PREFACE
Federal-Mogul Corporation’s (“F-M") Customs, Import VAT and Export Policy (“Policy”) sets forth F-M's global standard policies for compliance with applicable Customs rules and regulations. It is our policy to comply with all requirements of applicable import laws, exercise “Reasonable Care” with respect to our import transactions, and to avoid acts that might be considered illegal, unethical, or dishonest. Non-compliance with Customs laws and regulations may expose F-M to fines, penalties, and liquidated damages.
The policies stated are supported at the highest levels of management, and we look to department heads and each employee to fully comply with these policies. A key focal point of the Policy is the interaction and relationship between F-M management and employees. This interaction plays a vital role in achieving F-M’s customs compliance goals. The Policy contains the risk management steps of collecting data, prescribing action, and tracking and monitoring of all import-related transactions. All F-M employees must follow the policies detailed and F-M’s Deputy General Counsel and Secretary will ensure that the policies contained in the Policy are followed.
The purpose is to ensure that all F-M employees who are responsible for Customs-related functions will have a clear understanding of how their responsibilities impact and contribute to compliance with the Customs laws, regulations and policies of their country. F-M requests that all employees involved in our import and export operations read and understand these policies. F-M will conduct training, reviews, and discussions of these policies to enhance employee understanding. If you have questions or comments, we urge you to communicate them to us.
Questions or concerns regarding import and export procedures or the legal implications of any issue relating to the importation or exportation should be directed to F-M's Global Trade Compliance Manager or other designated employee.
Sincerely,
General Counsel and Secretary
GLOBAL TRADE COMPLIANCE MEMORANDUM
Global Trade Compliance Manager
Global Trade Compliance Department
Federal-Mogul Corporation
26555 Northwest Highway
Southfield, MI 48034
I have access to a copy of F-M’s Customs, Import VAT and Export Policy that is to be maintained on SharePoint. I have read and understood the sections of the Policy which apply to my job. I am fully acquainted with F-M’s customs compliance policies applicable to my Department. If I have specific questions about these policies, I will address them to the Global Trade Compliance Manager and my Department head.
I am aware of my responsibility to attend the initial training session (in person or via conference call) to review this Policy. During the meeting or conference call I will have an opportunity to ask questions about F-M’s import or export policies. Additionally, I will analyze typical customs situations, which may arise, in my job and how they will be handled according to F-M policy.
I am aware that I may be expected to attend additional training sessions, which will address changes in the laws or regulations, or changes in F-M policy, which may impact F-M procedures and the way I perform my job. F-M's Global Trade Compliance Manager will inform me of the dates/times of these training sessions.
Signed:
(Employee(s) Signature)
(Printed Name)
(Title)
(Department/Location)
(Date)
Print and return this completed form to the Training Department.