Compliance Guidelines

Sunalei is committed to operating ethically and responsibly, adhering to all relevant US laws and regulations, and ensuring transparency with our donors, supporters, and partners. As a US-based non-profit with a focus on domestic STEM job creation, we recognize the potential for international collaborations and interactions in achieving our mission. 

These guidelines aim to establish internal expectations and provide clarity to stakeholders regarding our approach to international operations while minimizing legal and reputational risks.

Scope

These guidelines apply to all activities, operations, and potential partnerships that cross international borders, including but not limited to:

• International Investors and Partners: Engaging with investors, collaborators, or partners based outside the United States.
• Overseas Professionals: Facilitating potential job opportunities within the US for STEM professionals coming from overseas, potentially requiring immigration-related assistance.
• International Donations: Accepting donations or support from individuals or organizations located outside the United States.
• Cross-Border Collaborations: Working with other organizations or entities overseas in furtherance of our mission.

Key Compliance Considerations

US Laws and Regulations:

• International Trade and Sanctions: Sunalei will abide by all US import/export regulations, trade restrictions, and sanctions programs (e.g., OFAC). We will conduct due diligence on partners to ensure they are not on any restricted party lists.
• Foreign Corrupt Practices Act (FCPA):  Sunalei maintains a strict anti-bribery and anti-corruption stance. We prohibit the giving or receiving of anything of value to improperly influence foreign officials or gain a business advantage.
• Investment and Financial Restrictions: Sunalei will adhere to any financial reporting or restrictions related to international donations or investments. We will maintain robust recordkeeping on sources and uses of international funds.

Immigration Support:

• Limited Immigration Assistance: While Sunalei may offer basic information and resources related to US work visas for STEM professionals, we will not provide comprehensive immigration legal advice or services.
• Partner Referrals: Sunalei may maintain strategic partnerships with qualified immigration professionals or firms to provide specialized immigration support services.

International Donations and Partnerships:

• Donor Vetting: Sunalei will conduct due diligence on potential international donors to ensure alignment with our mission and to assess any potential reputational or ethical risks.
• Transparency: Sunalei will be transparent about the source of international donations to our stakeholders.
• Mission Alignment: Sunalei will ensure international partnerships and collaborations align with our mission and ethical principles. We will avoid relationships that could potentially compromise our independence or negatively impact our reputation.

Operational Considerations

• Risk Assessment: Sunalei will regularly assess its risk exposure related to international operations and update these guidelines accordingly.
• Relationship Management and Oversight: Sunalei will assign a responsible individual (or team) to oversee international partnerships and ensure compliance.
• Partner Due Diligence: Before formalizing any international partnerships, Sunalei will conduct background checks and ensure alignment of values, missions, and practices.
• Contractual Agreements: Sunalei will utilize formal contracts or agreements to establish clear expectations and responsibilities when working with international partners.
• Recordkeeping and Reporting: Sunalei will maintain thorough records of all international activities, including contracts, correspondence, donations, and financial transactions. Regular reporting on international operations will be provided to the Board of Directors or relevant oversight bodies.

Continuous Improvement

Sunalei recognizes that international operating environments and relevant laws can evolve rapidly. We are committed to regular reviews and updates of these guidelines.

Disclaimer

These guidelines do not comprise the comprehensive International Operations Compliance Guidelines of the organization and are not a substitute for legal counsel. Sunalei will always consult with qualified professionals on complex international legal operations and integrate complete and custom-designed International Operations Compliance Guidelines with each international transaction.

Contact:

For more information, requirements, special requests, or consultation about Sunalei’s International Operations Compliance Guidelines, please contact:

Nitzahary Marchi
Global Compliance Director
nitzahary@sunalei.org

For direct mailing, please use:

SUNALEI – GLOBAL COMPLIANCE DEPARTMENT
ATT: Nitzahary Marchi
PO Box 277
Clawson, MI 48017