VOLKSWAGEN GROUP OF AMERICA

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7. 7.1 Transport by Rail Rail Loading Load according to AAR Manual of Standards and Recommended Practices Multi-Level Manual Section II: Recommended Practices for Motor Vehicle Loading/ Unloading Operations & Securement. RP-811-04 Loading of Vehicles. Rail loading takes place at various ramp destinations as prescribed by VWGoA Vehicle Logistics. Includes scanning of each vehicle loaded. Bolt or Cable seals used are C-TPAT and ISO17712 compliant. Seal serial number are recorded and/or transmitted to railroad. Green seal signifies direction of headlights. Prepare bills of lading and fax or transmit to destination, railroad(s) and VWGoA. Loading facility (processer) communicates pull and spot order to interchange railroad as directed and in format and timing as defined by railroad. Port of Houston only: Prepare switch order on rail connect web site and fax to PTRA railroad(s) directing the pull and spot activity for next day. Vehicle handling regulations apply to rail loaded units with the exception of the hand brake. (Put in park or 1 st gear, emergency hand brake applied while on rail car.) 7.2 CAUTION VW Golf/GTI should not go in the A6 position. New Beetle/NBC should not go in the A1 or A6 position. All Volkswagen and Audi Wagon/Avant should not be loaded on A deck. Rail Unloading Unload according to AAR Manual of Standards and Recommended Practices Multi-Level Manual Section II: Recommended Practices for Motor Vehicle Loading/ Unloading Operations & Securement. RP-816-04 Unloading of Vehicles. Note any unusual conditions found prior to unloading. (I.e. ridership, tie downs, excessive damage). Rail seal numbers are recorded, stored and transmitted to VWGoA transportation claims group, per request. Rail cars are opened and bridge plates installed. Drive automobiles to first point of rest. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 86

7.3 Rail Loading, On Train, and Unloading Inspection Requirements Rail providers play a critical role in the VWGoA supply chain and subsequent vehicle damage prevention efforts. Therefore rail inspections prior to loading, on the train, and after unloading are required from providers. Clean and damaged vehicle inspection data is to be sent to VWGoA s 3 rd party transportation claims service provider for evaluation and storage in the data warehouse. Inspection data is sent in an electronic format. Refer to Chapter 4.12 EDI and EPOD Data Requirements. Where rail loading/ unloading occurs on a VWGoA facility (plant and ports) it is the expectation the VWGoA contracted 3 rd party inspection company will used and the subsequent rail road or processor will share in the half of the inspection cost. 7.4 General Instructions for Service Providers and Parking Regulations Refer to Chapter 2: Vehicle Handling Regulations for complete policy. A staff member, responsible for operations is available at all times; name, telephone (mobile), fax number. The service provider is obligated to instruct new staff members before their first assignment on rules and regulations, handling guidelines contained in this document, the system used to report damage to the vehicle, damage discovered on the vehicle and instructions on driving and work clothes. All instructions are documented for understanding, i.e., counter-signature. Self-audits are carried out to ensure that all instructions are being adhered to. Any failure of compliance must be countered with repeated instruction. In the event of failure of technical equipment or systems, the service provider must implement an agreed upon emergency procedure. This procedure is approved by VWGoA on an individual basis. New vehicles are handled with care. The tires will not be allowed to spin; the engines are not over-revved and special care taken with curbstones. Great care is exercised when opening and closing doors. In the case of automatic transmissions, vehicle is at a complete stop prior to engaging gears. When moving vehicles in the winter, the windows of parked vehicles are cleared of ice and snow using suitable plastic ice scrapers (without steel or toothed edges) in such a manner that visibility is good. Scrapers must not damage any window surface. De-icing spray is used to remove thick layers of ice. Care is taken not to spin wheels, if vehicles are driven on ice. WARNING: Windshield wipers are not used on iced windows; a soft brush is used to remove snow. To avoid hairline scratches and small dents, the driver s must avoid leaning against the vehicles. Handlers also wear clean clothes and sufficient protection for belt buckles, rings, watches, etc. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 87

Regardless of the time of year, drivers must wear clean work clothes and no open toe shoes. Vehicles are checked for damage and missing parts before they are moved. Damaged or missing parts are reported. If protective interior covers in the drivers area have become detached, they are secured in the correct position. Protective layer on fabric roof of convertibles is not removed from vehicles. After the vehicle is moved, the ignition key is always removed and placed in the pocket of the left front (driver s) door; or key can remain on a tether around the steering column if it came from the factory on the tether. Drive the vehicle slowly and cautiously into the parking space, keeping sufficient distance from the other vehicles. Do not park vehicles under trees, pylons, etc. When parking, the transmission shift lever in automatic vehicles is placed in the park position and in first gear for those vehicles equipped with manual transmissions. The emergency brake is not utilized. Exception 1: Special exceptions will apply for vehicles parked on an incline. Fold up the sun visor in vehicles and place in horizontal position for Cabrio. Operator may mark on the Bodyguard in non-indelible marker to enhance processing through the facility (rush/sold, destination, location, battery, etc.) Only qualified personnel who have a valid driving license are allowed to handle vehicles. Visual inspections of tire pressure and inflate as necessary. The vehicle is not used to transport passengers or materials. Smoking, eating and drinking is prohibited in the vehicles at all times. Items, which protect the vehicle during transport, are not removed without authorization. The radio and other electrical equipment, that is not essential to moving the vehicle is not switched on. 15 M.P.H. speed limits are observed at all times. The engines are not over-revved, and not to exceed 3,000 rpm. Windows, doors and sliding roofs are closed. Gaps between vehicles have the following minimums: bumper to bumper: 12 inches - side to side: 24 inches. Observe instructions on spacing and alignment. This refers to normal storage operations. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 88

7.5 Full Body Cover (FBC) Some Volkswagen and Audi products have full body covers, these vehicles are handled as follows: The left front door flaps is closed after each operation. Ensure car covers are fitted properly; covering entire vehicle, clasps in place, and no visible disturbances. Ensure windshield tape is down and in place. If car cover is damaged, See section 5.5.3 and 5.5.6 for removal instructions. FBC Removal Process is a two person job. Failure to use two persons may result in damage to the vehicle. 7.6 Process for Damaged Vehicles at Railheads 7.6.1 Minor Damages Severity 1 and 2 damages are noted on the manifest/load sheet without verification. Vehicles are shipped to the dealer. Copy of trucking company turnover with noted damage is provided to the yard operator. 7.6.2 Major Damages/Theft Severity 3 or above is verified in bay by approved inspection company. Any unit with severity 3 damages found after hours or weekends are not shipped until verification is performed the next business day. Note damage on an inspection form or trucking company turnover document and notify yard management. Yard management will report the damages via the Vehi-Trac system Photos of damage required. For major damaged vehicles not being shipped to the dealer, disposition instructions are provided to yard management and trucking company by Fenkell Automotive /VWGoA Claims. Upon approval, ship the vehicle to the dealer with damages noted on trucking company turnover document. Any theft of vehicle components or vehicles is reported immediately to Fenkell Automotive Claims department at (800) 325-3517 or email claims@fenkell.com. Local law enforcement notification guidelines are still adhered to in addition to this notification. 7.6.3 Broken Glass/Flat/Damaged Tires Yard operator contacts Fenkell Automotive via their Vehi-Trac system. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 89

7.6.4 No Start Units Yard operator contacts Fenkell Automotive via their Vehi-Trac system. Under no circumstances is any vehicle jump started, Fenkell is contacted first and will advise the appropriate required action. 7.6.5 Missing Keys Thoroughly check interior and cargo area for keys. If no keys are found, immediately notify yard management. Yard management will report the missing keys via the Vehi-Trac System. A key is special ordered from a VWGoA Parts Depot and expedited to the rail yard. Ensure that the missing key exception is recorded by the survey company assigned by the rail road. 7.6.6 Keys Locked Inside Vehicles Immediately notify yard management. Yard management will report the issue via the Vehi-Trac System. In most cases, a locksmith is required to come to the rail yard to unlock the vehicle in question. At no time is locked unit towed or pulled off the railcar by unloading contractor. 7.7 Rail Bolt Seals 7.7.1 General Requirements ISO 17712 Compliant C-TPAT Compliant AAR RP-812-94 Recommended Practice. Section 1.2 Equipment. Two high security bolt seals are applied per railcar. Green colored bolt seals are applied to rail car end that forward facing (head light). Non-green colored bolt seals are applied to the rear facing (tail light end). Rail seal number format is 7-digit alphanumeric. Rail seal number (barcode) are recorded and submitted per EDI 404 rail specification. Data string is submitted on the M7 segment of EDI 404: M7*VW12179*8504101 Automax railcars require two seals per side. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 90

7.7.2 C-TPAT Requirements Seal Requirements for Manufacturers C-TPAT importers, carriers and manufacturers who wish to qualify for expedited processing and other related benefits under the U.S./Mexico FAST initiative are required to adhere to the following procedures, protocols and standards with regards to the use of high security seals. Carrier/Drayage Upon receipt of container/trailer, ensure that all seal information is true and correct as reflected on manifests, bills of lading or other documentation related to the movement of cargo. Establish verifiable security systems for cargo storage and handling facilities, container yards and conveyances operated by the carrier to prevent the improper manipulation and transportation of cargo and /or containers/trailers. Establish procedures for reporting any discrepancies or anomalies related to seal integrity. Seal Integrity Responsibilities Seals are of the high security type as per ISO guidelines (ISO/PSA 17712, Freight Containers-Mechanical Seals), adopted May 2003. All seals that are removed from a cargo container/trailer for legitimate intermediate examinations (customs inspection, conveyance damage surveys, law enforcement activity, etc.) are placed in the container just inside the doors, in plain view, before a new seal is affixed to the container. Establish a system for annotating and reporting any changes due to legitimate intermediate examination purposes as described above. Seals are affixed by a responsible, designated representative of the carrier. NOTE: A responsible, designated representative is defined as an employee who maintains a position of trust (i.e. security personnel) within the business and has received appropriate instruction and training in the proper use and application of high security seals. Access to seals is strictly controlled by the responsible party and issued at random in order to avoid seals being affixed in sequential order. Seals are stored in a secure location (locked cabinet, safe, etc.) until such a time as their use is warranted. Access to such secure locations is restricted to those parties responsible for the inventory and affixing of seals. A log is maintained in order to account for all seals under the control of the carrier. NOTE: A standardized log is currently under development. In the interim, any entity responsible for the sealing of cargo should use and maintain an accounting system of their own design. Establish a system to ensure verification of seal numbers and types and that all pertinent seal information is reflected on all manifests, bills of lading or other documentation (including electronic data transmissions) related to the movement of cargo. IMPORTER: Ensure that all related parties are aware of security guidelines and procedures as they relate to the use of seals and seal integrity. Establish a system to ensure all related parties/business partners adhere to established security guidelines and procedures relating to the use of seals and seal integrity. Establish procedures for reporting any seal discrepancies or anomalies to CBP. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 91

7.7.3 Application 1 Detach rail bolt head (bar-coded side) from main body. Insert main body into the rail bolt head firmly. You will hear a click when both pieces are connected. Verify connection by pulling main body away from rail bolt head. 7.7.4 Removal 24 bolt cutter required for removal. Volkswagen Group of America Vehicle Logistics Port Policies & Procedures Ver. 6.2 September 1, 2014 Page 92