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Automated Trade
Compliance processes

Automation and Control Solutions
       Bruno Fransman
         May 29th 2012
Introduction
Why automation?
  •   Key findings from the report include:
        – 84 percent of compliance professionals expect to handle more regulatory information in
            2012
        – More than a third of respondents spend an entire working day each week staying up-to-
            date with regulatory changes
        – 70 percent of respondents expect the cost of senior compliance staff to be higher this year
        – Only 11 percent of companies expect a significant increase in their budget for compliance
            this year
  •   While regulatory requirements continue to grow, compliance teams are showing signs of
      resource constraints limiting their ability to perform vital compliance functions. More than a third
      of compliance professionals say they spend more than an entire working day each week in
      simply staying up to date with regulatory changes and assessing their impact on the business.
  •   At the same time, compliance teams report difficulty finding time to coordinate with other parts
      of the company involved with managing regulatory risk. More than half of compliance
      professionals surveyed said they spend less than one hour a week working together with
      internal audit colleagues. One-third of respondents say they similarly spend less than one hour
      a week consulting with their legal and risk teams.
  •   While keeping executive management informed of regulatory issues is a key part of the
      compliance role, more than a quarter of respondents say they spend less than one hour a
      week reporting to their boards. In the U.S., more than half of the companies surveyed spend
      less than one hour a week reporting to their boards. This raises concerns about whether
      executive management is being kept sufficiently informed on compliance issues

Compliance Teams Stretched to their Limits (March 13th, 2012 by Corporate Compliance Insights and
                        Cost of Compliance Survey 2012 by Thomson Reuters ACCELUS)
ACS Today

     Profile               • Sales: $15.5B                                     • 70,000 Employees
                           • Technology, leading brands                        • Large installed base
     Strengths
                           • Security, ECC, Life Safety                        • Global reach                              41%
                                                                                                                           36%
     Growth                • 164 countries served                              • > 2M ship to addresses
     Focus
                           • 54 acquisitions since 2003                        • 110 ERPs
    ECC                     S&C                   HLS                   HBS          HPS            HSG                 HSM


                                                                        Buildings
                                                         Fire/Smoke                   Process
                                                         Sensors                      Controls

Thermostats                                                                                           Motion / Human
                           Speed and Position                                                       Presence Sensors

              Building     Sensors                                                                                          Scanning
                                                  System                                                                    &
              Automation                          Panels                Instant
                            Pressure                                    Alert                                               Mobility
                            Sensors
   Water
   Control

                                                                                                      CCTV/
                                                        Gas Detection                                                   Voice Picking
               Gas                                                                                    DVR
                                                                                      Distributed                       Personal Satellite
               Valves
                                                                                      Control                           tracking

                            Military Sensors
Industrial
Burners                                                                                                   Control
                                                Personal Protection                                       Systems      Mobile Computing

Comprised of 93 Supply Chains, 118 Plants, 93 DC’s, 9 Integration Centers
Background
           Distribution Footprint




  219 Global Locations Distributing Product
118 Factories - 93 DC’s - 9 Integration Centers
Honeywell – Corporate Policy
“Honeywell will comply fully with all applicable export and import control laws
   and regulations of the United States and of all countries in which it
   conducts business.”

•   Customs laws
     • Requirement to declare goods accurately on importation – classification,
       valuation, country of origin
     • Implies that our trade data is accurate – including sourced items!
     • Use free trade agreements legally and intelligently

•   Export control laws
     • Certain goods of strategic nature require government approval before export
     • Use of military components can “infect” non-military products
     • Restrictions on importing from certain countries – embargoes

•   Other government agency (OGA) requirements
     • ACS now faces permitting requirements in US/ MXon health/medical products
       in HSP – eyewash, first aid kit elements, ibuprofen, etc.
ACS Trade Service Offerings

Team Vision:                                                                                          Objective
A collaborative ensemble of                                                                          Build a global compliance
professionals partnering with                                                                        infrastructure; enable rapid trade
Honeywell colleagues to efficiently                                                                  problem-solving; continuously
transact business across national
                                                                Enabling Growth                      improve cross-border productivity
borders as advantageously as
                                                      •Export De-control and Licensing               and operations; and eliminate
possible for Honeywell, our                           •Customer Duty Preference Request
customers, and our suppliers while                    •Transaction Structuring and Approvals         regulatory barriers to growth.
                                                      •Regulatory Advice, Advocacy, and Rulings
obeying international trade rules.

                                              Productivity and Operational Support
                                              • Duty Avoidance and Incremental Duty Savings
                                              • Broker Management and In-house Customs Brokerage
                                              • Software and Automation
                                              • Product-line Moves and Technology Collaboration
                                              • Supply-chain Security
                                              • Direct Shipments/ Cross-dock Operations
                                              • Sourcing Decisions/ Vendor-managed Inventory



               Ensuring Compliance with International Trade Rules                      Mitigating Risk of Non-compliance
               • Standardized Internal Controls                                         Government Inquiries and Audits
               • HS and ECCN Classification                                             Government Disclosures
               • Internal Risk Assessments and Remedial Action Plans
               • Submissions to Government Agencies and Post-entry Audits
               • Cross-functional Training
               • Pre-acquisition Due Diligence and Post-acquisition Integration



 Enabling Growth and Increasing Productivity from a Foundation of Compliance
Components of Honeywell EU Trade Strategy



                                      CENTRALIZED
                                        CUSTOMS
                                     • Optimized trade
                                        operations

                              AUTHORIZED ECONOMIC
                              OPERATOR CERTIFICATION
                              • Faster border crossings
                              • Smoother customs operations


                CUSTOMS BROKER                  Automated Trade
                MANGEMENT                       • Trade documents
                • Control entries               • E-Filing
                • Measure Brokers               • Preference calculation
                • Assure compliance             • De-minimis calculation
                • Maximize duty savings         • Export control
                                                • ….

      TRADE MASTER DATA MANAGEMENT              WRITTEN PROCEDURES
      • HS and ECCN Classification              • Written procedures
      • Net weight                              • Develop training
      • Origins                                 • Establish accountabilities




                      Driving to meet EU requirements
Automated Trade solutions


        Introduction
CP/S Modell for EU TRADE Solution
Automation and
Control Solutions




Web-Order
                                         Delivery
EDI-Order           Order entry                                 Picking          Packing         Shipping Master Data
LINK-Order                               creation


       Transaction        G                                                           Freight cost      Automated
       Screening                                                                      calculation       Customs




                                                                                       Freight
                                                                                                        Export
       Freight Audit                EU PCT                                             Forwarder
                          G                                                                             Documents
       & Payment                    Caclulation                                        Integration

                                                               G      = GLOBAL used



                       Automated Tool                              Partners

                       Other


                       SAP + Roles and Content from external source
SAP GDM Trade Compliance and Solutions

                                  SAP CP/S
  NA
TRADE
 Docs
                                  XI - Gateway

                                                                             SAP


                                                                       Pref Calc.
              Automated
                                             Specific Automated
               Systems
                                             Trade Solutions at        De-minimus.
                                             EU sites
                                                                       Export Documents
        Global DPL Screening               EU Export Documents

        ECCN Shipping License              EU Electronic -Customs

        NAFTA Calculation,,                EU DG Documents
        Shipping docs , …..

        Landed cost calculation            EU Preference Calculation
                                           + docs
ACS Intranet Trade
    solutions
ACS Intranet solutions
Customs Issue Log




14                   HONEYWELL - CONFIDENTIAL   File Number
Metrics Web Tool




15                      HONEYWELL - CONFIDENTIAL   File Number
AEO




16         HONEYWELL - CONFIDENTIAL   File Number
Customs Compliance Assessment
• Rolling out EU compliance self-assessment

• Assess gaps and overall readiness for AEO
• Traffic light report
• Improvement plan




                         Traffic light report and improvement plan
Automated Customs
    Solutions
Electronic customs filing

     • Limited to exports (interfaced with SAP)
      - Export declaration filing
     • Export Trade documents
      -   Commercial (Customs/shipping) invoice
      -   EUR.1/A.TR
      -   COO
      -   LTDO (Long Term Declaration of Origin)




19                            HONEYWELL - CONFIDENTIAL   File Number
Automated Preferential Process Flow in FTA - (exporting plant point of view)
 Vendor                                                                                                            Customer
                                                                                                                    Customer
Vendor
  ?         Business Task 1                                Business Task 2                        Business Task 3
       Vendor Declaration                     Preference Calculation
          Management                                                                                  Proof of Origin
                                                     Sales Product XYZ                                documentation
      Look up missing/expired VDs
                                             BOM                                       Shipping
                                                                                       Plant
                                                     S1        S2          S3                      •Declaration of Origin
          Dunning/Solicitation
                                         ?                                                          on the Invoice or Packing list
                                               C11             C21              C31
          • Fax, E-mail                               C12            C22              C32          •European docs: EUR1, A.TR
          •Printing                                ………………….                                        •Long Term Declaration (LTD)
          •Portal
                                              E1          E2   … E3              E4         E5
               Get VD                         ?           MX          EU         CN          ?

                       Proof of Origin
                                                 Legal Rules of Origin
                                              for Preference Calculation
Automated Export Control
CP/S Global Design Model - Export
 Global Design Model - Export: The ACS global export design model
  consists of an integrated solution managed by Automated Tool with SAP
  hold management.
    3 TRADE APPROVED solution variants
        Solution based on regional requirements and site risk profile
Export Control Function:                                       Gold Silver Bronze
Restricted party screening via Automated Tool with soft alerts
Restricted party screening via Automated Tool with hard blocks
SAP Embargo controls with hard Blocks
SAP Embargo controls on returns with hard blocks
Foreign trade data missing with hard blocks (ECCN, HTS or COO)
Missing end user or end use results in hard blocks
Automated Tool license determination with hard blocks
Automated Tool license management and decrementing
SAP license determination with hard blocks
SAP license management and decrementing
Material master fields for ECCN, HTS and COO
SAP or automated export tool docs (C/I and SLI)
Sensitive country analysis - Origin
Qualify Honeywell for sales by verifying non-US content




Automation improves visibility on flows and costs and increases compliance
             level and generates savings and realizes growth
What is denied party screening & why is it required?

  • Export control laws make it unlawful for Honeywell US and its non-US
    subsidiaries to conduct business with entities that
     - violate export regulations; or
     - are involved in proliferating weapons of mass destruction; or
     - Are involved in narcotics trafficking; or
     - represent embargoed or terrorist-supporting countries.

  • Honeywell is liable if it does business with an entity involved in these
    activities. We cannot avoid liability by saying that we did not know of
    their activities.

  • The Tool provides several lists that includes the names, addresses and
    reason for denial for all restricted organizations, companies and
    individuals.




  All end users must be screened against these denial lists
                  to ensure compliance!
How does this impact our job & what to expect?
• Customer and Vendor Account Creation
    – When creating customer and vendor accounts – immediate transfer to
      Automated Tool for denied party screening (DPL)
    – If Automated Tool determines that there is a match, then order cannot be
      placed using this party until the DPL hit has been resolved in Automated
      Tool


• Order Entry – Party Creation at Order Level (Sales and delivery order)
    – If a customer is added ad hoc at the order level, then party info transferred
      to Automated Tool immediately for DPL screening
    – If Automated Tool determines that there is a match, then a delivery block will
      be created on the line items in the order until possible match resolved in
      Automated Tool.


• The SAP user will be notified via warning messages of any DPL
  matches, as well as daily summary reports e-mailed to a designated
  mailbox.
    – If a parties is changed after delivery, then the export docs and PGI will be
      blocked and the user will receive a workflow message
Lessons learned

     • Change management
      - From fully outsourced trade compliance to semi-outsourced
         Business do underestimate the impact
         Automation doesn’t mean that everything is automated: e.g.:
          • Trade Data Management: garbage in garbage out
          • Export control
                      » Before: no order screening only manual party
                        screening
                      » Automated Tool: order screening => increased
                        involvement by entities and functions: Sales, Order
                        Admin and purchasing
                      » “One time only” customers : repeated false hits
          • Customs
                      » Stricter processes (“less” flexible): people do
                        complain
                      » PCT: discipline on trade data management up to
26                      level of components
                                  HONEYWELL - CONFIDENTIAL                    File Number
Benefits

     • Increased compliance level
      - Helps for AEO-certification
     • Increased awareness across functions
      - Better visibility: Trade compliance more then just “stamping”
        documents
      - Increased understanding and appreciation of our function
      - Trade also means sales not just blocking or fire fighting
     • Better reporting to senior management
      - Metrics for senior management
      - Duty savings reports
      - => part of quarterly meeting reviews with CEO
     • Funding to get additional resources
     • Funding to get more and better automation

27                           HONEYWELL - CONFIDENTIAL                   File Number
Non Productivity vs. Productivity – Conclusions


ACS would incur $110M in Annual Duty Costs If It had No Global Duty Avoidance Program
    Year        Import Value    Duty Spend    Duty Saved           Duty Liability           Duty Ratio


    2011       3,474,646,476    59,807,627    50,689,151           110,496,778                3.18%



    2010       3,142,132,983    57,035,301    53,368,281           110,403,582                3.51%




ACS Duty Spend is $51M Annually Because of its Global Duty Avoidance Program
   Year        Import Value    Duty Spend    Duty Saved    Duty Avoided per $1 Import   Actual Duty Ratio
                                                                     Value

   2011       $3,474,646,476   $59,807,627   $50,689,151            85 cents                 1.72%



   2010       $3,142,132,983   $57,035,301   $53,368,281            93 cents                 1.82%




    46% Reduction in Duty Liability achieved through our Duty Avoidance Mechanism
2011 Productivity
Import Volumes in USD                                                             Duties paid in USD
   Country     Import Value                     2%                                                                      30
                                         3%                                         Country      Duty Paid




                                                                                                             Millions
                                                                                                                              42%
     US        1,554,275,102        4%               7%                                US       25,258,564              25
     MX         686,677,631
                                                                                      MX          584,716
                                                                                                                        20
     CN         402,811,856              7%                     45%                    CN        4,352,089
     CA         248,372,627                                                                                             15                                   22%
                                                                                       CA        2,756,762
     GB         140,055,300              12%
                                                                                       GB        4,452,195              10                                              15%
      IN        122,098,503                                                            IN       13,085,576                                   7%        7%
     DE         75,202,161                           20%                               DE         426,402                5                        5%
                                                                                                                                      1%                           1%
    Other       245,153,296                                                          Other       8,891,323               0
    TOTAL      3,474,646,476       US   MX      CN    CA   GB   IN   DE   Other      TOTAL      59,807,627                     US     MX     CN   CA   GB     IN   DE Other




Duty Rates in USD                                                                 Duty Savings in USD
                        Top Importing Countries
    Country      Import Value             Duty Paid             Duty %              Country    Savings                              Program             Duty Savings
      US         1,554,275,102           25,258,564             1.63%                 US      15,383,204                        Processing              19,069,415
      MX          686,677,631             584,716               0.09%                 MX      10,910,333                            NAFTA               17,317,626
      CN          402,811,856            4,352,089              1.08%                 CN      9,254,410                       Duty Drawback                 8,814,864
      CA          248,372,627            2,756,762              1.11%                 CA      1,491,493                          FTZ/Bond                   2,081,102
      GB          140,055,300            4,452,195              3.18%                 GB      1,640,856                       Other FTA/GSP                 1,672,972
      IN          122,098,503            13,085,576             10.72%                IN      10,358,852                             HTS                    285,373
      DE           75,202,161             426,402               0.57%                 DE       855,381                       EU Charlton House              280,125
     TOTAL       3,474,646,476           59,807,627             1.72%                Other     803,620                               Other                  179,680
                                                                                    TOTAL     50,689,151                            TOTAL               50,698,151
                          Highest Duty Rate %

    Country       Import Value           Duty Paid              Duty %
      AR           5,837,970              892,968               15.30%
      BR           26,673,072            3,644,519              13.66%
      VE           2,765,852              334,892               12.11%
      IN          122,098,503            13,085,576             10.72%
Next Steps – wish list

     • Broker Management
      - Two way interface : PO’s and metrics reporting
      - Import metrics
          Duty savings and risk assessment tool
          Reporting
     • Trade data improvements
      - Global HTS-classification tool
      - Origin solicitation and management
     • Further improve our intranet tools




30                               HONEYWELL - CONFIDENTIAL   File Number
Any Questions?




     We’ll always try to answer and support the business but answer can be dependent from
                                       support of others
31                                  HONEYWELL - CONFIDENTIAL                           File Number
Thank you for your attention.




Bruno Fransman
Global Customs Compliance Director
Bruno.fransman@honeywell.com
+32 2 728 20 38

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Export Compliance Management Seminar 29 May 2012: Automated Trade Compliance Processes

  • 1. Automated Trade Compliance processes Automation and Control Solutions Bruno Fransman May 29th 2012
  • 3. Why automation? • Key findings from the report include: – 84 percent of compliance professionals expect to handle more regulatory information in 2012 – More than a third of respondents spend an entire working day each week staying up-to- date with regulatory changes – 70 percent of respondents expect the cost of senior compliance staff to be higher this year – Only 11 percent of companies expect a significant increase in their budget for compliance this year • While regulatory requirements continue to grow, compliance teams are showing signs of resource constraints limiting their ability to perform vital compliance functions. More than a third of compliance professionals say they spend more than an entire working day each week in simply staying up to date with regulatory changes and assessing their impact on the business. • At the same time, compliance teams report difficulty finding time to coordinate with other parts of the company involved with managing regulatory risk. More than half of compliance professionals surveyed said they spend less than one hour a week working together with internal audit colleagues. One-third of respondents say they similarly spend less than one hour a week consulting with their legal and risk teams. • While keeping executive management informed of regulatory issues is a key part of the compliance role, more than a quarter of respondents say they spend less than one hour a week reporting to their boards. In the U.S., more than half of the companies surveyed spend less than one hour a week reporting to their boards. This raises concerns about whether executive management is being kept sufficiently informed on compliance issues Compliance Teams Stretched to their Limits (March 13th, 2012 by Corporate Compliance Insights and Cost of Compliance Survey 2012 by Thomson Reuters ACCELUS)
  • 4. ACS Today Profile • Sales: $15.5B • 70,000 Employees • Technology, leading brands • Large installed base Strengths • Security, ECC, Life Safety • Global reach 41% 36% Growth • 164 countries served • > 2M ship to addresses Focus • 54 acquisitions since 2003 • 110 ERPs ECC S&C HLS HBS HPS HSG HSM Buildings Fire/Smoke Process Sensors Controls Thermostats Motion / Human Speed and Position Presence Sensors Building Sensors Scanning System & Automation Panels Instant Pressure Alert Mobility Sensors Water Control CCTV/ Gas Detection Voice Picking Gas DVR Distributed Personal Satellite Valves Control tracking Military Sensors Industrial Burners Control Personal Protection Systems Mobile Computing Comprised of 93 Supply Chains, 118 Plants, 93 DC’s, 9 Integration Centers
  • 5. Background Distribution Footprint 219 Global Locations Distributing Product 118 Factories - 93 DC’s - 9 Integration Centers
  • 6. Honeywell – Corporate Policy “Honeywell will comply fully with all applicable export and import control laws and regulations of the United States and of all countries in which it conducts business.” • Customs laws • Requirement to declare goods accurately on importation – classification, valuation, country of origin • Implies that our trade data is accurate – including sourced items! • Use free trade agreements legally and intelligently • Export control laws • Certain goods of strategic nature require government approval before export • Use of military components can “infect” non-military products • Restrictions on importing from certain countries – embargoes • Other government agency (OGA) requirements • ACS now faces permitting requirements in US/ MXon health/medical products in HSP – eyewash, first aid kit elements, ibuprofen, etc.
  • 7. ACS Trade Service Offerings Team Vision: Objective A collaborative ensemble of Build a global compliance professionals partnering with infrastructure; enable rapid trade Honeywell colleagues to efficiently problem-solving; continuously transact business across national Enabling Growth improve cross-border productivity borders as advantageously as •Export De-control and Licensing and operations; and eliminate possible for Honeywell, our •Customer Duty Preference Request customers, and our suppliers while •Transaction Structuring and Approvals regulatory barriers to growth. •Regulatory Advice, Advocacy, and Rulings obeying international trade rules. Productivity and Operational Support • Duty Avoidance and Incremental Duty Savings • Broker Management and In-house Customs Brokerage • Software and Automation • Product-line Moves and Technology Collaboration • Supply-chain Security • Direct Shipments/ Cross-dock Operations • Sourcing Decisions/ Vendor-managed Inventory Ensuring Compliance with International Trade Rules Mitigating Risk of Non-compliance • Standardized Internal Controls Government Inquiries and Audits • HS and ECCN Classification Government Disclosures • Internal Risk Assessments and Remedial Action Plans • Submissions to Government Agencies and Post-entry Audits • Cross-functional Training • Pre-acquisition Due Diligence and Post-acquisition Integration Enabling Growth and Increasing Productivity from a Foundation of Compliance
  • 8. Components of Honeywell EU Trade Strategy CENTRALIZED CUSTOMS • Optimized trade operations AUTHORIZED ECONOMIC OPERATOR CERTIFICATION • Faster border crossings • Smoother customs operations CUSTOMS BROKER Automated Trade MANGEMENT • Trade documents • Control entries • E-Filing • Measure Brokers • Preference calculation • Assure compliance • De-minimis calculation • Maximize duty savings • Export control • …. TRADE MASTER DATA MANAGEMENT WRITTEN PROCEDURES • HS and ECCN Classification • Written procedures • Net weight • Develop training • Origins • Establish accountabilities Driving to meet EU requirements
  • 10. CP/S Modell for EU TRADE Solution Automation and Control Solutions Web-Order Delivery EDI-Order Order entry Picking Packing Shipping Master Data LINK-Order creation Transaction G Freight cost Automated Screening calculation Customs Freight Export Freight Audit EU PCT Forwarder G Documents & Payment Caclulation Integration G = GLOBAL used Automated Tool Partners Other SAP + Roles and Content from external source
  • 11. SAP GDM Trade Compliance and Solutions SAP CP/S NA TRADE Docs XI - Gateway SAP Pref Calc. Automated Specific Automated Systems Trade Solutions at De-minimus. EU sites Export Documents Global DPL Screening EU Export Documents ECCN Shipping License EU Electronic -Customs NAFTA Calculation,, EU DG Documents Shipping docs , ….. Landed cost calculation EU Preference Calculation + docs
  • 12. ACS Intranet Trade solutions
  • 14. Customs Issue Log 14 HONEYWELL - CONFIDENTIAL File Number
  • 15. Metrics Web Tool 15 HONEYWELL - CONFIDENTIAL File Number
  • 16. AEO 16 HONEYWELL - CONFIDENTIAL File Number
  • 17. Customs Compliance Assessment • Rolling out EU compliance self-assessment • Assess gaps and overall readiness for AEO • Traffic light report • Improvement plan Traffic light report and improvement plan
  • 18. Automated Customs Solutions
  • 19. Electronic customs filing • Limited to exports (interfaced with SAP) - Export declaration filing • Export Trade documents - Commercial (Customs/shipping) invoice - EUR.1/A.TR - COO - LTDO (Long Term Declaration of Origin) 19 HONEYWELL - CONFIDENTIAL File Number
  • 20. Automated Preferential Process Flow in FTA - (exporting plant point of view) Vendor Customer Customer Vendor ? Business Task 1 Business Task 2 Business Task 3 Vendor Declaration Preference Calculation Management Proof of Origin Sales Product XYZ documentation Look up missing/expired VDs BOM Shipping Plant S1 S2 S3 •Declaration of Origin Dunning/Solicitation ? on the Invoice or Packing list C11 C21 C31 • Fax, E-mail C12 C22 C32 •European docs: EUR1, A.TR •Printing …………………. •Long Term Declaration (LTD) •Portal E1 E2 … E3 E4 E5 Get VD ? MX EU CN ? Proof of Origin Legal Rules of Origin for Preference Calculation
  • 22. CP/S Global Design Model - Export  Global Design Model - Export: The ACS global export design model consists of an integrated solution managed by Automated Tool with SAP hold management.  3 TRADE APPROVED solution variants  Solution based on regional requirements and site risk profile Export Control Function: Gold Silver Bronze Restricted party screening via Automated Tool with soft alerts Restricted party screening via Automated Tool with hard blocks SAP Embargo controls with hard Blocks SAP Embargo controls on returns with hard blocks Foreign trade data missing with hard blocks (ECCN, HTS or COO) Missing end user or end use results in hard blocks Automated Tool license determination with hard blocks Automated Tool license management and decrementing SAP license determination with hard blocks SAP license management and decrementing Material master fields for ECCN, HTS and COO SAP or automated export tool docs (C/I and SLI)
  • 23. Sensitive country analysis - Origin Qualify Honeywell for sales by verifying non-US content Automation improves visibility on flows and costs and increases compliance level and generates savings and realizes growth
  • 24. What is denied party screening & why is it required? • Export control laws make it unlawful for Honeywell US and its non-US subsidiaries to conduct business with entities that - violate export regulations; or - are involved in proliferating weapons of mass destruction; or - Are involved in narcotics trafficking; or - represent embargoed or terrorist-supporting countries. • Honeywell is liable if it does business with an entity involved in these activities. We cannot avoid liability by saying that we did not know of their activities. • The Tool provides several lists that includes the names, addresses and reason for denial for all restricted organizations, companies and individuals. All end users must be screened against these denial lists to ensure compliance!
  • 25. How does this impact our job & what to expect? • Customer and Vendor Account Creation – When creating customer and vendor accounts – immediate transfer to Automated Tool for denied party screening (DPL) – If Automated Tool determines that there is a match, then order cannot be placed using this party until the DPL hit has been resolved in Automated Tool • Order Entry – Party Creation at Order Level (Sales and delivery order) – If a customer is added ad hoc at the order level, then party info transferred to Automated Tool immediately for DPL screening – If Automated Tool determines that there is a match, then a delivery block will be created on the line items in the order until possible match resolved in Automated Tool. • The SAP user will be notified via warning messages of any DPL matches, as well as daily summary reports e-mailed to a designated mailbox. – If a parties is changed after delivery, then the export docs and PGI will be blocked and the user will receive a workflow message
  • 26. Lessons learned • Change management - From fully outsourced trade compliance to semi-outsourced  Business do underestimate the impact  Automation doesn’t mean that everything is automated: e.g.: • Trade Data Management: garbage in garbage out • Export control » Before: no order screening only manual party screening » Automated Tool: order screening => increased involvement by entities and functions: Sales, Order Admin and purchasing » “One time only” customers : repeated false hits • Customs » Stricter processes (“less” flexible): people do complain » PCT: discipline on trade data management up to 26 level of components HONEYWELL - CONFIDENTIAL File Number
  • 27. Benefits • Increased compliance level - Helps for AEO-certification • Increased awareness across functions - Better visibility: Trade compliance more then just “stamping” documents - Increased understanding and appreciation of our function - Trade also means sales not just blocking or fire fighting • Better reporting to senior management - Metrics for senior management - Duty savings reports - => part of quarterly meeting reviews with CEO • Funding to get additional resources • Funding to get more and better automation 27 HONEYWELL - CONFIDENTIAL File Number
  • 28. Non Productivity vs. Productivity – Conclusions ACS would incur $110M in Annual Duty Costs If It had No Global Duty Avoidance Program Year Import Value Duty Spend Duty Saved Duty Liability Duty Ratio 2011 3,474,646,476 59,807,627 50,689,151 110,496,778 3.18% 2010 3,142,132,983 57,035,301 53,368,281 110,403,582 3.51% ACS Duty Spend is $51M Annually Because of its Global Duty Avoidance Program Year Import Value Duty Spend Duty Saved Duty Avoided per $1 Import Actual Duty Ratio Value 2011 $3,474,646,476 $59,807,627 $50,689,151 85 cents 1.72% 2010 $3,142,132,983 $57,035,301 $53,368,281 93 cents 1.82% 46% Reduction in Duty Liability achieved through our Duty Avoidance Mechanism
  • 29. 2011 Productivity Import Volumes in USD Duties paid in USD Country Import Value 2% 30 3% Country Duty Paid Millions 42% US 1,554,275,102 4% 7% US 25,258,564 25 MX 686,677,631 MX 584,716 20 CN 402,811,856 7% 45% CN 4,352,089 CA 248,372,627 15 22% CA 2,756,762 GB 140,055,300 12% GB 4,452,195 10 15% IN 122,098,503 IN 13,085,576 7% 7% DE 75,202,161 20% DE 426,402 5 5% 1% 1% Other 245,153,296 Other 8,891,323 0 TOTAL 3,474,646,476 US MX CN CA GB IN DE Other TOTAL 59,807,627 US MX CN CA GB IN DE Other Duty Rates in USD Duty Savings in USD Top Importing Countries Country Import Value Duty Paid Duty % Country Savings Program Duty Savings US 1,554,275,102 25,258,564 1.63% US 15,383,204 Processing 19,069,415 MX 686,677,631 584,716 0.09% MX 10,910,333 NAFTA 17,317,626 CN 402,811,856 4,352,089 1.08% CN 9,254,410 Duty Drawback 8,814,864 CA 248,372,627 2,756,762 1.11% CA 1,491,493 FTZ/Bond 2,081,102 GB 140,055,300 4,452,195 3.18% GB 1,640,856 Other FTA/GSP 1,672,972 IN 122,098,503 13,085,576 10.72% IN 10,358,852 HTS 285,373 DE 75,202,161 426,402 0.57% DE 855,381 EU Charlton House 280,125 TOTAL 3,474,646,476 59,807,627 1.72% Other 803,620 Other 179,680 TOTAL 50,689,151 TOTAL 50,698,151 Highest Duty Rate % Country Import Value Duty Paid Duty % AR 5,837,970 892,968 15.30% BR 26,673,072 3,644,519 13.66% VE 2,765,852 334,892 12.11% IN 122,098,503 13,085,576 10.72%
  • 30. Next Steps – wish list • Broker Management - Two way interface : PO’s and metrics reporting - Import metrics  Duty savings and risk assessment tool  Reporting • Trade data improvements - Global HTS-classification tool - Origin solicitation and management • Further improve our intranet tools 30 HONEYWELL - CONFIDENTIAL File Number
  • 31. Any Questions? We’ll always try to answer and support the business but answer can be dependent from support of others 31 HONEYWELL - CONFIDENTIAL File Number
  • 32. Thank you for your attention. Bruno Fransman Global Customs Compliance Director Bruno.fransman@honeywell.com +32 2 728 20 38