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CTPAT Practice Guidelines Required Document List Record Documents Regarding Container Sealing (including license plate, cargo number and seal number) Record Documents for Incoming/Outgoing Goods (mainly finished products) Record Documents for Incoming/Outgoing Processed Materials Record Documents for Raw Materials Documents provided by customers, including details security rules, specifications and product specifications Employee Personnel Record Factory Regulations and Rules Detailed Security Rules and Manual for Workers 24hr/day Security Shift Record Day-to-day Incoming/Outgoing Vehicle Record Visitor Record Post certificates for security guards and documents provided by local governmental authorities verifying their identify Chapter 1: Guidelines for Security and Safety Work Purpose The purpose of these procedures is to ensure that we comply with US Customs CTPAT (Customs-Trade Partnership Against Terrorism) security guidelines in the process of our product production, storage and transportation in an attempt to avoid delayed customs clearance at transport customs outside USA or to prevent thieves or terrorists from taking advantage of the above aspects to smuggle contraband goods into the United States. Scope These procedures are applicable to all safety maintenance activities of our Security Dept within the factory. Responsibilities It is the responsibility of the Security Manager to take charge of security planning and arrangements in the factory area. Reference Documents CTPAT – US Customs-Trade Partnership Against Terrorism guidelines. Procedures Security Training All security personnel are required to receive security education and trainings on recognizing hidden risks and identifying internal conspiracies. Contents of training include: fire safety, antiterrorism, check on incoming/outgoing personnel and vehicles, and security maintenance in factory area. Security Maintenance in Living Area All employees are required to show valid employee cards (ID cards) when entering and going out of the factory area. For those without such cards, security guards should conduct relevant cross-examination and keep them out. Visitors are required to explain reason(s) of visit to security guards and complete “Visitor Record”; after that,

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CTPAT Practice Guidelines

Required Document List

Record Documents Regarding Container Sealing (including license plate, cargo number and seal number)

Record Documents for Incoming/Outgoing Goods (mainly finished products)

Record Documents for Incoming/Outgoing Processed Materials

Record Documents for Raw Materials

Documents provided by customers, including details security rules, specifications and product specifications

Employee Personnel Record

Factory Regulations and Rules

Detailed Security Rules and Manual for Workers

24hr/day Security Shift Record

Day-to-day Incoming/Outgoing Vehicle Record

Visitor Record

Post certificates for security guards and documents provided by local governmental authorities verifying their identify

Chapter 1: Guidelines for Security and Safety Work

Purpose

The purpose of these procedures is to ensure that we comply with US Customs CTPAT (Customs-Trade Partnership Against Terrorism) security guidelines in the process of our product production, storage and transportation in an attempt to avoid delayed customs clearance at transport customs outside USA or to prevent thieves or terrorists from taking advantage of the above aspects to smuggle contraband goods into the United States.

Scope

These procedures are applicable to all safety maintenance activities of our Security Dept within the factory.

Responsibilities

It is the responsibility of the Security Manager to take charge of security planning and arrangements in the factory area.

Reference Documents

CTPAT US Customs-Trade Partnership Against Terrorism guidelines.

Procedures

Security Training

All security personnel are required to receive security education and trainings on recognizing hidden risks and identifying internal conspiracies. Contents of training include: fire safety, antiterrorism, check on incoming/outgoing personnel and vehicles, and security maintenance in factory area.

Security Maintenance in Living Area

All employees are required to show valid employee cards (ID cards) when entering and going out of the factory area. For those without such cards, security guards should conduct relevant cross-examination and keep them out. Visitors are required to explain reason(s) of visit to security guards and complete Visitor Record; after that, security guards may notify relevant employees who should show notes issued by manager or factory director and conduct relevant registry at Security Office before ushering any visitor into the living area.

Security guards should maintain security in the living area, have employees observe Dormitory Management Regulations, solve disputes between employees and maintain normal living order.

Security guards should conduct unscheduled check on dormitory. Once they find strangers there, they should cross-examine them immediately, handle them correspondingly and report to local public security bureau or police station for serious cases.

Security Maintenance in Factory Area

All employees are required to show valid employee cards when entering and going out of the factory area or they should be cross-examined and kept out of the factory area. To leave factory area during working hours, employees should show Leave Permit issued by department director or supervisor.

Visitors are required to explain reason(s) of visit at Janitor Office and complete Visitor Record. After that, security guards may notify relevant personnel by phone, issue VIP Card to visitors as appropriate and decide whether to escort them based on actual needs.

For incoming and outgoing vehicles, security guards should conduct relevant registry in Record for Incoming and Outgoing Vehicles and issue Driver Card when appropriate; release vehicles in compliance with Leave Permit issued by warehouse, take back Driver Card and record time of departure.

Security guards should keep monitoring on goods loading/unloading zones, goods yards and parking places and keep untrained or unauthorized personnel from entering such zones.

Security guards should conduct scheduled patrol in factory area, cross-examine persons without valid certificates, keep relevant records and report to local authorities for serious cases.

Security guards should implement Safety Improvement Plan, maintain safety in factory area, conduct internal safety check on quarterly basis and report relevant findings to security manager.

Supervision on Goods Loading and Unloading:

When loading goods in goods loading zone, security manager or his representative should conduct onsite supervision. Unauthorized personnel or vehicles are not allowed to enter such zones.

After loading is complete, security guards should lock them up immediately, and make sure that drivers send goods to factory after they obtain transport sheet or report sheet issued by warehouse.

Security manager or his representative should maintain supervision on incoming materials in unloading zone and forbid materials without shipping list to enter warehouse.

Dismissed Employees:

Personnel Dept should provide the name list of dismissed or discharged employees. Security guards should supervise such employees when they are packing their belongings and going through relevant procedures, arrange for them to leave after work, conduct check and cross-examination when they are leaving and take back their employee cards.

After dismissed employees leave factory, security guards should keep them from reentering factory area.

Fire Control:

Security guards should conduct monthly check on fire equipment and submit written report to factory director once they find out any outdated or damaged fire facilities.

Training on fire control and exercises on fire escape twice every year.

Records:

Training Record

Visitor Record

Record for Incoming and Outgoing Vehicles

Chapter 2: Computer Security Management System

Computer equipment in this document includes computer equipment in Computer Room and computer equipment installed by Computer Room in other departments or units.

Requirements:

Software driver or CD-ROM is not installed in ordinary operation departments. For computers installed with software driver or CD-ROM, Virus Killer software should be used every time when CD is used.

For Web-based computers, no one is allowed to copy software or files to computer without authorization.

Data backup should be managed by relevant personnel and floppy disk used for backup should be provided by designated person in charge.

It is required to ensure floppy disk and CD are free from virus before use.

Antivirus software should be installed in computers and for confidential computers, protection software such as Firewall should be installed.

Once virus is found in computers, it is required to report to Computer Room personnel for corresponding handling.

Before leaving, operators should exit systems and shut off computers.

No one should use others computers unless approved by relevant operators.

Supervisory Measures:

It is the responsibility of the designated person to conduct protection test and cleanup for all computers.

It is the responsibility of the designated person of Computer Room to conduct checks in compliance with the above work plans.

It is the responsibility of the manager to supervise the implementation of the protection measures.

Computers in which software driver is installed cannot be networked. For computers that are not networked, Computer Room should be responsible for software installation. To install software for any computer, relevant personnel should submit written report and Computer Room should conduct such installation upon approval by manager. In case of any anomaly for software, it is required to notify relevant personnel in Computer Room. No game software should be installed in any computer. Data backup should be managed by relevant personnel and floppy disk used for backup should be provided by designated person in charge.

Hardware maintenance personnel should take necessary antistatic measures when disassembling computers and reassemble those disassembled computers after work and before leaving. Relevant personnel should take practical measures to ensure proper use and maintenance of the computers and auxiliary equipment under their care. Relevant personnel should take necessary measures to ensure that all computers and peripheral equipment are always in neat and good condition. Computers with locks should be locked after use and before operators leave. All critical computers should have relay protection power as appropriate.

Relevant personnel should ensure proper use, cleaning and maintenance of all computers in relevant departments; frequently check the conditions of computers and peripheral equipment under their care; try to find out and solve problems in a timely manner.

Computer equipment is gradually becoming an indispensable part of our work. Based on this, Computer Dept has decided to incorporate computer management into the scope of performance assessment for relevant personnel and strictly implement this management.

In case of any one of the following circumstances, Computer Dept will investigate into such cases and hold relevant personnel and direct leader responsible as the case may be.

Computer affected by virus.

Unauthorized installation and use of unauthorized software (including game software).

Failure to use password function available in computers.

Failure to exit systems or shut off computers before leaving.

Unauthorized use of others computer or peripheral equipment, resulting in adverse effect or losses.

Failure to check or clean computers or relevant peripheral equipment in a timely manner.

Relevant personnel should be held responsible for damage or losses to hardware arising from the following circumstances.

Failure to operate in compliance with instructions.

Improper maintenance.

Unauthorized installation and use of hardware and electric devices.

Employees e-mail may bring about several types of security vulnerabilities for corporate network. For example, when receiving unwanted e-mail, they directly open its files without any vigilance or they directly open its files without scanning whether such files contain virus. Besides, if we fail to send latest Virus Library to employees computers and compulsorily implement our policies but let employees freely update their Virus Library in their computers, then, there exists some risk for virus attack even if employees cautiously scan and open files every time after determining there is no virus in such files. Whats worse, if unwanted e-mail, pornographic contents or other invasive contents run in offices uncurbed, we are likely to face many legal issues.

Password is the key vulnerability for most enterprises because many employees often share password or use simple password for the purpose of saving time. If password is too simple, it tends to be guessed out by others and used to steal information. There are other network security vulnerabilities. If users are not cautious enough, their password can be easily disclosed to others when they use some kind of trickery. For example, they can easily get employees password via phone call or e-mail as a disguise.

Employees completely dont know how to protect against security vulnerabilities. If employees password is defrauded by others, corporate portal will be open unprotected and susceptible to various types of attacks. Untrained employees or employees who are not satisfied with their jobs are more likely to disclose our exclusive or sensitive information to our competitors or those who should not access such information.

Our enterprise should decide who will be responsible for formulating and implementing our key policies. HR Dept should, in written form, let employees know about corporate policies through new employee training, require employees to sign and confirm that they know about and are willing to comply with corporate policies, and then, strictly implement corporate policies and regulations without any exception. When enacting such policies, the company should clearly define detailed rules for punishing those who violate such policies. Generally, security system and network management personnel should establish security protection mechanism, set up contingency groups to handle possible vulnerabilities, closely coordinate with HR Dept and report suspected situations on timely basis.

Network Maintenance

It is required to formulate procedures stipulating the use of Internet and have employees know about regulations governing their use of e-mail and computers. In addition, clear procedures stipulating the use of Internet can improve the efficiency of IT personnel in setting up and monitoring network security plans.

It is required to use technologies that can scan whether e-mail contains improper contents and record networking act against corporate regulations.

According to legal experts, monitoring employees e-mail and networking act may help protect corporate rights and interests in legal proceedings. Therefore, we should establish corresponding procedures and implement content-supervising mechanism to protect employees from disturbance.

It is required to train employees how to download latest antivirus information and how to determine whether their computers have virus, and teach them how to scan before opening files whether such files contain virus.

It is required to patch software vulnerabilities to reduce the possibility for virus to access corporate network via network interface or e-mail.

It is required to formulate password specifications, require employees to change password frequently, teach them how to protect against social frauds and require them not to disclose password in any case.

It is required to determine whether specific employees need to access confidential information and ensure confidential information is only open to those employees who absolutely need such information in their work.

It is required to warn employees of the risk resulting from various procedures such as downloading free software.

Chapter 3: Responsibilities For Security Posts

Purpose

The purpose of this responsibility document is to ensure that security personnel at different security posts clearly know about their responsibilities and attentively perform their functions to prevent the occurrence of accidents and maintain safe production and living environments. This responsibility document is applicable to all security posts in the factory. It is the responsibility of security manager to manage employees at all security posts in the factory. Security guards should attentively perform their post functions and obligations.

Scope

When receiving visitors, security guards should be polite and cordial to visitors, ask them to show their employer certificates or personal certificates and inquire why and who they will visit. Upon the approval from those they want to visit, security guards should record details in Visitor Record and issue VIP Card to them. For first-time visitors, security guards should escort them to relevant office.

Procedures

It is required to check visitors luggage and parcels but attention should be given to the following aspects:

Avoid contacting their body.

Mainly check if incoming visitors are bringing hazardous goods or unidentified articles into the factory and check whether outgoing visitors are taking factory property out of the factory, including corporate products, materials, semi-finished products or operating devices.

Be polite and friendly when checking, avoid arousing misunderstanding or disgust in them, explain politely when necessary and ask them to understand.

Incoming/Outgoing Vehicles

For transportation vehicles or business-related vehicles to enter factory area, it is required to check drivers valid certificates and shipping list, and carefully check if goods on vehicles are consistent with shipping list. In normal situation, it is required to record in Record in Incoming and Outgoing Vehicles and issue Driver Card to drivers. For outgoing vehicles, it is required to check leave permit and shipping list issued by Warehouse Dept, check if there is any abnormal goods in drivers cabs and cross-check shipping list with goods on vehicles. If goods are consistent with shipping list, take back driver cards, release such vehicles and keep records.

Factory Vehicle Management

It is required to intensify management on factory vehicles. To get released, outgoing vehicles to deliver goods should have leave permit issued by warehouse and approved by warehouse supervisor and it is required to check if carriage door is locked. For cargo-free vehicles as indicated in leave permit, it is required to check if there is any cargo on such vehicles.

Forbidden to Take Food into Factory

Employees are forbidden to take food into factory area or to enter or leave factory area during working hours. If they have to enter or leave factory area under special circumstances, they must have valid leave permit issued by department supervisor or higher-level personnel and record should be made.

Weather Conditions

Security guards for night shift and morning shift should turn on and turn off lights in factory area depending on actual weather conditions.

Check for Water, Power and Door/Window

Security guards should check for water, power and doors/windows in each workshop. In case of any abnormality, they should report so immediately and make relevant records.

Responsibilities

Before leaving, security guards on duty should go through handover and takeover procedures for takeover security guards, including:

To complete procedures stipulated or instructed by superiors.

To explain that incoming visitors or employees are still in factory.

To hand over delivered or deposited goods.

To tell the next security guard to supervise or keep watch on suspected situations in factory.

Responsibilities of Security Guards on Duty

Security guards for warehouse should keep unauthorized personnel out of warehouse. For material-requisitioning personnel, they should carefully check if they have material requisition form.

Security guards should direct transport vehicles and container trucks to proper parking berths and then have drivers stay at specified lounging locations without letting them to go to workshop.

When external vehicles enter warehouse to unload goods, it is required to check if they have delivery sheets, verify such sheets with warehouseman and conduct onsite supervision in the process of unloading.

When container trucks enter warehouse to unload raw materials, it is required to check if sealing is in good condition or if packing is normal. In case of any abnormality or shortage, it is required to report so to security manager immediately.

When container truck enters loading zone to load goods, it is required to check if there are any abnormal goods in the loading zone, open containers to see if everything is normal and forbid unrelated personnel to access loading zone.

When loading containers, security guards should stay on site to closely oversee loading personnel and all goods loaded onto containers. After loading is complete, they should oversee relevant personnel taking photos, close container doors and check to make sure all procedures are completed.

Security guards should strictly execute dormitory gate access regulations; conduct checks on incoming and outgoing employees; refuse to let dismissed or discharged employees or unrelated personnel enter or leave through dormitory gate. For visitors to enter the factory under special occasions, they should show application forms signed by supervisor in factory office and security guards should check their valid certificates and belongings and record so in Visitor Record. Security guards should closely check the luggage and parcels of visitors and outgoing employees. In this case, outgoing employees should show leave permit issued by dormitory supervisor. However, attention should be given to the following aspects:

Avoid contacting their body.

Mainly check if incoming visitors are bringing hazardous goods or unidentified articles into the factory and check whether outgoing persons are taking factory property out of the factory, including corporate products, materials, semi-finished products or operating devices.

Be polite and friendly when checking, avoid arousing misunderstanding or disgust in them, explain politely when necessary and ask them to understand.

It is strictly forbidden to abuse this power to place obstacles intentionally.

Responsibilities of Patrolling Security Guards:

Patrolling security guards should tour the surrounding areas of the factory to prevent external personnel from throwing hazardous articles into the factory area; supervise employees compliance with the laws and prevent the occurrence of internal conspiracies and collusion between insiders and outsiders.

Patrolling security guards should check if personnel in factory area have ID cards. In case they find any personnel without ID cards, they should cross-examine them and report the case to security manager.

Conduct supervision on parking lot, stop nonconforming parking and forbid anyone to enter parking lot except drivers.

Conduct unscheduled check on attendance of security guards on duty and correct nonconforming act of security guards in a timely manner.

Conduct scheduled check on security facilities to find out hidden hazards and immediately report hidden hazards, if any, to security manager.

Chapter 4: Human Resources Security Procedures

Human Resources Security Audit Procedures

The purpose of formulating Human Resources Security Audit Procedures is to meet the requirements of US Customs CTPAT guidelines. These procedures are applicable to all employees. It is the responsibility of Personnel Dept supervisor to plan and supervise the implementation of the procedures and relevant departments should coordinate.

Recruitment

In recruitment, it is the responsibility of Personnel Dept supervisor or clerk to interview applicants, verify their ID cards and other valid credentials and issue Application Form to them if they are eligible in compliance with the Labor Law.

Application Form

Applicants should complete the Application Form with their personal resume, educational background, political background and specific address as the case may be.

Important Posts

For applicants for important posts (such as transport, warehouseman and porter), Personnel Dept should verify their identity and background via public security authorities and they cannot be offered such posts unless verified as eligible.

Training

It is the responsibility of the Personnel Dept to arrange training for new employees; enable new employees to establish an understanding of corporate quality system, quality policy, factory regulations and disciplines; issue New Employees Pre-job Rules in Fire Control and Hygiene and file their records in Personnel Dept.

Personnel Training

It is the responsibility of the Personnel Dept to organize training for new employees; arrange instructors to offer training on fire safety and antiterrorism, including such common sense as fire control, first aid and escape as well as identifying unauthorized access, reporting internal conspiracies, personal safety and risk awareness; and keep training records.

Survey

To conduct in-depth survey in employee groups and focus on investigating whether there is any suspected phenomenon or cliques among employees.

Special Jobs

For employees for special types of jobs (such as transport, warehouseman and porter), Personnel Dept should verify their identity and background via public security authorities and verify whether they have criminal records or belong to unidentified party or have any complicated social relations.

Safety Reporting

To encourage and motivate employees to report against terrorism; try to find out, investigate and handle abnormal conducts and suspected objects in a timely manner; and protect those who report and keep their reporting undisclosed.

Chapter 5: Guidelines for Personnel Dept

Purpose

The purpose of these procedures is to define the responsibilities and arrangements of Personnel Dept in human resources recruitment, training and appraisal in an attempt to standardize our personnel management system.

Scope

These procedures are applicable to Personnel Dept.

Responsibilities

It is the responsibility of the Personnel Dept supervisor to establish the personnel management system, plan and implement personnel training and appraisal.

It is the responsibility of Personnel Dept clerk to implement new employee recruitment and training, and manage employees archives.

It is the responsibility of the manager to review and approve the personnel management system and training programs.

Procedures

Employee Recruitment

When it is necessary to recruit new employees based on production needs, relevant departments should submit written application to Personnel Dept supervisor and the Personnel Dept supervisor will formulate conditions for recruitment and the number of new employees to be recruited and submit them to manager for approval.

After approval, Personnel Dept issues recruitment notice to recruit new employees from the public.

Applicants are escorted by security guards to Personnel Dept. Personnel Dept supervisor or clerk will interview applicants and review their ID cards and other valid credentials, and issue Application Form to those eligible in compliance with the Labor Law concerning such conditions as employment age.

Applicants should complete the Application Form with their personal resume, educational background, political background and specific address as the case may be.

For applicants for important posts (such as transport, warehouseman and porter), Personnel Dept should verify their identity and background via public security authorities and they cannot be offered such posts unless verified as eligible.

Training

It is the responsibility of the Personnel Dept to arrange Grade I training for new employees; enable new employees to establish an understanding of corporate quality system, quality policy, factory regulations and disciplines; issue New Employees Pre-job Rules in Fire Control, Hygiene and Safety and file their records in Personnel Dept.

It is the responsibility of the Personnel Dept to organize Grade II training for new employees; arrange instructors to offer training on fire safety and antiterrorism, including such common sense as fire control, first aid and escape as well as identifying unauthorized access, reporting internal conspiracies, recognizing personal safety and risk awareness; and keep training records.

It is the responsibility of Personnel Dept to prepare corporate Annual Training Project and Program and submit it to manager for approval; organize and supervise the implementation of the program; and file Employee Training Record in Personnel Dept.

Archives Management

It is the responsibility of Personnel Dept clerk to manage personal archives of all employees and make reliable information available for inspection by labor and legal authorities.

Personnel Dept should keep Record for Dismissed Employees, clearly indicate names of such employees and the time and reason of their leaving and present relevant data to Security Dept for the purpose of avoiding reappointing those dismissed employees and preventing them from entering the factory area.

Personnel Dept may destroy personal archives and training records of dismissed employees but should permanently keep Department Employee Roster and Record for Dismissed Employees.

Dismissed Employees

The Personnel Dept should present the name list of dismissed or discharged employees to Security Dept and security guards should supervise such employees when they are packing their belongings when they are leaving and take back their employee cards.

Personnel Dept should not reappoint those dismissed employees after they leave the factory.

Record

Personal Archives

Application Form

Record for Dismissed Employees

Chapter 6: Security Guidelines for Shipping Dept

Purpose

The purpose of these procedures is to ensure that we comply with US Customs CTPAT (Customs-Trade Partnership Against Terrorism) security guidelines in the process of our finished product transportation in an attempt to avoid delayed customs clearance at transport customs outside USA or to prevent thieves or terrorists from taking advantage of the above aspects to smuggle contraband goods into the United States.

Scope:

These procedures are applicable to original manufacturers, warehouse personnel and transportation process.

Responsibilities:

It is the responsibility of the warehouseman to check data concerning transport vehicles and loaded goods.

Reference Documents:

CTPAT US Customs-Trade Partnership Against Terrorism Guidelines.

Procedures

Schedule for Goods Transportation:

After receipt of production order repeat order sheet issued by customers, Shipping Dept should submit production order documents to PMC Dept, and confirm unloading date specified or approved by customers.

After confirming actual unloading date with customers, PMC should submit to shipping company such information as unloading quantity, volume and destination. Shipping company should decide on Unloading Document number based on unloading documents, arrange and submit to Shipping Dept such documents as carrier name and forwarder. Shipping company should issue Unloading Document number and arrange carrier name. Carrier is required to arrange shipment.

After receipt of documents from shipping company, Shipping Dept is required to submit such documents as Unloading Document number and carrier name to relevant departments concerning Unloading Document number, carrier name and forwarder; communicate with such departments as shipping company, forwarder and PMC; and ensure goods successfully go through customs procedures when conditions are met.

Forwarder should arrange transport vehicles based on unloading date, load and transport goods in manufacturers warehouse department based on Unloading Document and Shipping Advice.

Warehouse Dept is required to review documents provided by forwarder to determine whether they can load goods.

After loading, Warehouse Dept should complete and sign Report Sheet and Consignment Bill and forwarder drivers sign Consignment Bill to confirm after verifying. This means consignment is successfully completed. Now, Warehouse Dept should fax to Shipping Dept the documents concerning goods transfer.

Record

repeat order sheet

Shipping Advice

Unloading Document

Consignment Bill

Chapter 7: Physical Security Procedures

Purpose

The purpose of these procedures is to take effective measures to ensure physical security for our company, resist unauthorized access and external invasion and ultimately, to ensure the safety of corporate property and employees.

Scope

The security procedures are applicable to all activities of all departments to maintain physical security.

Responsibilities

It is the responsibility of security manager and department supervisor to jointly plan and maintain physical security in the factory.

Procedures

Security Standards

All buildings should have strong red-brick walls and windows in goods storage zone should have firm anti-burglary nets.

Internal/external doors, windows, gates and railings should have sufficient locks.

All environments inside and outside buildings and parking zone should have sufficient safety warning signs.

All international, domestic, high-value and hazardous goods should be kept in safe places or isolated by other railing methods and properly identified.

Private car parking zone and transport vehicle parking zone should be separated from goods loading zone by railings and all railings should be 5ft high minimum.

CCTV systems should be installed in entire factory area, all gates and loading/unloading zones. Loading and unloading zones should keep video records for at least 31 days.

Factory gates should have 24-hour attendance by designated security guards. All environments inside and outside factory area and loading/unloading zones should be monitored by designated security guards.

Security Maintenance

Security guards should be reserved to intensify patrolling in factory area, ensuring all doors and windows are properly locked whether they are attended by employees or not.

CCTV monitoring system should have standby generator to provide emergency power supply and unauthorized access should be prevented. It is required to conduct preventive maintenance on the CCTV system at least once every three months.

Security manager should organize security guards to check and assess physical security measures in the entire factory each month.

When work is over and all employees have left, the following personnel of the following departments should check and ensure all doors and windows are properly locked:

Dept: Dept:

Dept: Dept:

Records

Monthly Internal Self-check Form

Chapter 8: Transportation Security Management Procedures

Purpose

The purpose of these procedures is to intensify security control on goods transportation, avoid goods loss and substitution in transit, prevent lawless gangsters or terrorist organizations from creating terrorist events and ensure successful and timely customs clearance.

Scope

All export goods should be loaded under the supervision of security manager or his designated representative. During the process of loading, strict monitoring should be maintained, no unauthorized personnel or materials should be allowed to approach or enter, and the entire process should be recorded.

Responsibilities

After loading/unloading, security manager or security representative should conduct further check and confirmation, and photos of goods should be taken. Photos should clearly indicate carton mark and shipping date. After all this is complete, it is required to lead-seal trucks and lock containers. Locking devices should contain one-off sealing strips with effective tamper-proof functions.

Reference Documents

After sealing and locking, high-definition and multi-angle photos should be taken for cargo trucks. Such photos should clearly indicate license plate, truck types, truck appearance, locking devices, labels and time of photographing.

Procedures

In transit, customs-declaration clerk of the factory should follow such trucks to customhouse, where customs-declaration clerk should make sure sealing strips are complete and in good condition, and cut them with scissors before delivering goods to customhouse.

Record

For each shipment, records, video records and photos should be maintained.

Chapter 9: Security Guard Training Procedures

Procedure 1

Security training should be offered to security guards twice every month for the purpose of intensifying their security awareness.

Procedure 2

When at work, security guards should be neatly dressed, well postured, wear post cards and employee cards.

Procedure 3

Security guards should observe disciplines, comply with regulations and rules, practice good working style, be polite and enthusiastic, and give detailed explanations to possible inquires.

Procedure 4

Security guards should strictly implement handover and takeover systems, take detailed records for affairs occurring for the current shift and hand over them for next shift to follow up.

Procedure 5

Security guards should improve their qualifications and security protection skills and try to foster capabilities for handling unexpected events.

Chapter 10: Security Survey & Handling Procedures

Procedure 1

The purpose of these procedures is to enable the company to investigate and handle all security-related events in a timely manner, minimize hidden hazards and prevent the occurrence of terrorist activities. These procedures are applicable to all our security-related activities. Security manager should plan and arrange the implementation of these procedures.

Procedure 2

It is required to conduct scheduled internal security check and report relevant results to security manager. For security-related issues, security manager should supervise and arrange timely investigation, conduct follow-up checks and ensure security-related event survey and handling reports are properly filed.

Procedure 3

When carrying out security patrol, security guards should stay alert, report to security supervisor (or security manager) when finding any security-related event is occurring or to occur, and immediately eliminate them when possible.

Procedure 4

For security-related events occurring in individual departments or areas, it is required to contact and inform Security Dept immediately. In case such events required immediate handling, relevant personnel may stay onsite to handle them. If such events require further investigation, relevant departments should coordinate with Security Dept in investigation, probe into handling proposals and submit such proposals for security manager to implement.

Procedure 5

We encourage employees to actively participate in security control and report security-related information. For information involving hidden hazards or even terrorist activities, it is required to stay highly alert and hand over such information to Security Dept for filing purpose. In this case, security manager should arrange investigations and handle such affairs cautiously.

Procedure 6

If security-related event involving serious issues or even violating the law is found out in security maintenance activities, Security Dept should contact public security and legal authorities in compliance with law and actively coordinate with them in handling such affairs.

Procedure 7

The investigation and handling of all our security-related events should be recorded and filed by Security Dept.

Chapter 11: Dismissed Employee & Terminated Customer Control Procedures

Procedure 1

The purpose of these procedures is to prevent dismissed employees and terminated customers from entering our factory area, and strictly meet CTPAT requirements concerning the control of unauthorized entry.

Procedure 2

These procedures are applicable to all our dismissed employees (including those who resigned, quit their jobs or were dismissed) and customers that have terminated contracts with our company (including suppliers and contractors).

Procedure 3

These procedures should be prepared by security manager and implemented by Personnel Dept and PMC Dept in coordination with Security Dept.

Procedure 4

When employees are dismissed, Personnel Dept should record so in Dismissed Employee Record, clearly indicate their names as well as when and why (how) they are dismissed, and present relevant documents to Security Dept.

Procedure 5

When quitting jobs or dismissed, employees should return their working clothes and hats to relevant workshops. Financial Dept should take back their employee cards before paying wages to them. When this is complete, such employees may leave the factory with Leave Permit issued by security manager. When leaving factory, their belongings should be checked.

Procedure 6

Security guards should keep close watch to keep out those who quit their jobs without permission and still hold employee cards. In this case, security guards may compulsorily take back their employee cards and refuse to let them in.

Procedure 7

Normally, dismissed employees should not be reappointed; and employees who leave the factory and quit their jobs without permission should not be reappointed within three months.

Procedure 8

PMC Dept should submit to Security Dept on timely basis relevant documents and information concerning suppliers, contractors and customers who have terminated contracts with our company for any reason, including such contents as customer name, date and reason of termination, and names of those business clerks who often visit our company. (Notice of Terminated Customers)

Procedure 9

After receiving the above notice, Security Dept may keep out such terminated customers when they ask to enter the factory area. If it is out of actual needs, they may enter the factory area after obtaining approval and showing Entrance Permit signed by security manager.

Chapter 12: Reception and Transport Procedures

Purpose

The purpose of these procedures is to standardize reception and transport activities, avoid goods loss or unauthorized access and meet the antiterrorist requirements of US Customs CTPAT.

Scope

These procedures are applicable to all warehousemen, drivers and other relevant personnel involved in reception and transport activities.

Responsibilities

Warehouse supervisor should plan and arrange goods transportation at warehouse and transportation should be performed by relevant drivers.

Procedures

Reception

Warehouse Dept and security manager or his designated representative should check all materials against Purchase Order issued by PMC and reject all materials with Purchase Order.

Incoming materials that have been verified should be placed in independent acceptance zone as soon as possible. It is the responsibility of IQC to conduct quality check on such materials and record results in IQC Check Report.

The quantity of incoming materials should be consistent with that specified in Purchase Order or Delivery Sheet. In case of inconsistency, Material Dept should conduct corresponding adjustment to avoid the entry of any materials without Purchase Order or loss to such materials due to theft or unauthorized requisition. For serious cases, it is required to report to factory office or foreign headquarter.

After check by IQC, eligible incoming materials should be placed in Accepted zones and suitable ID labels should be attached to them. Incoming and outgoing materials should be recorded in Material Storage Record for later tracking.

All storage environments should have firm doors and windows to prevent burglary and unauthorized entry. Warehouseman should check materials and report the results to the company or customer.

Goods Transport

For outbound finished products, warehouseman should check drivers transport advice and instructions issued by Shipping Dept (including Shipping Advice, Consignment Bill and container sheet) before loading.

For outbound transportation, general materials and semi-finished products can be loaded against presentation of advice issued by PMC or Shipping Dept.

Before loading, all containers should be clean and subject to routine check. When finding container doors are infirm or carriage is broken or untidy, it is required to report to warehouse supervisor and propose not to load goods.

When loading goods in loading zones, security manager or designated security personnel should keep watch to prevent unauthorized personnel or vehicles from entry.

After loading/unloading, it is required to lock trucks, attach one-off sealing strips and fill in transport sheet with seal number. Consignees should check whether transport sheet has been obliterated in transit and in case of anomaly, report to factory office and customer to discuss for possible solutions.

All vehicles should be managed by warehouse. Trucks should be parked in different zones. It is required to keep monitoring on truck parking zone to prevent unauthorized personnel from entry.

Chapter 13: Security Rules for Computer Application

Rules

To avoid damage to computer systems arising from artificial factors such as erroneous operation, ensure the security and proper operation of our computer systems and further improve our computer-based office efficiency, it is necessary to formulate corresponding specifications for secure application.

Dont try any computer operating procedures you are unfamiliar with. In case of any anomaly in computer that you cannot solve, notify Computer Room immediately for help from professionals.

Dont run or delete files or programs in computer or modify computer parameters.

Dont install or use software or program from unidentified sources or open e-mail or e-mail files from unidentified sources.

When receiving meaningless e-mail, delete them immediately and dont intentionally or viciously send them back or send them to others.

Never disclose password to others and prevent others from creating anomaly by accessing computer systems.

Change password frequently (once a month). In case password is disclosed, change it as soon as possible. Never use default password or password provided by others.

Scan computer system with Virus-Killer program on regular basis. For new software, files or e-mail, use Virus-Killer software to scan and check if they contain virus/hazardous programming codes, and conduct proper processing before opening them.

Use encrypted technology to protect sensitive data files before transmitting via Intranet and Internet. When appropriate, use digital protocol or add digital signature to encrypt information and data.

Close the function available in e-mail software to automatically process e-mail attachments and close the auto-processing function in e-mail application system or other application software to prevent virus invasion.

Offer regular training to all computer personnel on how to encrypt their personal files.

For computers for dismissed employees, computer supervisor should change their password and encrypt files in computer immediately.

Chapter 14: Security Management Responsibility System

Purpose

The purpose of establishing this responsibility system is to maintain our physical security, resist unauthorized access, prevent unauthorized personnel or vehicles from entry and ultimately, to ensure the safety of corporate property and employees.

Responsibilities

The responsibility of security manager includes:

To plan and maintain physical security in entire the factory, assess, review and plan improving and preventive measures on monthly basis.

To arrange work and training courses for security guards.

To mediate and handle safety-related accidents in factory area and attend governmental meetings.

The responsibility of security supervisor includes:

Carry out tasks assigned by security manager, directly supervise security guards in their work and listen to report concerning shift handover and takeover.

The responsibility of security guards includes:

On-post security guards should be responsible for the maintenance of the area behind factory building.

Patrolling security guards should take charge of day-to-day security work, including vehicle parking, supervision on drivers relaxation, monitoring on loading/unloading, turning on/off lamps in areas around the factory and checking if all doors and windows in workshops are properly locked after work.

On-duty security guards should check incoming and outgoing visitors and vehicles at factory gate, receive phone calls and perform registry for visitors.

Contact phone number of local law-enforcing authorities:

Police: 110

Fire brigade:119

Local police station:

First-aid hospital:

Town security/prevention office/Police zone:

Chapter 15: Warehouse Security Guidelines

Purpose

The purpose of these procedures is to ensure that our warehousemen comply with US Customs CTPAT (Customs-Trade Partnership Against Terrorism) security guidelines in the process of our product production, storage and transportation in an attempt to avoid delayed customs clearance at transport customs outside USA or to prevent thieves or terrorists from taking advantage of the above aspects to smuggle contraband goods into the United States.

Scope

These procedures are applicable to original manufacturers and warehouse personnel for their production, storage or transportation as well as their loading of goods, review and acceptance of incoming materials.

Responsibilities

Security manager is required to supervise the process of goods loading and the entry of visitors into the warehouse. Warehouse supervisor is required to check and accept loaded goods and incoming materials.

Reference Documents

CTPAT US Customs-Trade Partnership Against Terrorism guidelines.

Procedures

Security Training

All warehouse employees are required to receive security education and trainings on recognizing hidden risks and identifying internal conspiracies. Untrained or unauthorized personnel are not allowed to enter goods loading/unloading areas. All incoming and outgoing goods should be recorded.

Acceptance and Storage for Incoming Materials

Warehouse Dept and security manager or his designated representative should check all materials against Purchase Order issued by PMC and reject all materials with Purchase Order.

Incoming materials that have been verified should be placed in independent acceptance zone as soon as possible. It is the responsibility of IQC to conduct quality check on such materials.

The quantity of incoming materials should be consistent with that specified in Purchase Order or Delivery Sheet. In case of inconsistency, Warehouse Dept should conduct corresponding investigation to avoid the entry of any materials without Purchase Order or loss to such materials due to theft or unauthorized requisition. For serious cases, it is required to report to factory office or foreign headquarter.

After check by IQC, eligible incoming materials should be placed in Accepted zones and suitable ID labels should be attached to them. Incoming and outgoing materials should be recorded in Material Storage Record for later tracking.

Finished product warehouse should be managed by dedicated personnel and unauthorized entry is prohibited. When visitors or QC personnel enter the warehouse, they should be escorted by supervisor or higher-level personnel.

All storage environments should have firm doors and windows to prevent burglary and unauthorized entry. Warehouseman should check materials and report the results to the company or customer.

Outbound Goods Transport

For outbound finished products, warehouseman should check drivers transport advice and instructions issued by Shipping Dept before loading. Shipping instructions include Shipping Advice, Consignment Bill and container sheet.

For outbound transportation, general materials and semi-finished products can be loaded against presentation of advice issued by PMC or Shipping Dept.

Before loading, all containers should be clean and subject to routine check. When finding container doors are infirm or carriage is broken or untidy, it is required to report to warehouse supervisor and propose not to load goods.

When loading goods in loading zones, security manager or designated representative should keep watch to prevent unauthorized personnel or vehicles from entry.

When loading goods in loading zones, security manager or designated representative should keep watch to prevent unauthorized personnel or vehicles from entry.

After loading, warehouse supervisor is required to ensure the correctness of loaded quantity and lock it immediately. After confirmation by security personnel, drivers can obtain transport sheet or report issued by warehouse and transport goods out of factory.

If one-off sealing strips are attached to carriage, it is necessary to fill in transport sheet with seal number such that consignees can check whether transport sheet has been obliterated in transit. If they are obliterated, both sides should conduct investigation and report the results to factory office and customer.

Vehicle Management

All vehicles should be managed by warehouse. Passenger cars and trucks should be parked in different zones. It is required to keep monitoring on truck parking zone to prevent unauthorized personnel from entry.

Incoming trucks and containers should enter loading/unloading zone immediately. If there are too many loading trucks for the loading/unloading zone to accommodate, they should be parked in designated parking place which should be supervised by security guards.

Record

Visitor Entry Record

Material Loss Report

Record of Scheduled Check on Stored Materials

Chapter 16: CTPAT Security Control Procedures

Purpose

The purpose of these procedures is to ensure that we comply with US Customs CTPAT (Customs-Trade Partnership Against Terrorism) security guidelines in the process of our finished product transportation in an attempt to avoid delayed customs clearance at transport customs outside USA or to prevent thieves or terrorists from taking advantage of the above aspects to smuggle contraband goods into the United States.

Scope

These procedures are applicable to product production, storage and transportation by manufacturers and warehouse personnel outside USA.

Reference Documents

CTPAT US Customs-Trade Partnership Against Terrorism Guidelines.

Procedures

Human Resources Security Control

All employees are required to wear their employee cards when entering and going out of the factory area. For those without wearing such cards, security guards should conduct relevant cross-examination and keep them out. Visitors are required to explain reason(s) of visit to security guards and complete relevant registry; after that, security guards may notify relevant employees by phone, issue Visitor Card to visitors as appropriate and let them in or escort them in when needed.

New employees should have valid ID cards and fill in educational background, political background and detailed address. Those who fail to fill in the above basic contents correctly or cannot verify their true identity or social background should be excluded from recruitment.

Every new employee should receive pre-job training, including: factory regulations and disciplines, fire and hygiene knowledge, regulations on entry to important zones and goods storage as well as the method to report suspected person or suspected lawless act once they are found out.

It is required to set up employees complaint letterbox and encourage employees to report the above issues once they are found out.

For employees for important positions (such as transport, warehouseman, porter and loading/unloading), the company and relevant departments should verify their identity and background and verify whether they have criminal records or belong to any unidentified party.

Production Site Security Control

Materials released or requisitioned on production site should have reception/release documents and materials without such documents are prohibited for use on worksite. It is required to record the entry of unidentified materials and materials without documents, report to factory office and make adjustment for serious cases.

Nonproductive personnel are not allowed to enter worksite. Visitors on inspection, check and acceptance tour should be escorted by supervisor or higher-level personnel when they enter worksite.

It is required to designate personnel to manage packing zone. All finished products should be sent to finished product zone immediately. When finding finished product boxes are open, it is required to notify workshop supervisor, assign QC to check and place them in finished product zone after verifying them as accepted. Entry into finished product zone is prohibited without authorization.

The release, use and withdrawal of sharp objects should be recorded by designated person. It is required to collect broken sharp objects. If such sharp objects are not fully collected, it is required to report to leaders and record when and where such sharp objects were broken and record their codes.

Warehouse and Transport Security Control (Incoming materials, storage environment and shipping)

All materials entering warehouse should have corresponding documents. Warehouse personnel should check incoming materials against waybill and check report issued by IQC on quality before unloading. All incoming goods should be sent to independent acceptance zone as soon as possible.

Goods that have been verified by IQC as accepted should be sent to Accepted zones for storage and attached with proper labels, indicating their name, quantity, weight and date of warehousing. Material Storage Record may help track the incoming and outgoing of such materials.

Warehouseman should conduct scheduled check on materials in warehouse, complete Material Loss Report and report to factory office in case of any loss or shortage.

Storage environment in warehouse should have one (only one) approach through only one gate. Windows should be firmly closed to prevent entry from outside.

It is required to establish independent finished product warehouse and designate dedicated person to take charge. No entry is allowed without authorization. When visitors or QC personnel enter the warehouse, they should be escorted by supervisor or higher-level personnel.

Finished products and goods should have independent loading zones where no entry is allowed for unauthorized personnel and vehicles. Loading personnel are subject to direct management by warehouse and should receive training on security knowledge. After parking their trucks in proper parking place, drivers should stay waiting in suitable lounging place.

Warehouse supervisor should supervise loading process and prevent the entry of unauthorized personnel and vehicles as well as the occurrence of anomaly. When finding any anomaly or entry of unauthorized personnel into the loading zone, warehouse supervisor should stop them immediately and record what has happened as the case may.

Immediately after loading, warehouseman should seal and lock carriage doors to prevent them from being unlocked in transit. Drivers should not access such keys. For outbound export goods, warehouseman should attach factory seals and insert customs seals after customs check.

Comprehensive Environmental Security Control

CCTV system is installed in finished product warehouse to prevent pilferage in finished product warehouse.

CCTV system is installed in loading/unloading zones to monitor goods loading/unloading process and prevent the occurrence of lawless acts.

Cargo trucks entering factory area should not be parked in the same parking zone as private cars or passenger couches. Unauthorized personnel are forbidden to enter cargo truck parking zone. Warehouseman should keep close supervision on such zones.

Factory area should have sufficient lighting. Logistics Dept should assign persons on duty to tour factory facilities and establish attendance records in factory area.

Generator house should have standby generating system to provide sufficient power supply for lighting.

Access control should be established for cargo truck depot, warehouse and office zones, allowing no one to enter except authorized personnel and those who work in such zones. Preventive maintenance should be conducted on CCTV system at least once every three months.

Record

Records in CCTV system should be maintained for two months minimum.

Visitor records should be maintained for 6 months minimum.

Records for visitors entering such departments as workshop and warehouse should be maintained for 3 months minimum.

Chapter 17: Computer Security and Anti-fraud Files

Security Regulations

To protect our confidential documentation in computers from being disclosed and avoid severe disasters arising therefrom, all computer operators should abide by the following security regulations:

Store corporate or personal confidential files and protected files in specific directory at a proper location.

To avoid disclosure or damage to files, never open or try to open others files unless authorized by superiors or relevant personnel.

To prevent virus or Trojan Horse from attacking your computer, dont view or try to open unidentified e-mail or files. Once this occurs, ask Computer Room professionals for check immediately.

In some e-mail attachments, if there are any executable attachments or suspected attachments with append filenames such as EXE or COM, it is necessary to scan and kill virus with Virus-Killer software or ask Computer Room professionals before use.

Dont try any computer operating procedures you are unfamiliar with. In case of any anomaly in computer that you cannot solve, notify Computer Room immediately for help from professionals.

Dont install or use software or program from unidentified sources. Dont run or delete files or programs in computer or modify computer parameters.

When receiving meaningless e-mail, delete them immediately and dont intentionally or viciously send them back or send them to others.

Never disclose password to others and prevent others from creating anomaly by accessing computer systems.

Change password frequently. In case password is disclosed, change it as soon as possible. Never use default password or password provided by others.

Scan computer system with Virus-Killer program on regular basis. For new software, files or e-mail, use Virus-Killer software to scan and check if they contain virus/hazardous programming codes, and conduct proper processing before opening them.

Use encrypted technology to protect sensitive data files before transmitting via Intranet and Internet. When appropriate, use digital protocol or add digital signature to encrypt information and data.

Close the function available in e-mail software to automatically process e-mail attachments and close the auto-processing function in e-mail application system or other application software to prevent virus invasion.

Dont let unfamiliar personnel to use your computer. If you have to, someone should stand by to keep watch.

Dont send corporate or personal files to others or open such files for others to view or use without authorization.

In case of any inquiry concerning computer application or management, please consult Computer Room professionals.

Chapter 18: Surplus & Shortage Handling Procedures

Purpose

The purpose of these procedures is to facilitate timely inventory count on materials in warehouse, report and handle surplus and shortage and ultimately, to intensify effective control on corporate materials.

Scope

Warehouse supervisor is required to plan and make specific arrangements. Warehousemen are required to check materials and report on timely basis. Warehouse supervisor and PMC supervisor are required to discuss for solutions and submit such solutions to production manager for approval.

Responsibilities

Before issuing new Purchase Order, PMC Dept should notify Warehouse Dept to conduct inventory count on materials to be supplemented. Warehousemen should count the quantity of such materials, check them against Material Storage Record, record inventory count for each type of materials (indicating material name, type, quantity and incoming date) and submit the record to PMC Dept.

Warehousemen should count incoming materials according to Purchase Order and Delivery Sheet, make proper records, store materials in proper zones and attach Material Storage Record to them.

When Production Workshop requisitions materials, warehousemen should go through rigorous procedures, make proper records in incoming material record and Material Storage Record.

Warehouse Dept supervisor should arrange scheduled checks on warehoused materials focusing on materials shelf life, damage, shortage and surplus; record results in Warehouse Check Record; maintain supervision and control on consumption of customer materials; and report to PMC Dept via Customer Material Inventory Record.

When any order is cancelled or production is complete, it is required to count relevant materials (customer materials in particular) and report the quantity of backlogged materials to PMC for filing purposes.

Surplus or Shortage Handling

PMC Dept and Warehouse Dept should jointly track and investigate material shortage and surplus, and conduct investigation on material shortage, loss in production process, loss and erroneous storage in circulation, damage resulting from extended storage or expiring shelf life, and unidentified loss. Investigation should be conducted for reasons resulting in material surplus, including situations where ordered quantity is excessively large, different types of materials are mixed, erroneous materials are released and orders are cancelled. The results of such checks should be recorded in detail and submitted to PMC Dept.

Product director and Warehouse supervisor should probe into solutions based on material surplus and shortage survey report, submit solutions to Production manager for approval and record such solutions in Warehouse Check Record. Relevant departments should handle materials according to such decisions.

Product director should communicate with customers in a timely manner concerning material damage, loss and backlog, and probe into solutions with them.

Chapter 19: Cargo Document Control Procedures

Purpose

The purpose of these procedures is to define the control procedures for issuing and safekeeping of delivery documents; to ensure that we have clear accounts and complete procedures for inbound and outbound goods; to keep transportation data and data systems from unauthorized access and prevent lawless personnel from taking advantage of this to commit theft or terrorist events.

Scope

These procedures are applicable to all personnel who may access transport documents and data, including warehouse personnel and drivers.

Responsibilities

Warehouse personnel are required to verify and sign reception/release documents after reception or release. Warehouse supervisor is required to review such documents and submit original documents to corporate financial supervisor.

Reference Documents

Warehouse personnel should not receive or release goods until they have received relevant mandatory documents and data, including Purchase Order issued by PMC Dept and Shipping Advice issued by Shipping Dept. They should verify name, specifications and quantity for goods. In this process, they should keep alert to prevent unauthorized materials from entry and sign only after verifying as all right.

Procedures

Original documents such as reception/delivery documents and finished product consignment bills should be submitted to Financial Dept supervisor on the next day (preferably within 24 hours). Warehouse Dept keeps copies of transport documents for one month and submit document copies to company for filing purpose at the end of each month.

Records

It is required to keep corporate transport documents and systems confidential and particularly, to keep customers valuable information and systems from unauthorized access.

Chapter 20: Unexpected Event Handling Procedures

Procedure 1

The purpose of these procedures is to define how employees should report unexpected events to relevant departments and security personnel in an accurate and timely manner; to ensure that unexpected events are handled in a timely manner to minimize their hazard or damage to life and property.

Procedure 2

Reportable unexpected events include: theft of goods, containers and trailers; unauthorized entry of transport vehicles and personnel; deliberate sabotage to corporate property and personal safety; fire alarm; fighting between employees; work-related injuries and sudden disease attack to employees.

Procedure 3

In case of any accident, employees engaged in production in factory should report to supervisors immediately.

Procedure 4

In case of any accident, employees living in living zone should report to security guards on duty immediately.

Procedure 5

After receiving such reports from employees, department supervisors or security guards on duty should immediately report the same to security manager.

Procedure 6

In case of unexpected events, security guards on duty should immediately report the same to security manager.

Procedure 7

After receiving such reports, security manager should, in case of serious case, immediately report to local law-enforcing authorities and report details of such unexpected events to customers security supervisors within 24 hours.

Contact List

Security Manager:

Department Director:

Telephone Number for Emergency Calls:

Police 110 Extension:

Fire brigade: 119 Telephone exchange:

Local police: Factory director:

First aid: Security office:

Town security/prevention office/Police zone: Police office:

Security manager:

Chapter 21: Anti-theft Procedures

Purpose

The purpose of these procedures is to intensify our physical security and management system, effectively prevent theft activities and protect the security of corporate property.

Scope

These procedures are applicable to the safekeeping and management of all corporate properties.

Responsibilities

Security manager is required to arrange supervision and control on incoming and outgoing properties. Supervisors of various departments are required to maintain secure environments for material storage. Material personnel are required to verify the accounts of incoming/outgoing materials and quantity of inventory. Maintenance Dept is required to maintain and install corporate physical security facilities.

Procedures

Physical Security

All doors and windows in the company should have anti-burglary functions. Gates should have anti-burglary locks and windows should have bolts to prevent unauthorized entry.

CCTV system is installed within factory area and loading/unloading zones to monitor security activities concerning goods delivery and reception.

Only one gate is used as entrance and exit for factory area and attended 24hours/day by security guards.

For high-value articles, it is required to enhance physical protection, and establish iron boxes or precious article room to accommodate them.

Incoming/Outgoing Control

For visitors to enter factory area, security guards should conduct relevant registry, including visitor name, employer name and why, who and when to visit as well as Visitor Card number.

No employee is allowed to carry private articles into factory area. When any article is taken out of factory area, security guards should check them and record accordingly. It is prohibited to take anything out of the company without authorization.

It is required to intensify security patrol in factory area, keep close watch on and cross-examine unidentified or suspected persons and record accordingly.

Sufficient signs should be set up to warn employees not to enter restricted areas, including unloading zone, loading zone, finished product warehouse and parting lot for cargo trucks.

Material Tracking

For warehoused materials, Material Storage Record should be properly maintained and materials should be received and released in FIFO (first-in and first-out) sequence. Material management personnel should conduct scheduled checks on materials under their control. In case of material shortage, they should immediately report to department supervisors. For serious case, relevant departments should report to factory office and Security Dept; and Security Dept should conduct relevant investigations as needed.

Chapter 22: Antiterrorist Training Materials

Rules

Since the September 11 terrorist attack in USA, terrorist events have occurred frequently in the world and thus affected the growth of global economy. To protect our corporate property and employees personal safety, respond to CTPAT antiterrorist program, avoid delayed customs clearance for our goods and intensify all-staff security awareness, we hereby formulate the following antiterrorist training outlines:

To explain to employees the importance of wearing valid employees cards when entering or leaving through factory gate for the purpose of preventing unauthorized personnel from entry into factory area.

To conduct security check on all articles carried by personnel entering and leaving factory area, prevent hazardous articles and prohibited articles from entry, and effectively avoid loss to corporate property.

To train employees how to identify internal conspiracies, including: conspiracy to steal corporate materials or finished products; deliberate substitution of finished products; failure to pack in compliance with instructions; vicious input of prohibited articles in finished product cartons.

To train employees how to maintain cargo integrity and prevent the entry of unauthorized articles in day-to-day production activities.

To instruct employees not to go around workshops without authorization or enter such important zones as cargo warehouse, finished product warehouse, loading/unloading zones, transport zone, parking place, distribution house, chemical storage zone, oil depot and other zones with Danger and No Entry signs.

To educate employees to concentrate their minds on their work, cherish their positions and protect corporate property; operate and maintain tools and machines in compliance with instructions and report to supervisors when finding any anomaly or damage; clear up work stations and close doors and windows close to their work stations.

To help employees establish an understanding of the characteristics of the chemical substances used by our company, issue chemical safety training materials to them and train them on procedures to use and store chemicals as well as handle injuries; instruct them to pay attention to warning labels before use and avoid unauthorized contact.

To intensify training for personnel at important posts and particularly, security training for security personnel, warehousemen, stevedores and statistic clerks.

To instruct warehousemen and statistic clerks to take care of precious articles in their workshops, lock them in iron boxes, conduct scheduled check and make relevant records.

To ensure warehousemen and statistic clerks maintain consistency between accounting and actual quantity concerning material incoming, outgoing and storage.

To ensure they conduct scheduled inventory check and report to supervisors immediately when finding any damage, loss, shortage or surplus.

To ensure warehousemen and stevedores are aware of the importance of their posts, accept and release goods based on documents, keep highly alert, prevent entry of goods without documents, and assist security personnel in supervising and controlling the entry of unauthorized personnel into loading/unloading zones; report to supervisors or security manager immediately when finding suspicious phenomenon or unidentified goods.

To focus on antiterrorist training for security personnel, emphasize their compliance with Security Post and Duties, probe into and formulate security solutions in combination with the characteristics and trends of terrorist activities.

To educate employees to enhance security awareness; participate in security control; and report to workshop supervisors immediately when finding suspicious strangers without employee cards or anyone suspicious of carrying hazardous goods.

To inform all employees of our antiterrorist reporting procedures, name list and telephone numbers to contact in case of emergency; encourage employees to actively supervise and report phenomenon suspicious of terrorism, including act against factory regulations and rules, abnormal status, suspicious signs and cliques; internal conspiracies; suspected involvement in unidentified organizations; terrorist tendency through external collusion.

To let employees know of our award-giving reporting system, motivate employees to participate in antiterrorist activities, offer proper award to employees who provide valuable clues, keep their reporting undisclosed and protect their personal safety.