Overview
►Leading
provider of wafer fabrication equipment
(WFE) and services
►A
global company
 ~7,300 employees worldwide
 Offices in 16 countries
 Manufacturing in U.S., Austria, Taiwan and Korea
►Multi-billion
dollar company
 Annual revenue of ~$5.3B in FY 2015
Lam Research Corp.
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Lam Research Locations
United States
Europe & Middle East
Asia
Austria
Israel
China
Malaysia
France
Italy
India
Singapore
Taiwan
Arizona
Oregon
California
Texas
Idaho
Utah
Germany
Switzerland
Japan
New York
Washington
Ireland
United Kingdom
Korea
Ohio
Lam Research Corp.
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Lam Makes Wafer Fabrication Equipment
We manufacture the
equipment that is used
to create semiconductor
integrated circuits (chips)
Lam Research Corp.
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Lam’s Product Leadership
Deposition
Etch
Strip & Clean
Installed Base
Support
Lam Research serves ~28.5% of total wafer fab equipment market
Lam Research Corp.
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Lam Research Singapore
►Subsidiary
►Scope
of Lam Research Corporation
and Principal Business Activities
 Commission agent for semiconductor equipments, spare parts
distribution and services
 Representative of the immediate holding company in providing
technical and maintenance support services, and spare parts for
semiconductor manufacturing equipments.
Lam Research Corp.
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Internal Control Plan (ICP)
Lam Research Corp.
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Lam’s Internal Control Plan
Lam is committed to act in compliance with Trade laws in
all jurisdictions in which we do business.
Lam Research Corp.
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Lam’s Internal Control Plan
• Customers/Vendors/End-user
Screening Procedures
• Responsible Parties Procedures
Key ICP
Supporting
Documentation
• Internal Review Procedure
• Order Processing and Products
Screening Procedures
• Foreign Trade Business
Assessment End Users/End-Use
Questionnaires
• Office Visitor & Securing
Confidential Information
Lam Research Corp.
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Lam’s Internal Control Plan
Internal Controls Plan Process Owners
Export Compliance: Strategic Goods Control Officers
Human Resources: Human Resource Director
Physical and IT Security: Business Operations Director
Order Processing and Logistics:
Senior Manager (Customer Service Business Group Operations)
Lam Research Corp.
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Lam’s Internal Control Plan
Trade Compliance Management Policy
Defines & communicates clear commitment to compliance
Identify resources within the company responsible for
compliance activities and to whom questions may be directed
Provides a description of penalties for non-compliance
Established an Escalation Flow
Lam Research Corp.
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Technology Control Plan
Defines
procedures and
responsibilities
relating to
Hiring Process
Hiring of foreign nationals and
the transferring of foreign
nationals from one job
assignment to another
Trade Restricted
Individual Travel &
Technical Training
Ensuring that access controls to
the company’s technology by
employees, suppliers,
customers, and subsidiaries
meet export regulatory and
licensing requirements.
Access Controls
Physical & IT Security
Visitors
Clean Desk
Technical Data Discard
Lam Research Corp.
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Hiring Process
Lam Research Corp.
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Hiring Process
* Source for candidates and shortlist for interviews
* Obtain documentation (NRIC/Passport) to
determine nationality
* Successful candidate
* If TRI, align with Corporate Foreign Trade
department to start license application
* If license is granted, offer the position
* If license is not granted, restart the sourcing
and interview process
* New hire is required to read and sign the Export
Compliance Management Policy/Agreement on
the first day of work
Trade Restricted Individual (TRI):
Personnel who has citizenship/residency from the restricted countries (e.g. Russia), and requires a
license to receive Lam controlled technology per the USA export control regulations.
Lam Research Corp.
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Badge Colors and TRI
Employee Name
Employee Photo
Colour Stripe
Definition
Blue
Regular
Employee
Magenta
Contractor
Yellow
Temporary Staff
Red
Security
Green
Professional
Services
Employee Number
Color of the badge indicates the level of access and
privileges given to the individual who wears it.
For TRI, there will be a orange stripe on the badge
Lam Research Corp.
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Trade Restricted Individual Travel &
Technical Training
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Travel Management for TRI
Travel request
assessment
TRI travel to SG
SG engineer to
Trade Restricted
Countries
• Employee’s supervisor determine if the travel
activities are in compliance with the License
• Travel logs maintain for annual audit.
• A questionnaire would be filled by Lam SG’s
office
• Sent to the respective Lam Office and Foreign
Trade for approvals
• Briefed on the TRI requirements and the
receiving site manager notified
Lam Research Corp.
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Technical Training Management for TRI
Identify the Trade
Restricted Trainee
employee
• Host responsible to
ensure nationality
clearance.
External Attendees from
Trade restricted countries
• Fill a registration
questionnaire &
declaration prior to
training
• Retention of attendance
logs /declarations
Clearance from FT
• To embargo training if
not within approved list
supported under license
• Clearance from FT once
license obtained.
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Access Controls
Lam Research Corp.
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Physical Security
► Objective
of Physical Security and Network Security Controls
 Prevent unauthorized parties from accessing Lam’s controlled information
Visitors Sign-In &
validation of Identity
Clean Desk
Procedure
• Securing under
Lock & keys
• No display of
technical
information in
common areas
e.g. Meeting
rooms
Escorting External
visitors
Restrict to lobby
conference rooms
Technical
Data
Discarding
procedures
Badging
Screening for Trade
Restricted Individuals
Visual identification &
Color Differentiation
• Removal of Data
on paper through
secured trash
receptacles or
shredders
• IT Personnel to
manage removal
of datadisk/drives
Lam Research Corp.
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IT Security
Network
security
Intangible
Transfer of
Technology
• Network a/c Request form
• Access based on job functions and authorized
license conditions
• Physical security and access controls of servers
and network systems
• Categorization of local filers
• Designated email box to capture technology
materials transmitted.
• Quarterly communication & checklist /declaration
by frequent technology transfer groups
• Technology Export Control Agreements established
with related Lam entities
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Certification Training & Awareness Updates
Mandatory Biennial On-line Foreign Trade training module
Annual Certification of All employees. Training materials
shared to employees.
Training topics include export and re-export licensing of
controlled materials, customer screening, record keeping,
anti-bribery and post-shipment audit review, etc.
Regular updates of regulatory changes impacting operations are
provided to Lam’s management team by Foreign Trade
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Order Processing Procedure
Denied
Parties
Screening
• Screen customers against denial list prior to conducting business.
• Screen order automatically against denial list throughout its
lifecycle (e.g. order creation, changes to order, prior to shipment)
• Review orders requiring an export license
Export
Licensing
• Gather supporting documents and submit applications to authority
• Setup export licenses and product classification in SAP/GTS
• Audit export license transactions
• Generate export and shipping documents from SAP
Shipping
• Ensure all shipments have proper documentation prior to export
• Declare the correct export permit timely
• SAP/GTS is programed to block all unlicensed shipment
All relevant documents are maintained for five years
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Platform for Export Control Compliance Requirement
Global Trade Services (GTS)
ECCN / HTS classification, COO Database
Ability to block/release customer account for all sales
transactions
Ability to block/release licensable export transactions
Ability to generate report for audit purpose
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Shipment for Controlled parts
Configure GTS
Block order
ECCN classification
Country of export
Destination country
Alert the team that
the shipment require
export license
a. Bulk Permit –
Declare the
appropriate export
permit
b. Individual Permit –
Apply export license
Release Block
Shipment
After proper
declaration or license
received
Ship and attach
export permit and
Note: Function is
airway bill in system
limited to Foreign
Trade department
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Internal Review and Audit Process
Conduct annual audit as part of the governance
• All employees and responsible
departments to:
• participate in the annual internal
review
• provide requested documents
timely
• Address and close any action item
timely
• Interviews owners on current
processes, sight written procedures
and supporting documentation,
physical inspection in office,
highlight areas of risks.
Partnership:
Local Process Owners &
Corporate Foreign Trade
Team
• HR Hiring & Screening Process
• Physical & IT Security
• Shipment Control
• Certification & Annual Trainings
• Technical Training & Travel
Key Audit Areas
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Conclusion
►
Every employee is an integral part of Lam Research
export control compliance process.
►
Lam is committed to act in compliance with Trade laws
in all jurisdictions in which we do business.
Lam Research Corp.
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