CHAPTER 1.1
F-M IMPORT ORGANIZATION
It is important that each person involved in F-M’s import operations understands the roles of others in F-M and our service providers, and is aware of available government resources.
A. Organization Chart Personnel
The Trade Compliance Department is part of the Tax Department and is overseen by the Vice President and Chief Tax Officer.
B. Trade Compliance Department
Thailand's Trade Compliance Department, consisting of the Import / Export Coordinator and other customs-related personnel, is responsible for day-to-day customs matters. The Trade Compliance Department receives assistance in customs compliance from Global Trade Compliance Manager and the General Counsel’s office. It also receives the information necessary for customs compliance from many other areas within the company, such as purchasing, accounting and receiving.
One of the key contacts associated with customs-related operations is F-M’s Global Trade Compliance Manager:
Wendy Himebaugh
Global Trade Compliance Manager
Global Trade Compliance Department
Federal-Mogul Corporation
26555 Northwest Highway
Southfield, MI 48034
(248) 354-7084
The Global Trade Compliance Manager is the key person with respect to F-M’s global customs procedures and practices. She administers F-M’s customs compliance program.
C. F-M Approved Service Providers
Only approved service providers should be utilized in our import operations. A list of approved service providers (i.e. customs brokers, freight forwarders, carriers, routings, etc.) for many F-M import functions is maintained by the local Finance Manager and Global Purchasing.
D. Supervision of Services
It is important for each of us to monitor performance and Customs compliance with the service providers we use. It is also important for you to understand the available alternatives in any transaction and to evaluate which service alternative is best for F-M. You should not utilize services without fully understanding the implications and, if necessary, consulting with the applicable department head or other relevant departments. Often, service providers are regarded by government agencies or third parties as agents of F-M, especially where Powers of Attorney have been issued. Therefore, acts or omissions of our service providers may become the legal responsibility of F-M.
For example, if a freight forwarder or customs broker goes bankrupt after being paid by us for Customs fees or for the services of a steamship line on our behalf, we may be required to pay Customs and/or the transportation charges to the steamship line again in order to move or release our freight. Similarly, even if our customs brokers misclassify products in the import entry process, we are likely to be responsible for all penalties that may arise from these errors (where we are the importer of record). F-M may have a claim against such service providers for negligence or failure to follow our instructions, but only if we are clear in any instructions we give to them. We must agree upon and clearly specify the scope of their services and accurately understand any requests for information that we receive from them. In addition, they should provide F-M with copies of all documents relating to our transactions for our files. Any agreements relating to providing ongoing services, covering multiple transactions or initial appointments must be reviewed by the Global Trade Compliance Manager and/or local Finance Manager.
E. Appointments and Changes
It is our policy to utilize only import freight and transport service providers who are first reviewed and approved by Global Purchasing. Generally, service providers should provide proof of general liability and insurance coverage. No general powers of attorney should be issued to our service providers. Any limited powers of attorney should not contain any limitations, exclusions, or disclaimers on the service supplier's liability and must be reviewed by Global Purchasing.
Once an import service provider has been approved for use by F-M, no changes may be made without approval by Global Purchasing, and no service agreement should be terminated without prior consultation with Global Purchasing.
F. Government Resources
In addition to our personnel and outside providers, we should utilize the resources of government agencies, where appropriate, since they may be available free of charge or at low cost. Please note however: Contact with government agencies first should be cleared with the local Finance Manager or Global Trade Compliance Manager. Where we are trying to resolve a specific legal compliance issue, any such communication should be made and or directed by F-M’s general counsel.
The following government agencies are of general or particular interest to F-M:
1. Thai Customs Department, 1 Sunthornkosa Road, Klong Toey, Bangkok 10110 Thailand, Telephone: 02-6677880-4 Fax: 02-6677885. (www.customsclinic.org).
2. Thailand Ministry of Commerce, Department of Foreign Trade (www.dft.go.th)
for origin and dumping information, and assistance with access to foreign markets)
CHAPTER 1.2
EMPLOYEE TRAINING
This section addresses F-M’s policies relating to initial and periodic training of F-M employees, and the procedures for disseminating changes to the regulations with which F-M must comply.
Training Procedures
A. Initial and Periodic Training Requirements.
In order for F-M to obtain the full benefits of our compliance programs, it is necessary that we train employees in the policies that we have adopted to both use reasonable care in our import and export operations, and prevent inadvertent violations of the import laws and regulations. Each newly hired employee, or employee transferred into a department that deals with or handles imported or exported merchandise will be required to read this Policy and will be expected to become fully acquainted with our policies and procedures. The same shall be true of certain personnel in other departments that may be involved with the ordering and payment of imported merchandise. When they have read this Policy, they should send to the Global Trade Compliance Manager a signed memorandum addressed to the Global Trade Compliance Manager acknowledging that fact. The Global Trade Compliance Manager will maintain a log of employees who have completed this requirement. Employees who have not read the Policy after 30 days will be reminded to do so by the Global Trade Compliance Manager.
In addition, the Global Trade Compliance Manager and F-M’s consultants will conduct training regarding the contents of this Policy, which will include a question and answer session and allow Policy recipients to analyze typical problems within the context of F-M’s policies. You will be expected to attend such training when requested.
From time to time, the Global Trade Compliance Manager and F-M’s consultants will conduct additional training regarding changes in the laws or regulations or changes in F-M policy that may impact F-M. This training will be conducted as needed, and the Global Trade Compliance Manager will notify you of such training. The Global Trade Compliance Manager will maintain a log of employees attending such training.
B. Procedures for Disseminating Regulatory Changes
Laws or regulations affecting F-M's import and export operations change periodically. As such changes are proposed and/or arise, F-M local customs teams are expected to monitor such changes and communicate those that are relevant to the Global Trade Compliance Manager. If you have questions regarding the effect of the changes on F-M policies, or questions regarding the timing for implementation of any changes, you should discuss them with the Global Trade Compliance Manager. The purpose of such discussions will be to determine whether any change in F-M policy is required, whether any preparation is necessary for such changes, whether any other departmental personnel should be consulted, and the implementation date for such changes.
CHAPTER 1.1F-M IMPORT ORGANIZATIONIt is important that each person involved in F-M’s import operations understands the roles of others in F-M and our service providers, and is aware of available government resources.A. Organization Chart PersonnelThe Trade Compliance Department is part of the Tax Department and is overseen by the Vice President and Chief Tax Officer.B. Trade Compliance Department Thailand's Trade Compliance Department, consisting of the Import / Export Coordinator and other customs-related personnel, is responsible for day-to-day customs matters. The Trade Compliance Department receives assistance in customs compliance from Global Trade Compliance Manager and the General Counsel’s office. It also receives the information necessary for customs compliance from many other areas within the company, such as purchasing, accounting and receiving. One of the key contacts associated with customs-related operations is F-M’s Global Trade Compliance Manager:Wendy HimebaughGlobal Trade Compliance ManagerGlobal Trade Compliance DepartmentFederal-Mogul Corporation26555 Northwest HighwaySouthfield, MI 48034(248) 354-7084The Global Trade Compliance Manager is the key person with respect to F-M’s global customs procedures and practices. She administers F-M’s customs compliance program.C. F-M Approved Service ProvidersOnly approved service providers should be utilized in our import operations. A list of approved service providers (i.e. customs brokers, freight forwarders, carriers, routings, etc.) for many F-M import functions is maintained by the local Finance Manager and Global Purchasing.D. Supervision of ServicesIt is important for each of us to monitor performance and Customs compliance with the service providers we use. It is also important for you to understand the available alternatives in any transaction and to evaluate which service alternative is best for F-M. You should not utilize services without fully understanding the implications and, if necessary, consulting with the applicable department head or other relevant departments. Often, service providers are regarded by government agencies or third parties as agents of F-M, especially where Powers of Attorney have been issued. Therefore, acts or omissions of our service providers may become the legal responsibility of F-M.For example, if a freight forwarder or customs broker goes bankrupt after being paid by us for Customs fees or for the services of a steamship line on our behalf, we may be required to pay Customs and/or the transportation charges to the steamship line again in order to move or release our freight. Similarly, even if our customs brokers misclassify products in the import entry process, we are likely to be responsible for all penalties that may arise from these errors (where we are the importer of record). F-M may have a claim against such service providers for negligence or failure to follow our instructions, but only if we are clear in any instructions we give to them. We must agree upon and clearly specify the scope of their services and accurately understand any requests for information that we receive from them. In addition, they should provide F-M with copies of all documents relating to our transactions for our files. Any agreements relating to providing ongoing services, covering multiple transactions or initial appointments must be reviewed by the Global Trade Compliance Manager and/or local Finance Manager.E. Appointments and ChangesIt is our policy to utilize only import freight and transport service providers who are first reviewed and approved by Global Purchasing. Generally, service providers should provide proof of general liability and insurance coverage. No general powers of attorney should be issued to our service providers. Any limited powers of attorney should not contain any limitations, exclusions, or disclaimers on the service supplier's liability and must be reviewed by Global Purchasing.Once an import service provider has been approved for use by F-M, no changes may be made without approval by Global Purchasing, and no service agreement should be terminated without prior consultation with Global Purchasing.F. Government Resources In addition to our personnel and outside providers, we should utilize the resources of government agencies, where appropriate, since they may be available free of charge or at low cost. Please note however: Contact with government agencies first should be cleared with the local Finance Manager or Global Trade Compliance Manager. Where we are trying to resolve a specific legal compliance issue, any such communication should be made and or directed by F-M’s general counsel.The following government agencies are of general or particular interest to F-M:1. Thai Customs Department, 1 Sunthornkosa Road, Klong Toey, Bangkok 10110 Thailand, Telephone: 02-6677880-4 Fax: 02-6677885. (www.customsclinic.org).2. Thailand Ministry of Commerce, Department of Foreign Trade (www.dft.go.th) for origin and dumping information, and assistance with access to foreign markets) CHAPTER 1.2EMPLOYEE TRAININGThis section addresses F-M’s policies relating to initial and periodic training of F-M employees, and the procedures for disseminating changes to the regulations with which F-M must comply.Training ProceduresA. Initial and Periodic Training Requirements.In order for F-M to obtain the full benefits of our compliance programs, it is necessary that we train employees in the policies that we have adopted to both use reasonable care in our import and export operations, and prevent inadvertent violations of the import laws and regulations. Each newly hired employee, or employee transferred into a department that deals with or handles imported or exported merchandise will be required to read this Policy and will be expected to become fully acquainted with our policies and procedures. The same shall be true of certain personnel in other departments that may be involved with the ordering and payment of imported merchandise. When they have read this Policy, they should send to the Global Trade Compliance Manager a signed memorandum addressed to the Global Trade Compliance Manager acknowledging that fact. The Global Trade Compliance Manager will maintain a log of employees who have completed this requirement. Employees who have not read the Policy after 30 days will be reminded to do so by the Global Trade Compliance Manager. In addition, the Global Trade Compliance Manager and F-M’s consultants will conduct training regarding the contents of this Policy, which will include a question and answer session and allow Policy recipients to analyze typical problems within the context of F-M’s policies. You will be expected to attend such training when requested.From time to time, the Global Trade Compliance Manager and F-M’s consultants will conduct additional training regarding changes in the laws or regulations or changes in F-M policy that may impact F-M. This training will be conducted as needed, and the Global Trade Compliance Manager will notify you of such training. The Global Trade Compliance Manager will maintain a log of employees attending such training.B. Procedures for Disseminating Regulatory ChangesLaws or regulations affecting F-M's import and export operations change periodically. As such changes are proposed and/or arise, F-M local customs teams are expected to monitor such changes and communicate those that are relevant to the Global Trade Compliance Manager. If you have questions regarding the effect of the changes on F-M policies, or questions regarding the timing for implementation of any changes, you should discuss them with the Global Trade Compliance Manager. The purpose of such discussions will be to determine whether any change in F-M policy is required, whether any preparation is necessary for such changes, whether any other departmental personnel should be consulted, and the implementation date for such changes.
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