7.3 Internal Compliance Programs (ICP)

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

  1. Policies and Procedures:
    • Written guidelines on permits, CoC, traceability, and record-keeping
    • Procedures for NDF compliance, source verification, and quota adherence
  2. Training and Capacity Building:
    • Regular training for staff on regulatory requirements and company policies
    • Specialized sessions on documentation, inspections, and reporting
  3. Monitoring and Auditing:
    • Regular internal audits of permits, invoices, packing lists, and CoC records
    • Monitoring adherence to traceability and farm-to-market systems
  4. Reporting and Corrective Actions:
    • Clear reporting channels for potential violations or discrepancies
    • Mechanisms for corrective actions, including re-training, process adjustment, or disciplinary measures
  5. 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