GLOBAL SECURITY VERIFICATION

P RE V ERIFICATION K IT

T ABLE OF CONTENTS

WELCOME A N D I N TR O D U C T I O N 1

C-TPAT M I N I M U M S E C U R I T Y C R I T ER I A 2

S A M P L E S I TE A G EN D A 8

REQUEST FOR INDIVIDUALS 8

DOCUMENT CHECKLIST 9

P O S T V ER I FI C A T I ON P R O C E S S 10

ANTI BRIBERY LETTER 11

 GLOBAL SECURITY VERIFICATION

Thank you for choosing Intertek’s Global Security Verification (GSV) program. GSV assists clients to verify
their compliance with the U.S. Customs & Border Protection (CBP) Customs-Trade Partnership Against
Terrorism (C-TPAT) requirements. Driven by a heightened sense of security awareness and the need for
stricter border controls, CBP created C-TPAT to better secure U.S.-bound supply chains. The program is
voluntary for a range of eligible operators and instills a risk model for supply chain security from the point of
product origin to U.S. distribution.

Through a comprehensive on-site verification of security practices, the GSV program determines whether a
facility meets C-TPAT minimum security criteria and what improvements, if any, are necessary to achieve
compliance. GSV outcome reporting provides risk assessments based on country- and industry-specific
security performance. Together with supply chain specialists, we developed the survey tool and scoring
methodology used for the on-site verification. The same methodology has been provided to CBP, providing
an early foundation for the C-TPAT on-site validation program.

The opening meeting with the GSV inspector will familiarize facility management with the nature of the site
audit. The GSV inspector will interview key employees to gauge general security practices and review
relevant documentation. For the purpose of efficiency, please have copies of these documented
procedures available. GSV requires samples of each relevant document (this packet includes a list of
required documents). GSV ensures confidentiality.

Once the interviews and document reviews are complete, the GSV inspector will tour the facility,
administering a detailed survey to verify that documented policies and practices are adhered to and that
employees are knowledgeable of and follow all security protocol. This facility walk-through should take
between one to two hours depending on the size and complexity of the operation.

During the closing meeting, the GSV inspector will inform the facility of areas of low or non-compliance.
GSV will not disclose the facility’s score at this meeting; rather, a formal report on findings will be provided
to the facility within five (5) business days of the on-site verification.

Upon completion of GSV on-site verification, if the facility achieves a score of 71 or above, the facility will
qualify for the GSV certificate. The GSV certificate confirms completion of a GSV audit and indicates the
level of implementation of C-TPAT foreign manufacturer security criteria.

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 C-TPAT M INIMUM S ECURITY R EQUIREMENTS
FOR F OREIGN M ANUFACTURERS

The GSV audit is to verify the factory’s compliance with the U.S. Customs & Border Protection (CBP)
Customs-Trade Partnership Against Terrorism (C-TPAT) requirements. The requirements are as follows:

Minimum-Security Criteria for C-TPAT Foreign Manufacturers

04/28/2008

These minimum security criteria are fundamentally designed to be the building blocks for foreign manufacturers to
institute effective security practices designed to optimize supply chain performance to mitigate the risk of loss, theft,
and contraband smuggling that could potentially introduce terrorists and implements of terrorism into the global
supply chain. The determination and scope of criminal elements targeting world commerce through internal
conspiracies requires companies, and in particular, foreign manufacturers to elevate their security practices.

At a minimum, on a yearly basis, or as circumstances dictate such as during periods of heightened alert, security
breach or incident, foreign manufacturers must conduct a comprehensive assessment of their international supply
chains based upon the following C-TPAT security criteria. Where a foreign manufacturer out-sources or contracts
elements of their supply chain, such as another foreign facility, warehouse, or other elements, the foreign
manufacturer must work with these business partners to ensure that pertinent security measures are in place and are
adhered to throughout their supply chain. The supply chain for C-TPAT purposes is defined from point of origin
(manufacturer/supplier/vendor) through to point of distribution – and recognizes the diverse business models C-TPAT
members employ.

C-TPAT recognizes the complexity of international supply chains and security practices, and endorses the application
and implementation of security measures based upon risk1. Therefore, the program allows for flexibility and the
customization of security plans based on the member’s business model.

Appropriate security measures, as listed throughout this document, must be implemented and maintained throughout
the Foreign manufacturer’s supply chains - based on risk2.

Business Partner Requirement

Foreign manufacturers must have written and verifiable processes for the selection of business partners including,
carriers, other manufacturers, product suppliers and vendors (parts and raw material suppliers, etc).

Security procedures
For those business partners eligible for C-TPAT certification (carriers, importers, ports, terminals, brokers,
consolidators, etc.) the foreign manufacturer must have documentation (e.g., C-TPAT certificate, SVI number, etc.)
indicating whether these business partners are or are not C-TPAT certified.

For those business partners not eligible for C-TPAT certification, the foreign manufacturer must require that their
business partners to demonstrate that they are meeting C-TPAT security criteria via written/electronic confirmation
(e.g., contractual obligations; via a letter from a senior business partner officer attesting to compliance; a written
statement from the business partner demonstrating their compliance with C-TPAT security criteria or an equivalent
World Customs Organization (WCO) accredited security program administered by a foreign customs authority; or, by

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providing a completed foreign manufacturer security questionnaire). Based upon a documented risk assessment
process, non-C-TPAT eligible business partners must be subject to verification of compliance with C-TPAT security
criteria by the foreign manufacturer.

Point of Origin
Foreign manufacturers must ensure that business partners develop security processes and procedures consistent
with the C-TPAT security criteria to enhance the integrity of the shipment at point of origin, assembly or
manufacturing. Periodic reviews of business partners’ processes and facilities should be conducted based on risk,
and should maintain the security standards required by the foreign manufacturer.

Participation/Certification in a Foreign Customs Administration Supply Chain Security Program

Current or prospective business partners who have obtained a certification in a supply chain security program being
administered by foreign Customs Administration should be required to indicate their status of participation to the
foreign manufacturer.

Security Procedures
On U.S. bound shipments, foreign manufacturers should monitor that C-TPAT carriers that subcontract transportation
services to other carriers use other C-TPAT approved carriers, or non-C-TPAT carriers that are meeting the C-TPAT
security criteria as outlined in the business partner requirements.

As the foreign manufacturer is responsible for loading trailers and containers, they should work with the carrier to
provide reassurance that there are effective security procedures and controls implemented at the point-of-stuffing.

Container and Trailer Security

Container and trailer integrity must be maintained to protect against the introduction of unauthorized material and/or
persons. At the point-of-stuffing, procedures must be in place to properly seal and maintain the integrity of the
shipping containers and trailers. A high security seal must be affixed to all loaded containers and trailers bound for
the U.S. All seals must meet or exceed the current PAS ISO 17712 standard for high security seals.

In those geographic areas where risk assessments warrant checking containers or trailers for human concealment or
smuggling, such procedures should be designed to address this risk at the manufacturing facility or point-of-stuffing.

Container Inspection
Procedures must be in place to verify the physical integrity of the container structure prior to stuffing, to include the
reliability of the locking mechanisms of the doors. A seven-point inspection process is recommended for all
containers:
• Front wall
• Left side
• Right side
• Floor
• Ceiling/Roof
• Inside/outside doors
• Outside/Undercarriage

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Trailer Inspection
Procedures must be in place to verify the physical integrity of the trailer structure prior to stuffing, to include the
reliability of the locking mechanisms of the doors. The following ten-point inspection process is recommended for all
trailers:
• Fifth wheel area - check natural compartment/skid plate
• Exterior - front/sides
• Rear - bumper/doors
• Front wall
• Left side
• Right side
• Floor
• Ceiling/Roof
• Inside/outside doors
• Outside/Undercarriage

Container and Trailer Seals

The sealing of trailers and containers, to include continuous seal integrity, are crucial elements of a secure supply
chain, and remains a critical part of a foreign manufacturers’ commitment to C-TPAT. The foreign manufacturer must
affix a high security seal to all loaded trailers and containers bound for the U.S. All seals must meet or exceed the
current PAS ISO 17712 standards for high security seals.

Written procedures must stipulate how seals are to be controlled and affixed to loaded containers and trailers, to
include procedures for recognizing and reporting compromised seals and/or containers/trailers to US Customs and
Border Protection or the appropriate foreign authority. Only designated employees should distribute seals for integrity
purposes.

Container and Trailer Storage

Containers and trailers under foreign manufacturer control or located in a facility of the foreign manufacturer must be
stored in a secure area to prevent unauthorized access and/or manipulation. Procedures must be in place for
reporting and neutralizing unauthorized entry into containers/trailers or container/trailer storage areas.

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 vendors 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
vendor 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
should visibly display temporary identification.

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Deliveries (including mail)
Proper vendor ID and/or photo identification must be presented for documentation purposes upon arrival by all
vendors. 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.

Personnel Security
Processes must be in place to screen prospective employees and to periodically check current employees.

Pre-Employment Verification
Application information, such as employment history and references must be verified prior to employment.

Background Checks / Investigations

Consistent with foreign 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.

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 control must include safeguarding computer access and information.

Manifesting Procedures
To help ensure the integrity of cargo, procedures must be in place to ensure that information received from business
partners is reported accurately and timely.

Shipping and Receiving

Departing cargo being shipped 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. Procedures should also be established to track the timely movement of
incoming and outgoing goods.

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Cargo Discrepancies
All shortages, overages, and other significant discrepancies or anomalies must be resolved and/or investigated
appropriately. Customs and/or other appropriate law enforcement agencies must be notified if anomalies, illegal or
suspicious activities are detected - as appropriate.

Physical Security
Cargo handling and storage facilities in international locations must have physical barriers and deterrents that guard
against unauthorized access. Foreign manufacturer 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 and 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.

Information Technology Security

Password Protection
Automated systems must use individually assigned accounts that require a periodic change of password. IT security
policies, procedures and standards must be in place and provided to employees in the form of training.

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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.

Security Training and Threat Awareness

A threat awareness program should be established and maintained by security personnel to recognize and foster
awareness of the threat posed by terrorists and contraband smugglers 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 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.

1 Foreign manufacturers shall have a documented and verifiable process for determining risk throughout their supply
chains based on their business model (i.e., volume, country of origin, routing, C-TPAT membership, potential terrorist
threat via open source information, having inadequate security, past security incidents, etc.).
2 Foreign manufacturer shall have a documented and verifiable process for determining risk throughout their supply

chains based on their business model (i.e., volume, country of origin, routing, potential terrorist threat via open
source information, etc.)

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 S AMPLE SITE VISIT AGENDA

Supply Chain Security Risk Assessment Agenda

[DATE]
[COMPANY NAME]

Interviews with key managers are followed by individual/group interviews on [Company Name’s] security-
related documentation and processes.

Facilitator(s): [GSV inspector(s) responsible for facilitating assessment]

Attendees: Responsible managers in the following areas:

1. Information Technology
2. Business Partner Selection
3. Security
4. Logistics/Transportation and Documentation
5. Shipping
6. Training
7. Human Resources

R EQUEST FOR I NDIVIDUALS

GSV requests that managers in the following areas be made available for interviews over the course of the
day:

ƒ Business Partner Selection

ƒ Human Resources
ƒ IT
ƒ Logistics/Transportation and Documentation
ƒ Security
ƒ Shipping
ƒ Training

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 D OCUMENT C HECKLIST
In each instance where applicable, please have the following documents ready for the GSV inspector’s
review:

CHECK N A M E O F D O C U M E N T /R E C O R D
HR/T R A I N I N G
Written personnel security guidelines for hiring
Personnel files: including demonstration of pre-employment verification, background
checks and/or investigations, including updated/periodic employee checks (based on
cause or sensitivity of position)
Employee termination procedure
Employee code of conduct or handbook
Employee orientation and training(s) materials and records
Employee security awareness training materials and records
Employee ID records: including distribution, retrieval, and missing Ids
Facility access keys records: including distribution, retrieval, and missing keys
SECURITY
Facility security plan
Security guard/force contract
Security guard/force training record
Security guard/force job description
Security guard/force post orders and descriptions
Employee access control procedures
Employee entrance/exit records
Visitor/Vehicle entrance/exit access control and management procedures
Visitor/Vehicle entrance/exit records
Procedures for screening arriving packages and mail
Procedures for periodic unannounced security checks
Physical security procedures: including fencing, lighting, alarm systems, and CCTV
coverage
SHIPPING & LOGISTICS
Conveyance drivers entrance/exit records
Container security procedures

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 Container integrity inspection procedures
Container inspection records
Policy/procedures for affixing, replacing, recording and tracking seals
Cargo shipping and receiving procedures
Cargo loading records
Shipping documents: including purchase orders, invoices, pickup orders and customer
notifications
Over Short & Damage (OS&D) reports
Seal control records
INFORMATION TECHNOLOGY
Information access control procedures
IT security procedures
BUSINESS PARTNER SELECTION
Security standards and procedures for contractors and vendors: including contracts,
manuals, etc.
Selection process of business partners: including carriers, consolidators and 3PLs
Evidence of partners’ participation in C-TPAT or other supply chain security programs
administered by foreign Customs administrations: including SVI numbers (for C-TPAT),
contracts, letters and questionnaires
Procedures for periodic risk-based review of business partners’ processes and
procedures

P OST - VERIFICATION PROCESS

After conducting the comprehensive GSV audit, GSV will provide the GSV report to the facility within five
business days of the on-site verification. After receiving the comprehensive findings, the facility then bears
the responsibility for reviewing and implementing the proposed corrective actions supplied in the GSV
report. The facility will also benefit from access to GSV’s database for cross-comparison reporting on
supply chain security inspections. If the score achieved is 71 or above, the facility will qualify for the GSV
certificate. The GSV certificate confirms completion of a GSV audit and indicates the level of
implementation of C-TPAT foreign manufacturer security criteria. The GSV certificate does not take
precedence over any C-TPAT members’ factory security audit requirements. Based on your GSV visit
result, your C-TPAT member business partner will communicate with you regarding the level of expected
minimum performance and frequency of periodic visits to verify implementation, based on their
individual risk-based supply chain security program.

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 A NTI -B RIBERY L ETTER

Audit Date:
Factory Name:
Auditor Name:
Job No.:

To Manufacturers:

We believe in honesty and fair play and consider that gifts in business are unnecessary and might even jeopardize a cordial and
mutually beneficial, business relationship. Thus, we do not permit our staff to ask for or accept any benefit including gifts, money,
rebate, hospitality, etc. in business dealings. We therefore seek your cooperation not to offer any benefit to our staff in business
dealings. If your factory offers any abovementioned benefits to our staff, we would record it accordingly. We would provide such
information to the client if it is requested by client.

After reading the above announcement, please sign your name with company chop in the space below:

_____________________ ________________
Signature and Company Stamp Arrival
_____________________
Time

If you have any complaint or comment, please refer the information to the following person. We guarantee that complaint
will be followed up immediately.

Intertek Testing Services Shenzhen Ltd.

Sina Wang –Compliance Officer
Tel: (86) 755 2602 0514
Fax: (86) 755 2602 0899

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