Purpose: To provide guidance on establishing internal compliance programs for agarwood and other high-value plant trade, ensuring adherence to CITES regulations, national laws, and corporate governance standards.
A. Definition
- Internal Compliance Program (ICP): A structured system within an organization to prevent, detect, and address non-compliance with CITES, national regulations, and internal policies.
- Ensures that all staff and processes align with legal, ethical, and sustainability requirements.
B. Key Components
- Policies and Procedures:
- Written guidelines on permits, CoC, traceability, and record-keeping
- Procedures for NDF compliance, source verification, and quota adherence
- Training and Capacity Building:
- Regular training for staff on regulatory requirements and company policies
- Specialized sessions on documentation, inspections, and reporting
- Monitoring and Auditing:
- Regular internal audits of permits, invoices, packing lists, and CoC records
- Monitoring adherence to traceability and farm-to-market systems
- Reporting and Corrective Actions:
- Clear reporting channels for potential violations or discrepancies
- Mechanisms for corrective actions, including re-training, process adjustment, or disciplinary measures
- Integration with Technology:
- Digital tracking systems, QR codes, batch IDs, blockchain, and audit trails
- Automated alerts for permit expirations, quota limits, or documentation gaps
C. Benefits
- Proactively ensures regulatory compliance and reduces legal risk
- Supports traceability, ESG alignment, and investor confidence
- Improves operational efficiency and documentation accuracy
- Demonstrates good governance to regulators and market partners
D. Practical Recommendations
- Establish clear ICP policies and communicate them to all employees
- Conduct periodic training and capacity-building programs
- Implement digital tools for monitoring and record-keeping
- Perform regular internal audits and respond promptly to findings
- Align ICP with risk assessments, traceability, and compliance reporting
Learning Outputs
- Understanding of the purpose and structure of an Internal Compliance Program
- Ability to implement ICP components for CITES compliance and sustainability
- Awareness of the benefits for regulatory, operational, and investor confidence
- Skills to monitor, audit, and continuously improve compliance systems