Thompson & Co. of Tampa, Inc THE THOMPSON GROUP The Thompson Group “Import Shipping Requirements” TTG requires its foreign shippers to provide all documentation required for entry into the U.S. to the foreign freight consolidator, carrier, issuing bank or directly to TTG prior to exportation as specified under other associated agreements, such as an approved purchase order. Because of requirements and regulations for various U.S. government agencies, the types of documentation may vary and may include additional declarations or statements that are not contained in the following list. The foreign shipper is to contact the Import Compliance Manager at TTG if it has any questions regarding the type of documentation required for entry into the U.S. In general, the following documentation is required: o Commerical Invoice o Packing List o Express Release Bill of Lading o Other U.S. government agency documentation and declarations, such as the Federal Communications Commission, Food and Drug Administration, Fish and Wildlife, Department of Transportation, and Environmental Protection Agency. With the enactment of U.S. Treasury Directive 02-62 on December 2, 2002, it is a requirement for shippers to provide complete and accurate product descriptions and/or tariff information to the six-digit level to the entities providing the cargo manifest to CBP 24 hours prior to the cargo being laden on board. If accurate descriptions are not provided, the cargo can be denied loading onto the shipping vessel. This regulation applies to all ocean cargo destined for the United States, whether the cargo is to remain in the United States or be transported in-bond to another country. These regulations have been implemented as well for air and truck cargo as of December 2003. In addition, under Title 19 of the Code of Federal Regulations (19 CFR §141.86) commercial invoices are required to provide the following information in English: 1. Port of entry for which the merchandise is destined and date; 2. Invoice number; 3. Invoice date; 4. Terms of sale/payment, i.e., Net 30, Draft/At Sight, Receipt of Freight, etc.; 5. Trade terms, i.e., FOB, CIF, EX-FACTORY, etc.; 6. Net and gross weight for merchandise; 7. Detailed, accurate description of merchandise, including a part or model number/style number, carton marks and numbers; 8. Quantity of merchandise; 1 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP 9. Shipping unit of measurements; 10. Unit price in the currency of the purchase; 11. Type of currency; 12. Country of origin of the merchandise; and 13. Name and address of the foreign party responsible for invoicing, and the actual manufacturer’s complete name and address (if the party varies from the foreign invoicing party). TTG requires its foreign shippers to affix a high security seal to ocean containers destined to the U.S. that meets or exceeds the current PAS ISO 17712 Standards. TTG requires its foreign shippers to conduct an inspection of ocean containers prior to stuffing to detect any potential or existing breaches in security or container integrity issues. Specifically, the shippers are to inspect ocean containers for false walls, plates, hidden compartments, unusual repairs, hatches, “step-ups,” unusual interior paint or welding work, false boxes, unusual glued or welded seams on the interior or exterior, defective door locking devices, stripped exterior door bolts, wood or other unusual flooring material, and other similar security concerns. If a security breach is detected, the foreign shipper is to immediately notify the Purchasing Manager at TTG and the steamship line, seize and secure the container for inspection by law enforcement authorities, and obtain a replacement container from the steamship line. TTG recommends that its foreign shippers inspect containers through an eight-point inspection process, including: front wall, left side, right side, floor, ceiling/roof, inside/outside doors, outside/undercarriage, and door locking mechanisms. TTG requires its foreign shippers to securely control and maintain seals. Seals are to be maintained in a safe and secure environment, such as a locked file cabinet or safe. Seals are to be dispensed by a designated employee responsible for the disbursement and safekeeping of the seals, never a non-employee, such as a trucker. TTG requires its foreign shippers to inspect seals prior to being affixed to ocean containers to ensure that they are not faulty, tampered with, or manipulated. The probe and lock ends are to be examined carefully to ensure that glue or other debris has not been placed in the lock end and that the probe has not been altered to prevent locking. TTG requires its foreign shippers to affix the seal to the assigned container once the doors are closed. To increase the level of security, seals are to be affixed to the right door of the container on the hasp that has the welded rivit. Once affixed to the container, the seal is to be pulled downward and twisted to ensure that it does not unscrew and that it is securely locked. TTG requires its foreign shippers to record the seal number, commodity type, purchase order number, container number, and name of the employee that sealed the container in a log, spreadsheet, or similar means for recordkeeping purposes. The seal number is to be provided to the ocean carrier or consolidator for inclusion as a data element on the ocean bill of lading for verification purposes once it is received in the United States by TTG. 2 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP TTG requires its foreign shippers to store empty and full ocean containers in a secure area to prevent unauthorized access and/or manipulation. TTG recommends that containers be stored in a fenced-in and secure yard, where available. Where such a facility is not available, ocean containers are to be secured by backing up the doors to a hard surface, such as an elevated concrete loading dock or building wall and secured with a padlock or seal. TTG expects that its foreign shippers conduct training of its shipping personnel responsible for stuffing of containers, maintaining and disbursing of seals, storing of containers, and other similar activities as to the “Shipping Requirements” addressed in this Document. The shipping personnel are to immediately notify appropriate management of any discovered breaches in security or integrity issues regarding seals and containers. Furthermore, the shipping personnel are to immediately notify appropriate management if they detect any unauthorized or unidentified persons on company premises, including container loading and storage areas. TTG expects that its foreign shippers will immediately implement security measures, procedures and policies consistent with CBP Security Criteria for CTPAT: o Physical Access Controls: Access controls prevent unauthorized entry to facilities, maintain control of employees and visitors, and protect company assets. Access controls must include the positive identification of all employees, visitors, and shippers at all points of entry. Employees: An employee identification system must be in place for positive identification and access control purposes. Employees should only be given access to those secure areas needed for the performance of their duties. Company management or security personnel must adequately control the issuance and removal of employee, visitor, and service provider identification badges. Procedures for the issuance, removal, and changing of access devices (e.g., keys, key cards, etc.) must be documented. Visitors: Visitors must present photo identification for documentation purposes upon arrival. All visitors should be escorted and visibly display temporary identification. Deliveries (including mail): Proper ID and/or photo identification must be presented for documentation purposes upon arrival by all service providers. Arriving packages and mail should be periodically screened before being disseminated. Challenging and Removing Unauthorized Persons: Procedures must be in place to identify, challenge, and address unauthorized/unidentified persons. o Personnel Security: Processes must be in place to screen prospective employees and to periodically check current employees. 3 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP Pre-Employment Verification: Application information, such as employment history and references, must be verified prior to employment. Background checks / investigations: Consistent with foreign, federal, state, and local regulations, background checks and investigations should be conducted for prospective employees. Once employed, periodic checks and reinvestigations should be performed based on cause, and/or the sensitivity of the employee’s position. Personnel Termination Procedures: Companies must have procedures in place to remove identification, facility, and system access for terminated employees. o Procedural Security: Security measures must be in place to ensure the integrity and security of processes relevant to the transportation, handling, and storage of cargo in the supply chain. Documentation Processing: Procedures must be in place to ensure that all information used in the clearing of merchandise/cargo is legible, complete, accurate, and protected against the exchange, loss, or introduction of erroneous information. Documentation controls must include safeguarding computer access and information. Manifesting Procedures: To help ensure the integrity of cargo received from abroad, procedures must be in place to ensure that information received from business partners is reported accurately and timely. Shipping & Receiving: Arriving cargo should be reconciled against information on the cargo manifest. The cargo should be accurately described, and the weights, labels, marks, and piece count indicated and verified. Departing cargo should be verified against purchase or delivery orders. Drivers delivering or receiving cargo must be positively identified before cargo is received or released. Cargo Discrepancies: All shortages, overages, and other significant discrepancies or anomalies must be resolved and/or investigated appropriately. CBP and/or other appropriate law enforcement agencies must be notified if illegal or suspicious activities are detected - as appropriate. o Security Training and Threat Awareness: A security training and threat awareness program should be established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorism at each point in the supply chain. Employees must be made aware of the procedures the company has in place to address a situation and how to report it. Additional training should be provided to employees in the shipping and receiving areas, as well as those receiving and opening 4 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP mail. Additionally, specific training should be offered to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls. These programs should offer incentives for active employee participation. o Physical Security: Cargo handling and storage facilities in domestic and foreign locations must have physical barriers and deterrents that guard against unauthorized access. Importers should incorporate the following C-TPAT physical security criteria throughout their supply chains as applicable. Fencing: Perimeter fencing should enclose the areas around cargo handling and storage facilities. Interior fencing within a cargo handling structure should be used to segregate domestic, international, high value, and hazardous cargo. All fencing must be regularly inspected for integrity and damage. Gates and Gate Houses: Gates through which vehicles and/or personnel enter or exit must be manned and/or monitored. The number of gates should be kept to the minimum necessary for proper access and safety. Parking: Private passenger vehicles should be prohibited from parking in or adjacent to cargo handling and storage areas. Building Structure: Buildings must be constructed of materials that resist unlawful entry. The integrity of structures must be maintained by periodic inspection and repair. Locking Devices and Key Controls: All external and internal windows, gates, and fences must be secured with locking devices. Management or security personnel must control the issuance of all locks and keys. Lighting: Adequate lighting must be provided inside and outside the facility, including the following areas: entrances and exits, cargo handling and storage areas, fence lines, and parking areas. Alarms Systems & Video Surveillance Cameras: Alarm systems and video surveillance cameras should be utilized to monitor premises and prevent unauthorized access to cargo handling and storage areas. o Information Technology Security Password Protection: Automated systems must use individually assigned accounts that require a periodic change of passwords. IT security policies, procedures, and standards must be in place and provided to employees in the form of training. Accountability: A system must be in place to identify the abuse of IT, including improper access, tampering, or the altering of business data. All system violators must be subject to appropriate disciplinary actions for abuse. 5 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP The Thompson Group “Import Shipping Requirements” We have read and agree to implement the Shipping Requirements listed in this document. ____________________________________ Company Name ______________________________ Country ____________________________________ Name and Signature ______________________________ Date Please submit the signed acknowledgement to: Thompson Cigar Sabine Smallwood, Traffic Manager The Thompson Group 5401 Hangar Court Tampa, Florida 33634 813-884-6344 X6535 E-mail: ssmallwood@thompsongroup.com 6 Thompson & Co. of Tampa, Inc THE THOMPSON GROUP 7