1 AEO Template Introduction WCO Members recognize that global consistency of the approval process and enhanced benefits are essential to encouraging broad trade participation and realization of the mutual benefits of the SAFE Framework and Authorized Economic Operator (AEO) Programmes. In support of this objective, a harmonized AEO Application and Self Assessment questionnaire was developed. It can be used by economic operators applying for AEO status in multiple jurisdictions. It covers the main issues and areas to be addressed during Customs validation of an AEO applicant. The Customs administrations are also encouraged to recognize compliance with international security standards and requirements laid down by other intergovernmental organisations. This document is intended to be included in the WCO SAFE Package and WCO Members that are building the capacity to implement an AEO programme are encouraged to adopt it. The standardized approach will also facilitate the implementation of AEO programmes in developing countries, and potentially facilitate participation in AEO programmes by Small and Medium Sized Enterprises (SMEs). Moreover, the harmonized AEO Application and Self Assessment aims to encourage and facilitate mutual recognition of AEO programmes in order to deliver tangible, transparent and measurable benefits and will serve as an encouragement for applying for AEO status. The document should serve as a guideline, giving WCO Members the flexibility to adjust according to individual domestic requirements consistent with the SAFE Framework of Standards. The aim of the questionnaire is to help economic operators assess whether they meet the criteria to become an AEO and to help them appreciate the requirements associated with obtaining AEO status. At the same time it shall allow the customs authorities to assess the existing risks for the individual applicant. This means that the focus is only on the relevant risks and points for attention. Applicants are not required to give an answer on each and every question if the information was already provided to the customs authority (or other well indicated relevant government authorities if available/accessible for customs) or is not relevant for the specific situation of the applicant (in which case the applicant is invited to briefly explain why this is the case). Not answering a question does not mean the applicant will not be considered.
2 Executive Summary General Information about AEO Programmes In order to secure AEO certification, economic operators must conduct a comprehensive self assessment of their international supply chains based on risk management and in accordance with their business models. The information provided in the self assessment is used by the customs authorities in the AEO authorisation process and shall ensure that this process can be conducted in an efficient manner. The self assessment was developed and should be completed bearing in mind the SAFE Framework Pillar 2, Customs-to-Business, Technical Specifications for Standards Implementation, Standard 1 Partnership: A Customs-to-Business partnership programme should allow for the flexibility and customization of security plans based on the AEO s business model. The application and Self Assessment consist of four parts that should be completed in accordance with the regulatory requirements of the national Customs administration in conformance with the SAFE Framework of Standards. Part I Definitions Part II Global information about Applicant Company. Part III Specific information relating to each country for which the applicant is seeking AEO certification. Note: In Customs unions where branch offices are covered by the application of the parent company, completion of Part III at the branch office level is not required. Part IV A Self Assessment that affirms the existence of policies/procedures that will evidence a control environment against specific criteria required for AEO certification. The Self Assessment should be completed in accordance with the applicant company s business model. Flexibility and customization is especially important with regards to SMEs. II/2.
3 PART I Definitions AEO: Authorized Economic Operator (AEO) is a party involved in the international movement of goods in whatever function that has been approved by or on behalf of a national Customs administration as complying with WCO or equivalent supply chain security standards. AEOs include inter alia manufacturers, importers, exporters, brokers, carriers, consolidators, intermediaries, ports, airports, terminal operators, integrated operators, warehouses, distributors. Business Partner: External Suppliers, manufacturers, logistics service providers etc with whom the applicant has a commercial relationship (often contractual) to fulfil elements of its international supply chain. Service Providers: Suppliers, contractors and vendors to whom the applicant outsources part of its commercial activities Incident: Any security-related risk situation including introduction of unauthorized material or individuals into the supply chain, suspicious activity or security breach. II/3.
4 PART II A) General Company Information 1. AEO Application 1.1 Company Name Company Name (legal entity) Countries for which AEO sought (check all that apply) 1.2 Business Profile Business start date (yyyy-mm-dd) / Years in Business / Date of Establishment Owner Type (Corporation, Partnership, Sole Proprietor, Wholly Owned Subsidiary, Joint Venture, etc.) Principal Businesses (e.g. manufacturers, importers, exporters, brokers, carriers, consolidators, intermediaries, ports, airports, terminal operators, integrated operators, warehouses, distributors.) The nature of the economic activity that the economic operator carries on Company web site address 1.3 Participation In Customs Programmes Detail the ISO country code for all countries in which the economic operator has been admitted to an AEO programme. When the country code is selected you will be prompted to enter the corresponding authorization number If your company is part of a group, please indicate if any other entities in the group: Indicate Type Indicate Business Country Code: xx Authorization Number: nnnnnnnnn a) already have an AEO certificate; or b) have applied for AEO status and are currently undergoing an AEO audit by a national Customs authority. II/4.
5 B) Information on the legal entity applying for the AEO status 0.1 Company/Partner Name (legal entity) 0.2 Operating/Doing Business As (if different) 1. Business Profile in Country 1.1 Business Number (BN) / Business Code / Importer of Record Number/Carrier Code/Economic Operators Registration and Identification (EORI) number 1.2 VAT identification number(s) or N/A Business start date (yyyy-mm-dd) / Years in Business / Date of Establishment 1.3 Owner Type (Corporation, Partnership, Sole Proprietor, Wholly Owned Subsidiary, Joint Venture, etc.) 1.4 Business Sectors 1.5 Commercial activities and positions in the international supply chain (e.g. manufacturers, importers, exporters, brokers, carriers, consolidators, intermediaries, ports, airports, terminal operators, integrated operators, warehouses, distributors.) Indicate Type 2. Company Address in Country 2.1 Physical address / Full address where the entity was established Unit number Street City Prov./terr./state Country Postal code/zip code Contact Number Fax Number 2.2 Mailing address (if different) Unit number Street City Prov./terr./state Country Postal code/zip code Additional delivery info. 2.3 Full address where the main activities of the business are carried out 2.4 Full address of the office where the Customs documentation is kept II/5.
6 2.5 Full address of the office responsible for providing all Customs documentations (If the offices have the same address, indicate same ) 2.6 Full address of the office where the full accounts are kept (If the offices have the same address, indicate same ) 2.7 Multiple Locations List all locations and their addresses in country covered by this application: Site Contact Person Complete Address 2.8 Locations where a third party executes outsourced activities for the economic operator 3.1 Company Contact First and Last Name Position Title Telephone Fax Alternate Contact First and Last Name Position Title Telephone Fax Company Contact Information 1 4. Other certifications 4.1 List certifications under other security-related programmes, standards or other national agencies or authorities if applicable 1 In line with their respective legal systems and the requirements with a view to the background checks customs authorities may include additional questions in self assessment questionnaires regarding responsible persons in the applicant's company such as date of birth, national identification number and experiences and qualifications in Customs matters. II/6.
7 Part III Self Assessment of application (in country/countries of application) 1. Company information 1.1. Describe the internal organisational structure of your company (e.g. through an organisation chart) and the tasks/ responsibilities of each department and list the names of senior management personnel responsible for areas relevant for this application (e.g. Security, Customs Procedures, Finance, Human resources) How many employees do you have in your company? 1.3. Please describe any known planned changes to the company s business practices or relationships that will impact the handling of goods or the supply chain currently being used. II/7.
8 2. Compliance with general requirements for Authorised Economic Operators 2.1 Demonstrated Compliance with Customs Requirements Information and statistics on Customs matters and Customs routines The following questions are only to be answered by importers, exporters or manufacturers or their Customs representatives If you trade in goods that are subject to economic trade licences e.g. textiles, agricultural goods, dual-use goods please describe briefly your procedures for administering the licences related to the import and/or export of such goods Do you deal in goods subject to anti-dumping duties or countervailing duties? If, yes, please briefly provide further information Do you perform Customs formalities in your own name and for your own behalf? Yes No Are you being represented by someone regarding customs formalities (e.g. customs broker / agent)? Sometimes Always Never If so, by whom or how (directly or indirectly) (Name the most significant companies) Please describe your procedures for verifying the accuracy of Customs declarations, including those submitted on your behalf by, e.g., a Customs agent or a freight forwarder Please provide information on the instructions and guidelines for the internal reporting and investigation of breaches in connection with customs-related procedures, and mechanisms for appropriate recording and reporting to Customs Please provide information on the procedures in place on the establishment of Customs value What quality assurance measures do you take to ensure that the Customs value is correctly established (e.g. checks, plausibility checks, internal working instructions, regular training, and other means)? II/8.
9 Regarding country of origin: a) Give an overview of process followed to establish the preferential or non-preferential origin of the imported goods. b) What internal actions have you implemented to verify that the country of origin of the imported goods is declared correctly? c) Describe your approach in the issuing of proof of preferences and certificates of origin for exportation How and by whom, is the tariff classification of goods decided? What quality assurance measures do you take to ensure that the Customs tariff is correctly established (e.g. checks, plausibility checks, internal working instructions, regular training, and other means)? Is documentation retained supporting the measures relating to the procedures referred to in questions to ? Yes No Do you regularly monitor the effectiveness of your quality assurance measures relating to the procedures referred to in questions to ? Yes No Do you have procedures in place regarding the quality assurance measures relating to the procedures referred to in questions to ? Yes No If yes, briefly describe the procedures in place Compliance management Do you have a demonstrated record of compliance over the last three years 2? 2 Another period might be determined in accordance with the respective AEO programme II/9.
10 Have any applications for Customs authorisations/certifications been refused, or existing authorisations been suspended or revoked because of breaches of Customs rules in the last three years 3? 2.2 Satisfactory System for Management of Commercial Records Background information: The accounting and logistical system should provide customs with insights into the flow of goods and flow of money related to the goods flow and the tax aspects are very much relevant in that respect. This is motivated by the wording of the SAFE itself which in accordance with 5.2. Point B clarifies that the AEO is required to give Customs full access to necessary records and that record systems must permit Customs to conduct any audit of cargo movements relating to import and export. An audit trail of the tax relevant movement of goods gives customs the opportunity to cross check if goods can be surreptitiously introduced in international trade supply chains and it provides a clear indication on the licit purposes of a transaction Accounting and logistical system Please describe the essential elements of your business processes that facilitate a full audit trail of your Customs activities or tax relevant movement of goods or accounting entries Describe briefly your procedures for back-up, recovery, fallback, archiving and retrieval of your business records How long are the data saved in the production system and how long are these data archived? Internal control system Please describe the internal control system for the relevant departments of your company to identify, report to responsible management and rectify discrepancies in process and assure proper implementation of customs procedures and legislation Have your internal control processes been subject to any internal/external audit, including audit of your Customs routines? Yes/No 3 Another period might be determined in accordance with the respective AEO programme II/10.
11 Describe in brief your procedures for checking your computer files (standing data or master files)? How do these procedures cover the following risks from your perspective? a) Incorrect and/or incomplete recording of transactions in the accounting system. b) Use of incorrect permanent or out-of-date data such as number of articles and tariff codes. c) Inadequate control of the company processes within the applicant's business, if applicable. 2.3 Financial Viability Do you have a good financial standing which is sufficient to fulfil your customs related obligations with due regard to the characteristics of the type of your business activity? Please provide profit and loss statements and balance sheet for the last three sets. If a new business, state N/A Have insolvency proceedings been initiated in respect of your company in the last three years? Yes/No If Yes please provide details Please provide information about your financial standing over the last three years such as a letter from your audited financial statements, a copy of your finalised accounts (if your accounts have not been audited) or bank or financial institution statements that demonstrate financial viability If you are a newly established business provide all records and information in relation to your financial status e.g. latest cash flow, balance sheet and profit and loss forecasts approved by the directors/partners/sole proprietor. II/11.
12 3. Premises Security and Access Controls Please describe the measures that are in place to resist unauthorised entry to premises. Provide comment in the following areas: 3.1 Perimeter Fencing Describe the perimeter fencing and/or appropriate peripheral barriers in place to enclose the areas around cargo handling and storage facilities Briefly describe the procedures in place: - for the segregation of high value and hazardous cargo. - to ensure that all fencing is regularly inspected for integrity, damage and repaired. - for perimeters identifiable (signage) as controlled areas for authorized personnel only Gates and Gate Houses Briefly describe the procedures in place: - to control the movement of all vehicles and/or personnel entering or exiting the gates. - to protect premises against unauthorised access by private vehicles. - that specify when and how searches of vehicles or personnel entering or exiting controlled areas of the premises are to be performed Are gates through which vehicles and/or personnel enter or exit manned, monitored or otherwise controlled? 3.3 Parking Briefly describe the procedures in place to prohibit the parking of employees and visitors vehicles in close proximity to cargo handling and storage areas. 3.4 Building Structure Is the building constructed of materials that resist unlawful entry and protect against external intrusion? Briefly describe the procedures in place to ensure that the integrity of the structures is maintained by periodic inspection and repair. II/12.
13 3.5 Locking Devices and Key Controls Briefly describe the procedures in place: - to ensure that all external and internal windows, doors, fences and gates are secured with locking devices or alternative access monitoring or other control measures. 4 - for issuance and access to locks and keys. - for conducting periodic inventory of locks and keys Lighting Describe briefly the procedures in place to ensure adequate lighting inside and outside company facilities including the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas Describe the processes in place to maintain equipment and retention of recordings. 3.7 Alarm Systems and Video Surveillance Cameras Are alarm systems and video surveillance cameras utilised to prevent potential intruders from attempting to gain entry, detect possible intrusion, expand the area of security surveillance and assist in post-incident investigations? 3.8. Security Personnel and Organisation If personnel is in charge of the security of the company please describe briefly the procedures in place? If an organisation/unit is in charge of the security of the company please describe briefly the procedures in place. 3.9 Access Controls for Employees Describe briefly company employee access controls to the premises/site at all times, including; - Is an employee identification system in place that provides positive identification for access control purposes and while working in restricted areas? - Are employees only given access to those areas needed for the performance of their duties? 4 Inner and outer doors and windows within the site or building should be locked or secured (e.g., by locks, swipe cards, keypads, etc.). 5 Personnel or an organisation/unit must be in charge of the security of the company. Company may engage the services of a security organisation to further enhance the security of their facilities. The identity of that person or company must be communicated and maintained current with the Customs authority. II/13.
14 3.10 Access Controls for Visitors and Vendors / Contractors Describe briefly the positive identification procedures and access controls to the premises/site at all times for visitors, vendors and contractors, including; - to register and control all visitors, vendors, contractors, etc. - to present photo identification or proper vendor ID for positive identification and access control purposes. - are all visitors required to visibly display identification passes Challenging and Removing Unauthorised Persons Describe briefly the procedures in place for employees to report and challenge any unauthorised or unidentified persons? II/14.
15 4. Personnel Security Describe briefly the organisations' procedures that maintain assurance over the integrity of personnel in positions directly involved with order processing, packing, storing or shipping cargo or completing company documentation. Provide comment in the following areas: 4.1 Pre-Employment Verification and Background Checks Describe briefly the procedures in place: - to ensure the application information for both permanent and temporary personnel, such as employment history and references, verified prior to employment. - to ensure background checks conducted on prospective permanent and temporary personnel as appropriate and to the extent allowed for by law. 4.2 Periodic Background Checks / Reinvestigations for Current Personnel Describe briefly the procedures in place: - for the provision of periodic checks to the extent allowed by law performed on current permanent employees - as to whether the periodic checks are based upon the position and responsibilities of the personnel in the company. 4.3 Resignation and Termination of Personnel Describe briefly the procedures in place: - to remove identification cards, as well as premises and information systems access for terminated and resigned permanent and temporary personnel. - to control the employee's ability to compromise security standards, if company policy, national law, employment contract or union agreement allows for a period of continued employment between termination/resignation notice and last work day Temporary personnel security standards Describe briefly the procedures in place to ensure temporary employees are checked regularly according to security standards. Please specify - how and by whom the temporary employees are checked. - the areas where these employees are used. - the security instructions for these employees. II/15.
16 4.5 Education, Training and Awareness Describe briefly the procedures in place to educate your personnel with regard to the risks associated with movements of goods in the international trade supply chain Describe briefly what educational material, expert guidance and appropriate training on the identification of potentially suspect cargo is provided to all relevant personnel involved in the supply chain Describe briefly what procedures are in place for employees to identify and report suspicious incidents Describe briefly any specific training conducted to assist employees in maintaining cargo integrity, recognizing potential internal threats to security and protecting access controls. II/16.
17 5. Business Partner Security The following section is dealing with the security of business partners. Please provide comments in the following areas: Please provide a list of regular business partners including the modes of transportation and nodes. 5.1 Selection of Business Partners Describe briefly the procedures in place for the selection of and working with business partners taking into account elements that can identify and rectify security weaknesses? 5.2 Security Requirements for Business Partners As far as possible and in accordance with the business model, describe briefly the procedures in place for business partners to demonstrate they are meeting the company s supply chain security requirements (e.g. through written or electronic confirmation; through contractual obligations; through a letter from a senior business partner officer attesting to their compliance; through a written statement demonstrating their compliance with Customs supply chain security programme(s); or by providing a completed supply chain security profile)? 5.3 Security Certification For business partners who have obtained certification in a supply chain security programme administered by the Customs administration of another country describe briefly the procedures in place to maintain documentary proof of the business partners certification? 5.4 Review of Business Partners Compliance to Security Requirements Describe briefly the procedures in place to review business partners compliance to security requirements? 5.5 Storage Facilities If you use storage facilities and they are not owned by you please indicate who you rent/lease the storage facilities from. II/17.
18 6. Cargo Security The following section aims to verify your procedures in place regarding cargo security. Provide comments in the following areas: Describe briefly the procedures in place to protect against the introduction of unauthorised material and persons? 6.1 Documentation Processing and Verification If you are an importer or exporter, please describe briefly the procedures in place - to ensure that information in all documentation used in the movement and clearance of cargo, both electronic and manual, including those documents prepared by third parties such as Customs house brokers, are legible, complete and protected against the exchange, loss or intentional introduction of erroneous information and available for examination. - directing staff what should be done if they encounter a suspicious document If you are carrier, please describe briefly the documented procedures in place to ensure that information in the carriers manifest accurately reflects the information provided to the carrier by the shipper or its agent and is filed with Customs in a timely manner 6.2 Receipt and Release of Cargo Describe briefly the procedures in place - to ensure that arriving and departing cargo is reconciled against relevant documents, for example, cargo manifest, packing list, bill of lading, purchase order and delivery order. - to compare, where feasible, the cargo with delivery documents when receiving and releasing cargo and to inform the appointed security officer if a discrepancy is detected. - to ensure that persons / drivers delivering or receiving cargo are positively identified before cargo is received or released and to provide supervision to cargo handling processes. II/18.
19 6.3 Procedural Documentation Describe briefly the documented procedures in place - for critical process handover points (e.g., document preparation processes, issue of seals, breaking of seals, physical count of cargo, conveyance inspection, cargo delivery, cargo receipt). 6 - pertaining to custody and responsibility over cargo when a party takes receipt of the cargo or when a service is provided. - to monitor on a continuous basis the movement of the cargo. - for controlling the movement of cargo within the port or airport prior to exit or the movement prior to entry, where applicable. for monitoring the loading of cargo for export. 6.4 Inspection of cargo conveyance Describe briefly the procedures in place - to verify the physical integrity of the cargo conveyance prior to stuffing, including the reliability of the locking mechanisms of the doors. - for inspecting the structure of the transport conveyance including the reliability of the access controls. When appropriate to the type of conveyance is a seven-point inspection process carried out for all dedicated transport conveyances prior to stuffing, including: a) Front wall; b) Left side; c) Right side; d) Floor; e) Ceiling; f) Inside/outside doors; and g) Outside/undercarriage? 6.5 Container Seals Do you use ISO compliant high security seals? Describe briefly the procedures in place on how seals are to be controlled 7, affixed and checked to ensure only designated authorised person(s) distribute seals. 6 When goods arrive in a sealed container, a physical count of cargo is not required unless the sealed container is to be devanned. 7 Controlled might mean received, securely stored, assessed, used and accounted for. II/19.
20 6.5.3 Do you require hauliers to have documented procedures for regular vehicle inspections after stops in journey; that drivers ensure the integrity of the load whilst other consignments are added or removed; and that drivers have been trained in prompt reporting of incidents? Describe briefly the procedures in place to periodically review compliance with these requirements. 6.6 Storage of Conveyances, Containers and Cargo Describe briefly the procedures in place to prevent unauthorised access and/or tampering of conveyances, containers and cargo in your custody stored in a secure area. 7. Conveyance Security The following section aims to get information regarding the conveyance security. Provide comments in the following areas: Describe briefly the procedures in place to protect, to the extent and scope of your authority and responsibility, conveyances (e.g. trucks, prime movers, trailers) against the introduction of unauthorised personnel and material. 7.1 Conveyance Inspection Describe briefly the procedures in place to consider potential places of concealment on conveyances and ensure that these are regularly inspected. 7.2 Drivers Guide Describe briefly the procedures in place to train drivers on subjects such as: (a) (b) (c) (d) (e) (f) Inspection of conveyance; Confidentiality of load, route and destination; Policy on keys, parking area, refuelling and unscheduled stops; Reporting for accident or emergency; Reporting of any irregularity in loading, locking and sealing; and Testing of security alarms and tracking devices, if any. II/20.
21 8. Information Security The following section aims to verify the procedures in place regarding information security. Provide comment in the following areas 8.0. Information Technology (IT) Describe briefly the procedures in place - to maintain confidentiality and integrity of data and information systems used in the supply chain including protection against misuse and unauthorised alteration. - to ensure proper transfer, storage and final disposal of data and information Documentation Security Describe briefly what actions have been taken in order to protect (e.g. constricted access rights, creation of electronic backup) information/documents from unauthorised access, abuse, intended destruction and loss? Have there been any cases of unauthorised access to documents in the last year, and if so what measures have been taken to prevent this from happening again? Please briefly answer the following questions: - a) Which categories of employees have access to detailed data about the flow of materials and goods? - b) Which categories of employees are authorised to change such data? Are changes comprehensively documented? 8.2. Information Security Procedures Describe briefly how access rights for the computer systems are issued and who is responsible for the running and protection of the computer system? Describe briefly the information security procedures and/or security related controls in place to protect information systems from unauthorised access? II/21.
22 8.3. Accountability What computer system (hardware/software) do you use for your business in general, and for Customs matters in particular? Provide information on the following: - separation of functions between development, testing and operation; - separation of functions between users; - access controls (which ones/to whom); - traceability between business system and declaration system At what location are your Customs related computer activities undertaken? Have Customs related computer applications been outsourced? If yes, to which company were the applications outsourced and how do you manage access controls for the outsourced applications? Describe briefly the procedures/ systems in place to identify the detected abuse of IT including improper access, tampering or the unauthorized altering of business data? 8.4. Data Back-ups and Recovery Plans Please describe where your main server is located and give details of how it is secured Describe briefly the actions you have taken in order to protect your computer system from unauthorised intrusion (Firewall, antivirus programme, password protection, etc...)? Describe briefly the procedures and back-up capabilities in place to protect against the loss of information? Does the company have a contingency plan for system disruption/failure? II/22.
23 9. Incident Management In the following section you are invited to inform about your procedures in the area of incident management. Provide comments in the following areas: Describe briefly the procedures in place identifying such threats as terrorism, contraband/human Smuggling, Organised Crime or other Conditions which may increase the probability of a security breach Describe briefly the crisis management, business continuity and security recovery plans in place Describe briefly the training provided for employees in crisis management and any drill conducted for the contingency plan Describe briefly the procedures in place to report and respond an incident or risk situation and identify root causes so that actions can be taken to protect against recurrences. 9.1 Report, Investigate and Analyse Describe briefly the procedures in place to ensure that incidents are reported to management, investigated and analysed with the objectives of determining the cause of the incident and implementing the necessary revisions and improvements to protect against the recurrence of such an incident. 10. External Services This section aims to get information regarding your security measure in relation to external services. Provide comments in the following areas Describe briefly the external services under contract, such as security guards, cleaning companies, suppliers, maintenance companies, etc., which are based at your premises? Are there written agreements with the external service providers containing security requirements (i.e. restricted access controls etc....)? Describe briefly how compliance with the procedures included in these agreements is checked? II/23.
24 11. Measurement, Analyses and Improvement Describe briefly the procedures in place - to conduct assessments of the security risks in business operations and take appropriate measures to mitigate those risks. - to establish and conduct regular self-assessments of your security management system. - for responsible parties identified to conduct regular self-assessments, review and implement recommendations for possible enhancements to ensure continued adequacy of the security management system. II/24.
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