The objective of this operating procedure is to define roles, responsabilities and lead times for SBS, CCT, CTC to provide the service of partners manual screening to the GBU Composite Materials.
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 management is manually handled.
The group policy is nevertheless turned towards best level of compliance and the solution to ensure that the GBU shipments are authorized and to manually screen the recipient 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 all exports, re-exports, domestic transactions and business partners against the various Governments published restricted party, sanctioned countries and products licensing requirements.
Composite Materials GBU Internal Compliance Program also states a defined 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 1700 shipments per year.
2. Screening frequency
The agreed screening frequency between the site Med-Lab and SBS is at the order creation only.
3. Operation sequence
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.
The GBU sends the new transaction details at SBS CTC generic email address: solvaycustoms@solvay.com
Mandatory fields for an efficient screening:
- full name of the recipient of the sample;
- the country of destination;
- the End Use Statement (if required by the End Use Policy).
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 opinion on the transaction.
Analysis include the partner screening report from Thomson Reuters, verification and approval/denial of the End Use Statement.
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 transaction details for manual screening along with a copy of the End Use Statement if needed |
| CTC | Customs specialists | daily check of the new transactions 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 deliveries 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 transaction status (approved or denied) |
| CTC | Customs specialists | archive the screening analysis with resolution case on World Check One |
| CTC | Process Expert | supports CTC specialists and audit the process |