ISM Chemical Group Winter Conference New Orleans

1. ISM Chemical Group Winter Conference New Orleans Thomas A. Cook American River International February 2009 ARI 2009

2. Trade Compliance in Global Supply Chains: Structuring a Successful Program Why even engage in this subject? • Government Mandates: Due Diligence, Reasonable Care and Supervision & Control • Management Oversight • SOX ARI 2009

3. Agenda • Eight Step Process • Key Issues related to the Chemical Industry ARI 2009

4. Eight Step Process • Senior Management • Point Person and Committee • Information Flow & Benchmarking • Point Person … Training • Action Plan • SOP’s • Technology • Implementation and Connectivity … Training & Education ARI 2009

5. Senior Management • No shot without their support • Costs and Infrastructure • Penalties, Consequences and Benefits • SOX ARI 2009

6. Point Person and Committee • Logistics, Supply Chain: Qualified Personnel • Supported by a Committee … crossing all lines in the Organization ARI 2009

7. Information Flow & Benchmarking • Regulatory Issues • Where are you at? • Facilities Review • Use of outside consultant or expertise to provide necessary support ARI 2009

8. Point Person: Training • Wealth of Information • Train the Trainer • Licensed and Certified • www.compliancemaven.com ARI 2009

9. Action Plan Responsiveness to the Benchmarking Developing Actions Prioritizing Who will do what by when Management Tool for Accountability/Responsibility ARI 2009

10. Standard Operating Procedures (SOP’s) • Organizes and standardizes what the company needs to do • Meets government guidelines • Mitigates government review and scrutiny • Mitigates dependency on key personnel • SOX, ISO and other internal business process ARI 2009

11. Technology • Reduces opportunity for human error • Makes for more efficient systems in global supply chain logistics and operations • Necessary to reduce costs and personnel count • Allows global interface of all “connections and parties” in import and export activities ARI 2009

12. Implementation and Connectivity: Training and Education • Execution of the Action Plan • Implementation of the SOP’s and new business process’s • Training and Education of all direct and indirect personnel: purchasing, sales, operations, senior and middle management, finance, legal, etc ARI 2009

13. Current Issues • Since 9/11 … over 109 Regulatory Changes in Global Supply Chains • Chemical Companies - Post 9/11 Commission - Bio-Terrorism Act - ISF (10 + 2) - FDA Prior Notice - International Ship and Port (ISP) ARI 2009

14. Current “Hands-On” Issues • AES • USPPI • Deemed Exports • FCPA • Denied Parties • SOX • Wood Packing • CSI • 24 Hour Manifest • Focused Assessments: Documentation, HTSUS Classification, Origin, Material Data Safety, and Record Keeping • C-TPAT • INCO Terms • ISF • TSA Screening ARI 2009

15. Summary • Proactive Trade Compliance is a Responsible Path • Risk Management Approach • Follow the Steps … over 370 companies, approximately 20% of Fortune 1000 • Benefits: Supply Chain Stays Open, Reduce Threats, Fines and Penalties … More efficient run Global Supply Chain ARI 2009

16. Speaker Bio and Contact Information Thomas A. Cook Tom has been involved in Global Trade for over 30 years in the field of supply chain management, logistics and trade compliance. He has authored over 9 books on International Business … the most recent Managing Global Supply Chains: Compliance, Security and Dealing with Terrorism. Tom is Managing Director of American River International, a boutique and specialized logistics provider and consultant engaged in global trade management. Tom can be reached at … 1-800-524-2493 or at tomcook@americanriverintl.com ARI 2009