C TPATExpectations
C TPATExpectations
C TPATExpectations
C-TPAT
Expectations for
Agents, Vendors &
Manufacturers
For Distribution to all new and existing Beall’s import related Business Partners
V. PROCEDURAL SECURITY………………………………………………………………………………….. 17
IX. ATTACHMENTS……………………………………………………………………………………………………. 25
Beall’s C-TPAT Expectations Vendor Acknowledgement Form…………………. 26
Beall’s Self-Assessment Form………………………………………………………………………………. 27
Beall’s Vendor Container 7-point Inspection Form……………………………….…….... 31
Beall’s C-TPAT Contact Information…………………………………………………………………. 32
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Introduction
In the wake of 9/11 the Bureau of Customs and Border Protection (“CBP”)
immediately tightened security at U.S. borders and cautioned the importing community of
the susceptibility of the supply chain to breaches in cargo security. It also prompted CBP to
institute a voluntary security program known as the Customs-Trade Partnership Against
Terrorism (C-TPAT). This joint initiative between CBP and the global business community
will not only strengthen the supply chain but it will also give visible benefits to those
companies choosing to join. In exchange for implementing improved security practices and
communicating security requirements to their business partners, importers can expect to
have reduced inspections and quicker clearance of imported freight. By participating in the
C-TPAT program, Beall’s hopes to increase vigilance amongst its employees and partners,
and establish a more secure and efficient supply chain. By setting a precedent for our
foreign counterparts, Beall’s will prove itself to be a leader in supply chain security.
Beall’s has developed a list of requirements for each of these specific areas of focus
noted above. We recognize that some of the requirements may be based on U.S. standards
and may not be possible to implement in other countries. We also recognize that certain
requirements may not be appropriate for some vendors due to the factory’s size and
structure.
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However, it is important for each business partner (vendor and manufacturer) to
ensure and acknowledge that security regulations are formulated and implemented to
protect the Company, its employees and the security of Beall’s supply chain.
It is imperative that all employees observe the facility’s security policies and report
any suspicious or improper actions to management and/or the proper authorities.
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Section I – Business Partner Security
SECTION I
Business Partner Security
As a member of the C-TPAT program, Beall’s is required to ensure that all of its business
partners adopt security-minded strategies and procedures that meet the C-TPAT
requirements. Thus, Beall’s goal is to continue to partner with its vendors, suppliers and
manufacturers in order to protect the security and integrity of the Company’s supply chain.
Beall’s, like many C-TPAT companies is now contractually requiring businesses to improve
security in order to meet C-TPAT guidelines. As a result, C-TPAT extends its reach well
beyond U.S. borders and impacts the security of companies both here and overseas. Examples
of how Beall’s leverages foreign suppliers to tighten security in the supply chain include:
Beall’s conducts regular audits of our foreign import vendors to ensure compliance with
C-TPAT security guidelines.
Beall’s is conditioning contractual business relationships with our service providers and
vendors based on C-TPAT participation and/or adherence to C-TPAT security guidelines.
Beall’s is leveraging existing internal inspection teams. We require C-TPAT cargo security
training for quality assurance personnel or non-security related business representatives
who visit foreign vendors and factories on a regular basis.
To better secure and facilitate the supply chain security and flow of goods entering the United
States, Beall’s is committed to ensuring that all of the Company’s preferred existing and new
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Section 1 – Business Partner Security
trading partners fulfill their commitments by verifying that agreed security measures have
been implemented.
As a participant of the C-TPAT program, Beall’s not only reinforces its Company’s belief in
corporate good citizenry, Beall’s believes that assessing its supply chain security procedures
and practices improves business efficiency. Perhaps the greatest success of C-TPAT is that
although participant companies join voluntarily, members have made participation and/or
compliance with C-TPAT security standards by their business partners a requirement for
doing business. Ultimately, these partnerships will help CBP create a true green lane that
speeds low risk shipments across all our borders and through our ports of entry and preserve
global trade in this time of global terrorism.
Beall’s vendors are required to meet and/or exceed the following requirements:
All Beall’s import related vendors, business partners and foreign manufacturers
must have written and verifiable processes for the selection of business partners
including, carriers, other manufacturers, product suppliers and vendors (parts and
raw material suppliers, etc).
Beall’s reserves the right to request copies of vendor’s written processes for the
selection of business partners for verification that C-TPAT requirements are being
met.
Beall’s reserves the right to periodically inspect vendor’s business facilities to ensure
compliance with Beall’s and U.S. Customs C-TPAT requirements.
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Section 1 – Business Partner Security
For Beall’s business partners who are C-TPAT members: (i.e. foreign manufacturers,
carriers, ports, terminals, brokers, consolidators, etc.) Beall’s requires documentation
verifying business partner’s C-TPAT status. The following are acceptable forms of
documentation:
- copy of C-TPAT certificate and SVI number
AND
- a completed “Beall’s C-TPAT Vendor Self-Assessment Form.”
Note: Beall’s requires written notification from its C-TPAT certified business partners if
there is a change in the partner’s C-TPAT status. All vendors are required to submit a
completed “Beall’s C-TPAT Vendor Self-Assessment Form” on an annual basis. Beall’s
reserves the right to terminate business relations with business partners who fail to
submit annual self-assessments of their security practices.
For Beall’s business partners who are eligible for but not C-TPAT certified (foreign
manufacturers, carriers, ports, terminals, brokers, consolidators, etc.) Beall’s requires
business partners who are eligible for but not C-TPAT certified to demonstrate that they
are meeting C-TPAT security criteria via written/electronic confirmation. Accepted forms
of business partner written/electronic confirmation are:
- contractual obligations
- a letter from a senior business partner or officer attesting to compliance
- a written statement from the business partner demonstrating their
compliance with C-TPAT security criteria or an equivalent WCO
accredited security program administered by a foreign customs authority
AND
- a completed “Beall’s C-TPAT Vendor Self-Assessment Form.”
Note: All vendors are required to submit a completed “Beall’s C-TPAT Vendor Self-Assessment
Form” on an annual basis. Vendor’s failure to do so could result in Beall’s termination of
business relations with non-compliant vendor. Based upon a documented risk assessment
process, eligible but non-C-TPAT certified business partners are subject to verification of
compliance with C-TPAT security criteria by Beall’s.
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Section 1 – Business Partner Security
Note: All vendors are required to submit a completed “Beall’s C-TPAT Vendor Self-Assessment
Form” on an annual basis. Vendor’s failure to do so could result in Beall’s termination of
business relations with non-compliant vendor. Based upon a documented risk assessment
process, Beall’s business partners ineligible for C-TPAT certification are subject to verification
of compliance with C-TPAT security requirements by Beall’s and/or U.S. Customs.
Beall’s requires all business partners to ensure the development and implementation of security
processes and procedures consistent with the C-TPAT security criteria to enhance the integrity of
all Beall’s shipments at point of origin.
Current or prospective business partners who have obtained a certification in a supply chain
security program being administered by foreign Customs Administration are required to indicate
their status of participation to Beall’s.
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Section II – Container Security
SECTION II
Container Security
Container and trailer integrity must be maintained to protect against the introduction of
unauthorized material and/or persons. At the point-of-stuffing, procedures must be in place
to properly seal and maintain the integrity of the shipping containers and trailers. A high
security seal must be affixed to all loaded containers and trailers bound for the U.S. All seals
must meet or exceed the current PAS ISO 17712 standard for high security seals.
In those geographic areas where risk assessments warrant checking containers or trailers
for human concealment or smuggling, such procedures should be designed to address this
risk at the manufacturing facility or point-of-stuffing.
Procedures must be in place to verify the physical integrity of the container structure prior to
stuffing, to include the reliability of the locking mechanisms of the doors. A seven-point inspection
process is required for all factory loaded containers. Seven container points to be inspected are:
Front wall
Left side
Right side
Floor
Ceiling/Roof
Inside/outside doors
Outside/Undercarriage
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Section II – Container Security
Procedures must be in place to verify the physical integrity of the trailer structure prior to stuffing,
to include the reliability of the locking mechanisms of the doors. The following ten-point inspection
process is recommended for all trailers:
The sealing of trailers and containers, to include continuous seal integrity, are crucial elements of a
secure supply chain, and remains a critical part of a foreign manufacturers’ commitment to C-
TPAT. The foreign manufacturer must affix a high security seal to all loaded trailers and containers
bound for the U.S. All seals must meet or exceed the current PAS ISO 17712 standards for high
security seals.
Written procedures must stipulate how seals are to be controlled and affixed to loaded
containers and trailers, to include procedures for recognizing and reporting compromised
seals and/or containers/trailers to US Customs and Border Protection or the appropriate
foreign authority. Only designated employees should distribute seals for integrity purposes.
Containers and trailers under foreign manufacturer control or located in a facility of the foreign
manufacturer must be stored in a secure area to prevent unauthorized access and/or manipulation.
Procedures must be in place for reporting and neutralizing unauthorized entry into
containers/trailers or container/trailer storage areas.
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Section II – Container Security
Written procedures must stipulate how seals are to be controlled and affixed to loaded containers -
to include procedures for recognizing and reporting compromised seals and/or containers to US
Customs and Border Protection or the appropriate foreign authority. Only designated employees
should distribute container seals for integrity purposes.
Containers must be stored in a secure area to prevent unauthorized access and/or manipulation.
Procedures must be in place for reporting and neutralizing unauthorized entry into containers or
container storage areas.
Beall’s requires all business partners to have procedures in place that adhere to the following
security criterion:
Original copies of completed 7-Point container inspection forms are required for
payment approval. Originals are to be included in the document packet submitted
to Beall’s Import Accounting & Compliance Dept. for Direct Wire Transfer
Payments or to the LC issuing bank for LC payments. Copies are to be included in
the documents presented to the Beall’s approved freight forwarder for Customs
entry purposes.
Beall’s will conduct periodic reviews of all business partners’ processes and
facilities based on risk to ensure that C-TPAT security standards are being met.
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Section III – Physical Access Controls
SECTION III
Physical Access Controls
Access controls prevent unauthorized entry to facilities, maintain control of employees and visitors,
and protect company assets. Access controls must include the positive identification of all employees,
visitors, and vendors at all points of entry.
3.1 Employees
An employee identification system must be in place for positive identification and access control
purposes. Employees should only be given access to those secure areas needed for the performance
of their duties. Company management or security personnel must adequately control the issuance
and removal of employee, visitor and vendor identification badges. Procedures for the issuance,
removal and changing of access devices (e.g. keys, key cards, etc.) must be documented.
3.2 Visitors
Visitors must present photo identification for documentation purposes upon arrival. All visitors
should be escorted and should visibly display temporary identification.
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Section III – Physical Access Controls
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Section IV – Personnel Security
SECTION IV
Personnel Security
Implementing personnel security measures is an important step in securing the supply chain. The
focus of a personnel security program is to investigate the background of prospective employees to
ensure that they pose no risk to Beall’s operations. Please note that the requirements provided below
are based on U.S. standards and may not be possible to fulfill in other countries. However, Beall’s
expects all business partners to take as many steps as possible to avoid hiring someone whom may
pose a threat to Beall’s or its supply chain.
Criminal convictions –
All felony and misdemeanor convictions involving workplace violence, burglary/ robbery,
theft, assault, identity theft, murder, kidnapping, rape, terrorist threats, or other crimes.
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Section IV – Personnel Security
Application verification
Prior employment
Address verification
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Section V – Procedural Security
SECTION V
Procedural Security
Security measures must be in place to ensure the integrity and security of processes relevant to
the transportation, handling, and storage of cargo in the supply chain. Procedural security
measures regulate incoming and outgoing goods and are designed to prevent the introduction of
unmanifested materials into the supply chain, or the loss or exchange of Beall’s merchandise. Each
business partner and/or factory should have a designated employee supervising the introduction and
removal of cargo. All merchandise must be properly marked, weighed, counted, and documented.
Procedures must be in place to govern the detection and recording of shortages and overages.
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Section V – Procedural Security
Departing cargo being shipped should be reconciled against information on the cargo
manifest.
The cargo should be accurately described, and the weights, labels, marks and piece count
indicated and verified. All merchandise must be properly marked, weighed, counted,
and documented.
Drivers delivering or receiving cargo must be positively identified before cargo is received
or released.
Procedures should also be established to track the timely movement of incoming and
outgoing goods.
Customs and/or other appropriate law enforcement agencies must be notified if anomalies,
illegal or suspicious activities are detected - as appropriate.
Each factory should have a designated employee supervising the introduction and removal
of cargo.
Containers, trailers, and/or railcars left at the facility overnight must be secured.
Containers that are full of cargo must be locked and sealed with industry-approved seals
and said seal numbers must be recorded. The seals should be uniquely numbered and
require destruction to be removed.
All containers or trailer entering or leaving the facility must be recorded, along with the
name of the driver who took custody of the Beall’s merchandise.
The factory should have a procedure for inspecting and verifying seals.
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Section V – Procedural Security
Beall’s reserves the right to request on-site access to business partner’s facilities to ensure
that the C-TPAT requirements are being met.
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Section VI – Security Training & Threat Awareness
SECTION VI
Security Training & Threat Awareness
Beall’s requires all vendors, manufacturers and service providers to establish and maintain a
threat awareness program by security personnel to recognize and foster awareness of the
threat posed by terrorists and contraband smugglers at each point in the supply chain.
Employees must be made aware of the procedures the company has in place to
address a situation and how to report it.
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Section VII – Physical Security
SECTION VII
Physical Security
7.1 Fencing
Perimeter fencing should enclose the areas around cargo handling and storage facilities.
Interior fencing within a cargo handling structure should be used to segregate domestic,
international, high value, and hazardous cargo.
There must be a formal registration process for documenting visitors to the operations.
Gates through which vehicles and/or personnel enter or exit must be manned and/or
monitored.
The number of gates should be kept to the minimum necessary for proper access and
safety.
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Section VII – Physical Security
7.3 Parking
Private passenger vehicles should be prohibited from parking in or adjacent to cargo
handling and storage areas.
Parking for employees must be separate from the dock and cargo operations.
Management or security personnel must control the issuance of all locks and keys.
7.6 Lighting
Adequate lighting must be provided inside and outside the facility including the following
areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas.
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Section VII – Physical Security
7.8 Beall’s expects all vendors, manufacturers and business partners to adhere
to the physical security requirements below:
Clear zones must be maintained internally and externally to monitor the security of the facility.
Brush and growth should be cleared at least 35 feet from perimeter barrier.
All containers and trailers that remain at the warehouse overnight should be secured. Trailers
loaded with cargo should also be sealed, with the seal number recorded and verified.
Seal numbers must be verified before the container, trailer or truck is released.
Employees should be familiar with the trucking vendors. The identification of the driver should
be checked before cargo is released to his/her custody.
Truck drivers should never be allowed to randomly enter the factory and pick up a trailer
without supervision.
All visitors and persons not employed by the company should be escorted by an employee at all
times.
Each facility should also have a communication system in place to contact internal security
personnel or local law enforcement police in the event of an emergency.
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Section VIII – Information Technology
SECTION VIII
Information Technology
Beall’s requires all vendors, manufacturers and business partners to ensure the integrity and security of all
information technology data. All vendors and manufacturers must adhere to the following information security
requirements:
Automated systems must use individually assigned accounts that require a periodic change of password. IT
security policies, procedures and standards must be in place and provided to employees in the form of
training.
Vendors and manufacturers must have systems in place that are supported by the use of firewalls, anti-virus
protection and encryption software to prevent against outside intrusion.
All vendors, manufacturers and business partners should have a data backup plan.
System backup data should be stored at an off-site location for safekeeping.
8.4 Accountability
A system must be in place to identify the abuse of IT including improper access, tampering or the altering of
business data. All system violators must be subject to appropriate disciplinary actions for abuse.
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Beall’s, Inc.
C-TPAT Expectations for
Vendors & Manufacturers
SECTION IX
ATTACHMENTS - Vendor Forms
Beall’s C-TPAT Expectations
Import Vendor Acknowledgement Form
_________________________________________________ ___________________
Authorized Signature Date
_________________________________________________
Company Stamp/Seal
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Beall’s C-TPAT Expectations - Import Vendor Security Self-Assessment Form
Read the attached Beall’s C-TPAT Expectations for Vendors & Manufacturers and C-TPAT security recommendations from U.S. Customs then
describe your company's security procedures related to export/import shipments to Beall’s, Inc. and its subsidiaries: Beall’s Imports, Inc. and/or
Beall’s Outlet Stores, Inc. in the U.S. by checking (√) the appropriate blocks below.
Please print, sign and forward completed forms to Attn: Beall’s C-TPAT Coordinator’s Office at [email protected]
========================================================================================================================
1. Select (√) the category that best describes your business with Beall’s entities in the U. S. (Check all that apply)
2. Years in business
4. Number of employees:
5. What Beall’s , Inc. subsidiary / location(s) in the United States does your company most frequently ship to?
Beall’s Imports, Inc. Beall’s Outlet Stores, Inc. Both
6. Does your company have written security procedures at non-U.S. facilities doing business with Beall’s, Inc. and its subsidiaries
and conduct periodic reviews of internal controls to ensure security compliance?
Yes No
27
Beall’s C-TPAT Expectations - Import Vendor Security Self-Assessment Form
7. Does your company affix seals to loaded containers for shipments to Beall’s Inc. and its subsidiaries in the U.S.?
Note: All seals must meet or exceed the current PAS ISO 17712 standard for high security seals.
Yes No
9. If yes to above question, are containers stored in a secure area to prevent unauthorized access or manipulation?
Yes No
10. Does your company ship full container loads (CY/CY) or mostly LCL shipments to Beall’s, Inc. and its subsidiaries? (Please indicate
your best estimate by volume percentage)
CY/CY Loads Only CFS / LCL Loads Only Both % CY/CY % CFS / LCL
11. Does your company have procedures in place to verify the physical integrity of the container structure prior to stuffing, and do
they address ensuring the reliability of the locking mechanisms of the doors? (See the following link for items to be addressed during a
container inspection: http://www.customs.gov/xp/cgov/trade/cargo_security/ctpat/security_criteria/sec_criteria_foreign_mfc/)
Yes No
12. Does your company conduct 7-point inspections on all import containers scheduled to convey Beall’s merchandise?
Yes No
13. Does your company have physical access controls to prevent unauthorized entry to facilities, maintain control of employees
and visitors, and protect company assets?
Yes No
14. Have you developed and communicated a process to report shipment overages/shortages, losses or abnormalities, whether
suspected or confirmed, to Beall’s, Inc. management?
Yes No
15. Is your company a member of any of the following U.S. Customs programs: C-TPAT, ISA, the Business Anti-Smuggling Coalition
(BASC), or any other internationally-recognized security initiatives?
Yes, C-TPAT (Please specify SVI# and include copy of C-TPAT Certificate) SVI#
16. If a member of the C-TPAT program, has your company been certified and validated? If yes, please state your company’s Tier in
the C-TPAT program.
Yes, C-TPAT certified and validated C-TPAT Tier 1 2 3 Yes, certified, not validated N/A
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Beall’s C-TPAT Expectations - Import Vendor Security Self-Assessment Form
17. Does your company have a Security & Threat Awareness Training program for its employees?
Yes No
18. If yes, how often is Security & Threat Awareness training provided for employees?
Yes No
20. Does your company have an incentive program to encourage employees to report security anomalies and incidents?
Yes No
21. Does your company have written procedures for reporting security anomalies and incidents to local law enforcement and/or
U.S. Customs?
Yes No
22. Do your company’s computer systems have limited access that is reserved for authorized company personnel use only?
Yes No
23. Are your company’s computer systems password protected to prevent unauthorized access?
Yes No
24. Does your company use firewalls, encryption software and anti-virus protection to guard from outside intrusion?
Yes No
Yes No
26. Is system mainframe back-up data stored at an off-site location for safekeeping?
Yes No
27. Identify the individual within your company to whom questions about the security of Beall’s, Inc. and its subsidiaries shipments
may be directed:
Contact Name:
Contact Title:
Company Name:
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Beall’s C-TPAT Expectations - Import Vendor Security Self-Assessment Form
Address:
Phone:
Email:
Insert Company Name Here acknowledges Beall’s, Inc. and its subsidiaries emphasis on supply chain security and
recognizes the expectation that Beall’s business partners share that commitment. I understand that Beall’s, Inc. and its
subsidiaries may refer security inquiries from U. S. Customs to me.
Name: Title:
Company Stamp/Seal:____________________________________
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Beall’s Import Vendor Container 7-Point Inspection Form
To be completed by business partner/factory where the container is physically stuffed and inspected.
Applicable for vendors shipping full container loads ONLY!
Vendor / Actual Manufacturer (Full Name & Address) Container Stuffing Location (Full name & Address)
Consigned To:
Beall’s Imports, Inc. Beall’s Outlet Stores, Inc.
th
1806 38 Avenue East 2100 47th Terrace East
Bradenton, FL 34208 Bradenton, FL 34203
I have visually inspected and verified, to the best of my ability, the condition of the container noted above. I confirm that the
container is structurally sound, weather tight, has no false compartments, and the locking mechanisms are in good order and
show no visible signs of being tampered with.
Inspected By: Date Company Stamp/Seal:
Copy of completed form to be included with paperwork presented with the cargo to Beall’s approved Freight Forwarder at origin for Customs entry purposes.
Original to be included with payment paperwork to Beall’s Import Accounting & Compliance Department or to the Beall’s LC issuing bank.
Beall’s C-TPAT Contact Information
Tel: 941-747-2355
Email: [email protected]