The objective of this operating procedure is to define roles, responsabilities and lead times for SBS, CCT(Customer, Credit and Trade Service Line) CTC (Customs and Trade Control), to provide the service of partners manual screening to the GBU Composite Materials Med-Lab site.
The distribution site Med-Lab ERP SAGE is not linked to any trade control IT tool, no automatic screening of partners is done at order entry. Embargo situations are manually handled.
The group policy is nevertheless turned towards best level of compliance and the solution to ensure that the GBU shipments are authorized is to manually screen the recipients against restricted party lists and economic sanctions.
1. Context
Solvay currently exports U.S., European and other Foreign produced materials from numerous Solvay locations globally. To prevent the sale or purchase of good or services from or to a restricted party, it is Solvay’s policy to screen business partners (for exports, re-exports, domestic transactions) against the various Governments published restricted party, sanctioned countries and products licensing requirements.
Composite Materials GBU has internally defined a list of countries of concern for which an End Use Statement is a pre-condition of sale.
The site Med-Lab estimates the amount of 3000 shipments per year.
2. Screening frequency
The agreed screening frequency between Med-Lab and SBS is for new customers when an account is opened and for all other customers at least once every 12 months.
3. Operation sequence
The GBU sends the new account details at SBS CTC generic email address: trade.control@solvay.com
Mandatory fields for an efficient screening:
- full name of the recipient;
- the country of destination;
- the End Use Statement (if required).
The GBU will have to check in advance whether the destination country is listed as a "country of concern", see Annex 1.
Any shipment to a country of concern will require an End Use Statement.
CTC Customs specialists perform screening of the account in Thomson Reuters World Check One and verify the validity of the provided End Use Statement in case of accounts located in a "country of concern".
Within 24 hours after reception of the email containing all mandatory fields, SBS, CCT, CTC answers back to the requestor's email and provides the approved/denied result on the transaction.
Analysis include the partner screening report from Thomson Reuters, verification and approval/denial of the End Use Statement.
CTC Customs specialists perform batch screening of existing customer on World Check One at least every 12 months.
Any issues related to trade control has to be reported to the GBU Empowered Official.
CTC Process Expert audits the process at least every 12 months.
4. Roles and responsabilities
| | |
|---|
| GBU | Site | verifies the country of destination and request an End Use Statement when required |
| GBU | Site | sends emails to CTC with new account details for manual screening along with a copy of the End Use Statement if needed |
| CTC | Customs specialists | daily check of the new accounts to be analyzed |
| CTC | Customs specialists | analyze new partners in Thomson Reuters and follow internal procedure in case of perfect match |
| CTC | Customs specialists | analyze, approve/deny End Use Statements for accounts located in countries of concern |
| CTC | Process Expert | provides support for the license determination |
| CTC | Customs specialists | answer back to the GBU within 24 hours after email reception and provide account status (approved or denied) |
| CTC | Customs specialists | archive the screening analysis with resolution case on World Check One |
| CTC | Customs specialists | perform batch screening of existing customer on World Check One at least every 12 months |
| GBU | Empowered Official | manages non compliance issues related to the site |
| CTC | Process Expert | supports CTC specialists and audits the process |