Customs -Trade Partnership Against Terrorism (C-TPAT) Vendor Participation Overview

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1 Customs -Trade Partnership Against Terrorism (C-TPAT) Vendor Participation Overview On September 11, 2001, combating the threat of terrorism became U.S. Customs number one priority. Due to the attacks on that day, U.S. Customs came to understand the United States is not immune to terrorist attacks carried out by global terrorists. One of the best means to prevent further terrorist attacks is to secure all supply chains from the point of origin through the delivery to the final U.S. destination. The mechanism implemented to protect against such threats is the Customs-Trade Partnership Against Terrorism (C-TPAT). U.S. Customs priority under C-TPAT is to prevent terrorists and terrorist weapons from entering the United States. That important mission means improving security, not only at physical borders and ports of entry, but globally in collaboration with the international trade community. Participants in the program include importers, brokers, carriers, and certain foreign manufacturers. U.S. Customs mandates all active participants in C-TPAT such as The Sportsman s Guide, and their foreign partners to adhere to the requirements of the C-TPAT program. The program recognizes that in order to improve, protect, and strengthen the cargo supply chain, the involvement of all members of the Global Community is required. The Sportsman s Guide is C-TPAT certified and is an active member of the C-TPAT community. As a C-TPAT participant, TSG also requires that its business partners not only understand the C-TPAT requirements, but implement processes and controls necessary to be C-TPAT compliant. To ensure the necessary levels of compliance, this letter outlines the expectations of our valued partners to secure our supply chain. U.S. Customs requires our foreign business partners: demonstrate they are meeting C-TPAT security criteria via written or electronic confirmation (e.g., contractual obligations: via 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 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 by The Sportsman s Guide or its designated third party auditor. At the time of a new vendor implementation, the vendor will be required to complete a TSG C-TPAT Questionnaire that will be reviewed by TSG s C-TPAT compliance team for an overall assessment prior to purchase orders being issued. Existing vendors will be audited for C-TPAT as a part of subsequent Social Compliance and Security audits. All additional costs resulting from third party audits will be incurred directly by the vendor. TSG has used its leverage to negotiate favorable rates with a third party service provider responsible for completing the audits. At the completion of the audit, your factory will be scored based upon your level of compliance. In certain instances, factories may be required to facilitate stand alone C- TPAT audits where TSG deems necessary.

2 If a vendor is found to not meet the minimum supply chain security requirements on the C-TPAT audit by the third party auditor, or if TSG rejects a TSG C-TPAT Questionnaire, the vendor is considered to have failed the audit. Vendors that have failed an audit are required to submit a written Corrective Action Plan (CAP) to TSG within a period of no more than 30 days from date of the notification. It will be up to TSG to determine whether a 90 day follow up audit will be necessary. TSG will use its discretion in deciding to terminate Purchase Orders or engage in future business with the vendors that are non-compliant. Again, all third party audits will be completed at the expense of the vendors. Specific areas covered in the C-TPAT third party audits include but are not limited to the following: Container and Trailer Security Container and trailer integrity must be maintained to protect against unauthorized products and/or persons. At the point of loading, vendors must have procedures in place to properly seal and maintain the integrity of the shipping containers and trailers. Container Inspection Procedures must be in place to verify physical integrity of the container structure prior to loading, including the reliability of the locking door mechanisms. A seven point inspection process is required for all factory loaded containers. Seven point container inspection: (see enclosed link for more information) Front wall Left side Right side Floor Ceiling/roof Inside/outside doors Outside/undercarriage Trailer Inspection Procedures must be in place to verify physical integrity of the trailer structure prior to loading, including the reliability of the locking door mechanisms. A ten point inspection process is required for all trailers. Ten point trailer inspection: Fifth wheel area - check natural compartment (i.e. lockbox, storage racks, etc.)/skid plate Exterior front/sides Rear bumper/doors Front wall Left side Right side Floor Ceiling/roof Inside/outside doors Outside/undercarriage

3 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 preventing and reporting unauthorized entry in containers/trailers or container/trailer storage areas. Container and Trailer Seals The foreign manufacturer must affix a high security seal to all loaded inbound U.S. containers and trailers. All seals must meet or exceed the current PAS ISO standard for high security seals. seal_requirements.xml Written procedures must stipulate how seals are to be controlled and affixed to loaded containers and trailers, including procedures for recognizing and reporting compromised seals and/or containers/trailers to U.S. Customs or the appropriate foreign authority. Only designated employees should distribute seals for integrity purposes. Physical Security Fencing/Gates/and Gate Houses: Cargo packed product stored outside the exterior yard area should be enclosed with fencing and/or is secured otherwise to prevent unlawful access. Parking: Company must have a defined parking area for private vehicles which are separate from the shipping, load dock, and cargo areas. Building Structure: The main manufacturing and final storage buildings are of a solid structure to prevent unlawful access. Locking Devices and Key Controls: Security systems shall cover all critical areas (all external doors, loading docks, production areas, etc.). Lighting: Major access and security points shall be lit (lights in all critical areas must be functioning). Alarms Systems and Video Surveillance Cameras: The facility is protected by security systems and/or security personnel. Security systems are tested periodically and monitored. 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 Identification System must be in place for positive identification and access control purposes. Employees should only be given access to those source 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.

4 Visitors Visitors must present photo identification for documentation purposes upon arrival. All visitors should be escorted and should visibly display temporary identification. Deliveries 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 distributed. Challenging and Removing Unauthorized Persons Identify, challenge, and address unauthorized/unidentified persons. Pre-Employment Verification Employment history and references must be verified prior to employment. Background Checks/Investigations Employees (Personnel Security) Background checks and investigations should be conducted on new employees. Periodic checks and reinvestigations should be performed on current employees. Personnel Termination Procedures Companies must have procedures in place to remove identification, facility access, and systems access for terminated employees. Procedural Security Documented processes shall be in place to verify: a. Information used in the clearing of merchandise/cargo, legibility, completeness, and accuracy; b. That documents are protected against the exchange loss or introduction of incorrect information; and c. That computer access and information are safeguarded. Manifesting procedures shall be in place to verify: Information received from business partners is reported accurately and timely. Shipping and receiving procedures shall be in place to verify: Departing cargo is reconciled against cargo manifest, accurately described, and weights, labels, marks, and piece count are indicated and verified against purchase or delivery orders. Drivers delivering or receiving cargo should be identified before cargo is received or released. Cargo must be tracked and traced. Cargo Discrepancies Must be resolved and/or investigated appropriately so that all shortages, overages and any discrepancies are reported to Customs and/or appropriate law enforcement agency.

5 Information Technology Security Written computer security policies/procedures are established. Individual accounts and passwords are created for users to access the system. Passwords are changed periodically (at least every 90 days). Access to computer systems is monitored and reviewed periodically. Security Training and Threat Awareness Security awareness programs should be in place in the following areas: threat awareness, security procedures, cargo integrity, internal conspiracies, protecting access controls, container security and facility security. Supply Chain Security Best Practices To assist our supply chain partners to meet or exceed the C-TPAT guidelines, please note the following examples of supply chain security best practices exercised by C-TPAT member companies. (See enclosed links for more information) Securing Empty Containers: Driver conducts and documents a 7-point inspection of the container/trailer using a checklist prior to leaving container/trailer facility. Driver uses mirror to inspect the undercarriage container/trailer. Inspection list signed by the driver after seal at the container facility is affixed by the facility security and verified and documented by both parties. Securing Full Containers: Digital picture taken of the back of the loaded container before doors are closed and sealed. Pictures transmitted to port terminal operator and importer in the United States. Inspecting and Weighing Containers: Weigh empty containers/trailers before and after loading. Shipping Manager, Guard, or the Driver should be present for loading and sign off on checklists after verifying inspections are completed. If the container arrives at the factory and will not be stuffed immediately padlocks and plastic seals are placed on the doors until container is ready for load. Container/Trailer Storage: Inventory management system is used to track and monitor empty containers staged in factory yard. Physical Security: Manufacturer maintains an alarm system with laser sensors in remote areas of the facility. These sensors help secure those areas of the facility that are inaccessible to security patrols.

6 411 Farwell Avenue, South Saint Paul, MN Ph:(651) Fx:(651) Shipping doors are assembled in a way which requires a security guard outside and a shipping clerk inside the facility to open it. Security guards view towers installed along the perimeter of the facility. Towers are manned at all times to allow the security staff to monitor activities inside and outside the property. Visitors: Reception personnel issue a numbered visitors badge to non-employees and service vendors. Sign-in sheet are maintained by reception personnel. The company establishes a visitor s database. A valid form of government issued identification is presented to the receptionist. The receptionist verifies visitor s identity and appointment. The visitor s address and identity information are entered into the database for future identification purposes. Visitors go through a metal detector and personal bags are x-rayed and searched. Access Controls: All employees regardless of their position within the company are required to pass through a metal detector when entering and departing the building. If an employee needs to gain access to a room requiring a key, the employee must swipe his or her Company ID card to gain access to a secure lock box containing the designated key to the room. Company s reception areas have a hidden panic button that can be used to alert company and community law enforcement personnel to a security threat. As a participant of the C-TPAT program, The Sportsman s Guide embraces the necessity of supply chain security within all levels of its organization. TSG s expectation is that all of its business partners will work to improve, protect, and strengthen existing cargo supply chains. It is essential that TSG and their partners work together to ensure total supply chain security. We recognize this may be a challenging endeavor, but consider the impact if just one of your containers has a security breech. The Sportsman s Guide looks forward to working with its business partners to improve Global Security and our existing supply chains. Reference Resource Websites (Links) Security Criteria for Foreign Manufacturers C-TPAT Cargo Security icplan.pdf Supply Chain Security Best Practices best_practices.pdf C-TPAT Customs Border Protection 7 Point Inspection Video https://ctpat.cbp.dhs.gov/images/videos/container%20inspection.wmv

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