Visa Sponsorship Letter Best Practice Procedure

Tracy Horridge Export and Security Administrator Thermo Scientific Portable Optical Analysis Wilmington MA

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Visa Sponsorship letters

• Needed to obtain a visa to visit the US by some Foreign nationals • Based on country of citizenship • 36 countries participate in the visa waiver program • Letter writer assumes responsibility for the actions of the visitor while the visitor is in the US • The letter must contain accurate information, using false or misleading information constitutes a felony • What can go wrong?

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Corrective Action Taken

• Immediately implemented a procedure to be followed by all US business units.

• Procedure was communicated directly to all Site Leaders • The procedure requires that sponsor letters be approved by Site Leader and a member of the Global Trade Compliance (GTC) team • Addresses past deficiency, when sponsorship/invitation letters were non-uniform and inadequate - written by a variety of personnel (sales people, engineers, buyers, human resources, administrators) • Export Coordinator involvement required • Visitor must be screened against denied parties lists • Must look at the controls of technology that the visitor may be exposed to

When can we sponsor a visitor?

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• Thermo Fisher only sponsors visas for valid business purposes • Sponsorship for dates at Thermo facilities only. • No leisure travel.

• No behavioral assurances or guarantees can be made • Relatives of visitors should not be sponsored, letter is for visitor only • Letter should be written per Thermo guidelines • Visitors name, home address, date/place of birth, passport number, place/date of issuance/expiry, employer • Payment of travel expenses must be approved • Care must be used not to violate the Foreign Corrupt Practices Act (FCPA) or Thermo Fisher’s policies

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Sample Letter

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Compliance Concerns

• Understand our products and technology and what visitors will have access to • If there are controlled products or technology access may need to be restricted or export license approved • Be careful to prevent Deemed Exports • If there is knowledge that visitor plans to visit other Thermo Fisher sites, ensure that Export Coordinator at that site is notified and aware • Red Flags • Look for any indication that the visitor plans to stay in the US beyond visa allowance • Are they attempting to access restricted technology?

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Host Responsibilities

• Did the visitor show up/depart as scheduled • If they do not show up, immediately advise the export coordinator for reporting to GTC, Site Leader and Legal • Assure that the visitor is accompanied at all times • Visitors should not be allowed to roam the facility freely • Submit a written report of the visit to the GTC Team • Summary of meetings, training etc • When did they arrive, depart • Where did they go

Web Tool Developed to Assist

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• Website was designed to assist Thermo Fisher employees in the creation of these letters • Electronic approval and follow-up mechanism to help better manage the process. • Site Leader, business unit export coordinator, and GTC team will receive notifications of the proposed visit • No letters will be generated until approval by the appropriate parties occurs. • The drafter of the letter will receive emails after the visit requesting information regarding the visit.

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Web Tool

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Web Tool

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Web Tool Information

• Series of checklists to assure compliance at all steps in the process • Export Coordinator • Site leader notification • Main Checklist • Visitor Information • • Travel Expense reimbursement Thermo Employee • Follow up Checklist • Did visitor arrive/depart as scheduled?

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Questions