ISM Chemical Group Winter Conference New Orleans

Thomas A. Cook

American River International

February 2009

1ARI 2009

Why even engage in this subject?

Government Mandates: Due Diligence, Reasonable Care and Supervision & Control Management Oversight

SOX

2ARI 2009

Trade Compliance in Global Supply Chains: Structuring a Successful Program

Agenda

Eight Step Process

Key Issues related to the Chemical Industry

ARI 2009 3

Eight Step Process

Senior Management Point Person and Committee Information Flow & Benchmarking Point Person … Training Action Plan SOP’s Technology Implementation and Connectivity … Training &

Education

4ARI 2009

Senior Management

No shot without their support Costs and Infrastructure Penalties, Consequences and Benefits SOX

5ARI 2009

Point Person and Committee

Logistics, Supply Chain: Qualified Personnel

Supported by a Committee …

crossing all lines in the

Organization

6ARI 2009

Regulatory Issues

Where are you at?

Facilities Review

Use of outside consultant or

expertise to provide necessary

support

7ARI 2009

Information Flow & Benchmarking

Point Person: Training

Wealth of Information Train the Trainer Licensed and Certified www.compliancemaven.com

8ARI 2009

Action Plan

Responsiveness to the Benchmarking

Developing Actions

Prioritizing

Who will do what by when

Management Tool for Accountability/Responsibility

9ARI 2009

Standard Operating Procedures (SOP’s)

Organizes and standardizes what the company needs to do

Meets government guidelines Mitigates government review and scrutiny Mitigates dependency on key personnel SOX, ISO and other internal business process

10ARI 2009

Technology

Reduces opportunity for human error Makes for more efficient systems in global supply chain

logistics and operations Necessary to reduce costs and personnel count Allows global interface of all “connections and parties” in

import and export activities

11ARI 2009

Implementation and Connectivity: Training and Education

Execution of the Action Plan Implementation of the SOP’s and new business

process’s Training and Education of all direct and indirect

personnel: purchasing, sales, operations, senior and middle management, finance, legal, etc

12ARI 2009

Current Issues

Since 9/11 … over 109 Regulatory Changes in Global Supply Chains

Chemical Companies - Post 9/11 Commission - Bio-Terrorism Act - ISF (10 + 2) - FDA Prior Notice - International Ship and Port (ISP)

13ARI 2009

Current “Hands-On” Issues AES

USPPI Deemed Exports

FCPA Denied Parties

SOX Wood Packing

CSI 24 Hour Manifest

Focused Assessments: Documentation, HTSUS Classification, Origin, Material Data Safety, and Record Keeping

C-TPAT INCO Terms

ISF TSA Screening

14ARI 2009

Proactive Trade Compliance is a Responsible Path

Risk Management Approach

Follow the Steps … over 370 companies, approximately 20% of Fortune 1000

Benefits: Supply Chain Stays Open, Reduce Threats, Fines and Penalties … More efficient run Global Supply Chain

15ARI 2009

Summary

Speaker Bio and Contact Information

16ARI 2009

Thomas A. Cook

Tom has been involved in Global Trade for over 30 years in the field of supply chain management, logistics and trade compliance.

He has authored over 9 books on International Business … the most recent Managing Global Supply Chains: Compliance, Security and Dealing with Terrorism.

Tom is Managing Director of American River International, a boutique and specialized logistics provider and consultant engaged in global trade management.

Tom can be reached at … 1-800-524-2493 or at tomcook@americanriverintl.com