AEO demands that the applicant demonstrates robust processes and procedures across International Supply Chain operations for both (unlike C-TPAT in the USA for example) customs compliance and physical logistics.
In the UK, HMRC applies its own particularly rigorous and high standards of examination and audit; other customs authorities do recognise this even if harmonisations across both the EU and worldwide are applied in theory.
Veracis brings a proven multi-disciplinary approach from experience and expertise in both customs and air freight security. This approach is scalable; the EC’s intent is that any company demonstrates systems appropriate to its size, and:
- we will not start an AEO project unless the client can demonstrate a sound business case for it;
- we believe in complete client involvement;
- it’s your business – you know it from the ground up;
- our aim is to ensure client does only what is needed & focuses on key areas needed to build for AEO;
- we conduct a company analysis against AEO requirements for that client’s size to determine the outputs necessary;
- we do not seek to impose a change management dialogue onto what are already well run companies;
- we believe that the best procedure writers are your in house experts who “do the job” and we prefer to work “with you” to achieve the AEO deliverables;
- where ISO procedures are in place, they are usually more than adequate for AEO purposes;
- AEO uses ISO principles in a practical way and ISO level procedures and their underpinning bureaucracy are not necessary;
- HMRC does not expect applicants to invest in new systems just for AEO;
- HMRC does expect applicants to, where necessary, upgrade security facilities.
- To explore and resolve specific issues, we can call on our relationship with the HMRC AEO Policy Team and Senior AEO officers. We have also prompted the clarification of AEO legislation in the UK, for example in an HMRC CIP covering the enabling of Community Transit Guarantee Waivers for AEO holders. The HMRC AEO team sets out to recognise and reward company good practice and help the applicant meet AEO requirements, rather than use a confrontational process. Where this is approach is not manifested, we will intercede with senior AEO officers.
Our services and involvement can cover, according to each client’s requirements and resources:
- introduction of the AEO application process, methodology and its promotion to an AEO team and to staff generally: we recognise how important staff buy-in is when their perception is that process changes will take place;
- AEO project monitoring, using a “traffic light” system to simply and clearly highlight progress against each AEO application item;
- use of existing documentation wherever possible, reviewing or drafting policies & procedures if needed. To support this, we operate a checklist approach combining the application questionnaire with HMRC and EC guidance notes;
- advice on preparation of an AEO “pack” to provide a consistent structure and a “comfort zone” for the auditing officer;
- drafting the actual C117 and C118 application forms;
- arranging unofficial pre-vetting by HMRC;
- a test pre-audit review;
- liaison at HMRC audit;
- a comprehensive Safety & Security review of logistics operations including often overlooked HR and staff vetting issues;
- delivery of a Safety and Security report meeting a significant part of the C118 Section 5 requirements;
- guidance or compilation of a Risk and Threat Assessment in order to create a, or enhance an existing, Business Continuity Plan.
- The adequacy of trading partners and contractors is a critical part of the AEO audit. Where appropriate we will:
- demonstrate on site the audit process necessary to vet your partners in the ISC;
- provide a contractor “self assessment” scorecard model for you to evaluate and audit them;
- advise on contracts/SLAs/security declarations
Veracis’ objective is to assist its clients in making a successful application, through meeting the HMRC audit, and we will:
- review your company profile and trading practices;
- confirm your Customs processes, with their supporting financial and logistical systems;
- identify both special benefits to be gained (such as guarantee waivers) and potential issues, such as authorisations, simplifications, customs warehouse operation;
- take you through the application procedure to ensure you put forward a meaningful presentation of your company’s credentials.