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SECURITY MANUAL

Overview:
1. Introduction…………………………………………………………………………
2. Customs Trade Partnership against Terrorism (C-TPAT)…………………….……
3: Phased Security Standards for Factories……………………………………..
4. How to use this Manual…………………………………………………………….
6. Physical Security…………………………………………………………………..
7. Access Controls…………………………………………………………………….
8. Procedural Security…………………………………………………………………
9. Personnel Security………………………………………………………………….
10. Information technology……………………………………………………….…...
11. Education and Training …………………………………………………………….
12. Appendix of forms
13: Employee Badge……………………………………………………….…...
14: Restricted Area Access List……………………………………………….
15: Key Log Form……………………………………………………………..
16: Non-Business Hours Access List…………………………………………
17: Visitor Log Form…………………………………………………………..
18: Vehicle Log Form………………………………………………………….
19: Transit Monitoring Log Form………………………………………….…..
20: Written Application………………………………………………………...
21: Reference Check Log Form………………………………………………..
22: Background Check Log Form………………………………………….…...
23: Terminated Employee Checklist……………………………………….…..
24: Training Attendee Sheet……………………………………………………
25: Training Agenda……………………………………………………………
26: Factory Security Policy Instructional Document…………………………..
27: Appendix of Posters
a. “No Parking for Private Vehicles”…………………………………………
b. “Restricted Access for authorized personnel only”………………………..
c. “This Facility is equipped with a video surveillance system. You are
Subject to recording.”………………………………………………………
d. “All visitors must sign the visitor log”……………………………………..
e. “All employees and visitors and their belongings, including vehicles, are
Subject to search”…………………………………………………………..
f. “Truck Drivers and their helper cannot be in the loading area.
They must wait in_________________ until the loading is complete”………
g. “For security, call ________
h. “No Trespassing”…………………………………………………………..

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14. Appendix of Tables

1. Introduction
Customs-Trade Partnership against Terrorism (C-TPAT)
In response to the events of September 11, 2001, US Customs (now Customs and Border
Protection [CBP] within the Department of Homeland Security [DHS]) introduced an anti-
terrorism initiative named “Customs-Trade Partnership against Terrorism” (CTPAT). The
initiative is a cooperative partnering of Customs and the trade community in the war against
terrorism. Customs developed recommendations applicable to the various actors within the trade
community that are designed to enhance security at US borders.

The program is open to U.S. Importers and logistics services providers, as well as a select group
of foreign manufacturers. Currently, the program is not open to any of suppliers and factories,
but there are plans to expand the program to include more foreign manufacturers in the future.
will make suppliers aware of the opportunity to join CTPAT once it arises. It is strongly
encourages its entire product and services providers to join this important security initiative.

4. Phased Security Standards for Factories


Physical Security

1. Doors must have adequate locks while all windows must have locks that prevent opening from
outside. Windows and doors must be locked at all times when building is not occupied.

2. The packing and loading areas must be segregated from the rest of the factory in a way that is
sufficient to provide secure access restriction.

3. International, domestic, and dangerous goods cargo must be marked and segregated within the
warehouse of the factory by a safe, caged, fenced-in, or otherwise area.

4. Buildings must be constructed of durable and impenetrable materials such as cement, cinder
block, or brick in order to prevent unlawful entry and to protect against outside intrusion.

5. All access points and ground floor windows must have adequate lighting min 800 lucks at all
times of the day and night.

6. The parking lot must have lighting, and private vehicles are parked no closer than 10 meters to
the shipping/loading dock areas.

7. The factory must have an internal communications system in place to contact security
personnel and/or local law enforcement.

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Access Controls

1. Employees must have a factory issued photo identification badge and this badge must be
visible at all times while on factory grounds.

2. Visitors and vendors must present photo identification to be verified and logged by security
personnel before receiving a visitor’s badge. The Visitor badges must be collected at the
conclusion of the visit.

3. The facility must have procedures to verify the identity and authorize all persons entering the
packing and loading areas.

4. Visitors and vendors must be monitored by an employee during their visit at the facility
5. The facility must have procedures in place to challenge unauthorized/unidentified persons

6. Employees must be physically checked and their identity must be verified by security
personnel before being allowed onto factory grounds.

Procedural Security

1. A factory security guard must supervise the loading of merchandise into the vehicle/container
destined to our consolidator/carrier/freight forwarder. For approved factory loads, the security
officer is also responsible for inspecting the container prior to loading to verify that it is secure
and empty. If abnormalities are discovered, management must review prior to releasing the
freight.

2. The facility must have procedures to ensure the timely movement of finished goods from the
factory to the carrier/consolidator/freight forwarder. If there is abnormality local law
enforcement must be notified.

3. During the loading/unloading of cargo, the facility must have procedures to match the actual
product count with the accompanying shipping documentation. Management must review any
discrepancies before the shipment in question is released.

4. The factory must have procedures for verifying seals on containers, trailers, and railcars.

5. Truck drivers and their helpers are prohibited from actively participating in the loading of
freight. For full container loads, drivers and their helpers are not allowed access to the loading
area until the loading process is complete. However, the truck drivers are allowed a final
inspection.
6. The factory must have formal, written procedures pertaining to their security procedures,
incorporating all FMG security standards.
7. Loaded containers, which are not moved immediately, must be stored in a secure area.
Unloaded containers must be stored in a secure manner.
8. The factory must notify local law enforcement agencies in the event illegal activities or
suspicious behavior is suspected or detected.

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Procedural Security

9. The factory must have verification procedures in place so that all shipments are properly
labeled, marked, weighed, counted, and documented.

10. The factory must have procedures in place to maintain the integrity of data by preventing
unauthorized personnel from making any unauthorized change.

Personnel Security
1. The factory should conduct pre-employment screening of all prospective employees, including
contract and temporary employees. All employees should complete an application to be
maintained on file.

2. As a standard hiring procedure, a copy of the employee’s government issued identity


document must be made. This applies to temporary workers as well.

Information Technology

1. The factory protects its IT system from illegal use and access through the use of firewalls,
employee passwords, and anti-virus software.

2. The factory backs-up data on a regular basis

3. The factory has procedures so that employees change their passwords on a periodic basis.

4. The factory has policies to determine which employees is authorized access to its IT system

Education and Training


1. The factory must have a mandatory security program for its employees to cover recognizing
internal conspiracies, maintaining product integrity, and challenging unauthorized access.

2. The factory must encourage active employee participation in its security procedures through
the use of rewards, recognition, etc.

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5. Physical Security

1. Doors must have adequate locks while all windows must have locks that prevent opening from
outside. Windows and doors must be locked at all times when building is not occupied.

All exterior doors must be outfitted with functional locking devices.

All ground floor windows must be equipped with functional locking devices that prevent the
window’s opening from the outside.

Alternately, window bars (see picture) or mesh wire may be used to secure windows.

Windows and doors must be locked when the building is not occupied.

Emergency exits should be equipped with an audible alarm that will alert security/management
if they are opened. Alternatively, a factory can choose doors. With electronic locks that will
unlock automatically when the fire alarm is triggered.

In order to guarantee a secondary exit without compromising security, panic bars are useful to
satisfy both requirements.

Door hinges should always be on the inside of a door, not on its outside. If hinges are on the
outside, they could be removed and the door could be opened without opening the lock.

A person should be charged with making sure those doors and windows are locked after the
last employee leaves for the day.

As an added security practice, the person locking all doors can place a paper sticker over the
door lock and initial on the sticker. This way, one can verify in the morning if the door has been
unlocked overnight.

It is suggested that one door of the structure be a ‘lock-up door;’ i.e., this door is first opened
and last closed, with all other doors locked from the interior with slide bolts, hasps, etc. The
lock-up door should be secured by a deadbolt.

Any wooden exterior doors should be solid and at least 1 ¾ inches (4.445 cm) thick.

Sole key-in-knob and double cylinder locks shall never secure exterior doors.

If the facility relies on swipe key cards or other electronic locks, records of door openings
should be maintained for at least 30 days

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The packing and loading areas must be segregated from the rest of the factory in a way that is
sufficient to provide secure access restriction. The packing area (definition: the areas where
finished products are put into shipping cartons) and the loading area (definition: the area where
shipping cartons are loaded onto the conveyance or container) must be secured in a manner that
Allows restricting access to these areas to authorized employees only. In other words, no one
should be able to enter these restricted areas unless they have a legitimate reason (employees
who work in these areas, security guards etc.)
Required:

The packing area and loading area should be closed off to all transit activities. For example, if
employees have to walk through the packing area to get from the ironing department to the
cafeteria, then the factory management needs to find another way for employees from the ironing
department to access the cafeteria. The same logic applies for the loading area. Oftentimes,
employees walk by the loading area on their way to other buildings on the premises. Again, the
zones need to be restricted against this kind of unauthorized foot-traffic.

Access restriction must be based on business need and job function. An office employee does
not normally need to access to the loading area, and a sewing employee does not need to access
the packing area etc.

Buyer understands that restricted access to the packing and loading areas can have a serious
impact on a factory’s operations. For example, many factories have the packing area as the last
step of the finishing department. Workers move back and forth between different elements of
finishing (trimming, spot-removal, ironing, bagging, packing etc.). In these cases, restricted
access to one element of the finishing department, namely packing, will impede the movement
flow. Nonetheless, we have to make sure that the packing area is one of the most sensitive areas
in terms of security. Only by restricting access to these areas, will factories by able to satisfy US
Customs demands and meet the CT-Pat requirement.

It is the factory manager’s responsibility to determine which solution or combination of


solutions (listed below) will best secure the packing and loading areas, without impeding the
factory’s daily operations:

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How this can be accomplished by

1: Issuing different colored badges to employees allowed in restricted areas. Security guard or
supervisor to check badges and restrict access. This color coded system allows for easily
identifying an employee in a restricted zone. For example an employee wearing a pink badge
(which identifies ironing workers) should not be found in the cartooning area (where packing
employees wear blue badges).

2: Issuing different colored badges to employees allowed in restricted areas. Controlled and
monitored CCTV systems.

3: Temporary fencing (for small or shared loading areas). A supervisor should control and
restrict access.
4: Physical barriers (fence, door, gate, turnstile etc.). A supervisor or security guard should
control and restrict access. Having a physical barrier that can be passed only by authorized
employees (swipe card, key, access code, biometric etc.) is the most effective form of securing
access.

SMALL FACTORIES:
1: Packing: The packing areas should be in an area of the factory that is segregated and secure.
All employees should be properly trained to pack and handle goods according to the facilities
outlined security procedures.

2: Loading: A security guard or supervisor should monitor all loading activities. All employees
should be properly trained to load and handle goods according to the facilities outlined security
procedures. If the container is parked on a public area, employees should walk the cargo into the
conveyance and not leave them stacked on the street.

3: All factory employees should wear badges that permit them to enter both the packing and
loading areas, however a factory supervisor should be aware of the traffic through the areas in
order to maintain security.

4: If the facility chooses to use temporary workers for packing and loading, it is imperative that a
security guard or supervisor monitors their activities at all time in these areas.

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Additional Security required.

By stationing a security guard or a supervisor in the area. This person must check employee’s
badges to confirm that they work there or otherwise be able to visually distinguish employees
that are authorized in these areas. If the factory elects to have a supervisor ensure that only
employees working in the specific department enter the area, this additional responsibility must
be included in the supervisor’s job function. While it is acceptable that the supervisor attends to
Additional duties while ensuring that only authorized employees are in these areas, he or she
must be aware of the additional responsibility related to restricting access to these areas to
authorized employees only.

By posting signs with the name and picture of the supervisor in the packing and loading areas.

By posting the number of employees that work in the packing loading department allows a
security guard or supervisor who is entering the workstation or monitoring the area through
cameras, to easily identify when there are unauthorized individuals present.

The packing (cartooning) area should be segregated from the work floor by means of a
physical barrier. For example, packing could take place behind a mesh wire fence or in a separate
room that is accessible only to employees working there.

The loading area should allow for access restriction. For example, the loading area can be
secured with fencing.

Signs stating “Restricted Zone. Access for authorized personnel only” should be posted.

Security/management should have access lists for each individual restricted area these lists
should be checked monthly to ensure they remain updated.

3. International, domestic, and dangerous goods & cargo must be marked and segregated within
the warehouse of the factory by a safe, caged, fenced-in, or otherwise controlled area required:

Dangerous goods/hazardous materials must be marked and segregated within the warehouse.
Access to the hazardous materials storage area must be restricted. If necessary, hazardous
materials require secondary containment.

International cargo must be segregated from domestic cargo and marked as such.

Segregation of goods must be in form of a physical barrier or other appropriate means of


separation. Suitable examples are: a separate room, a fence, a room divider, or a demarcated area
that is under supervision of security guard or CCTV.

Access to the warehouse should be restricted to authorized personnel only. Entry and exit of
persons should be monitored.

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The factory should segregate all merchandise from other merchandise within its warehouse. It
is preferred that such segregation is not merely a demarcation (for example lines pained on the
floor), but in form of a physical barrier (a separate room, vault, fenced in area).

4. Buildings must be constructed of durable and impenetrable materials such as cement, cinder
block, or brick in order to prevent unlawful entry and to protect against outside intrusion.

Each individual building must have a structural perimeter barrier; i.e. a medium that defines the
physical limits of the building.

Production buildings and warehouses must be constructed of durable and impenetrable


materials, which include, but are not limited to: Cement, Wood, Cinder Block, Metal and Brick

The only openings in such buildings are: Doors, Windows, Vents, Cargo gates etc.
Corrugated plastic sheeting (see picture) may only be used as a roof, not as a sidewall.

Additional Security Suggestions.

Openings, such as vents and utility holes greater than 96 square inches (.06194 m 2), through
which unauthorized entry may be gained should be blocked/covered as necessary. Air
conditioners and vent covers should be secured to the structure.

When considering renovations to existing buildings and constructions of new buildings,


security should be an aspect to be taken into account when planning the structure.

5. All access points and ground floor windows must have adequate lighting (minimum of 10 foot
candles) at all times of the day and night.

This rule applies to all access points of the facility—doors, windows, vents, cargo gates/dock
door etc.
Instead of applying a light fixture above each entry point, a factory could chose floodlights that
are pointed at the building exterior and illuminate the entire complex.

During daylight hours, sunlight may be sufficient, depending on construction type and/or
vegetation. For example if buildings are built so close to each other that little or no natural light
can filter down, lights must be turned on. The same applies to vegetation: If trees filter out
natural light, artificial lighting must be used to create adequate light conditions. Lights must be
turned on in inclement weather.

In certain regions, several factories may share a building. In these cases, the doors to the
individual factory are considered access points. They could for example be in a hallway.

LEFT: Entry point to factory in a hallway—adequately illuminated.

RIGHT: Entry point to a facility in a hallway—too dark.

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Additional Security Suggestions:

Use a light meter to obtain foot-candle reading.

Best illumination standards are floodlights that provide daylight conditions without shadows.

The lighting system should be checked by security guards on patrol on a daily basis and
maintained professionally on a semi-annual basis. Maintenance records should be maintained.

Interior lights should be kept on a 24 hours a day, 7 days a week basis.2 this acts as a deterrent
and allows better CCTV recording.

6. The parking lot must have lighting, and private vehicles are parked no closer than 10
meters to the shipping/loading dock areas.

The parking lot must be illuminated.

If the factory premises are too small to establish a 10-meter no parking zone around the loading
gates, an alternative solution is to remove all private vehicles from the premises whenever
loading or unloading takes place. At small facilities, this is usually not on a daily basis, thus
disruption should be minimal.

If the factory premises are too small to establish a 10 meter no parking zone around the loading
gates and removing private vehicles from the premises during loading and unloading activities is
not feasible, the factory can also use portable fences (as used on construction sites) and establish
a secure perimeter around the loading area.

Portable fences/ barricades (see picture below) can also be used to make the loading area
Secure when the loading gate is shared with other facilities in the same building. Fences can be
erected temporarily while loading activities take place to ensure that no UN manifested material
can be loaded.

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SMALL FACTORIES:

O Parking: If the loading and unloading takes place on a public street or in a public parking area,
it is not necessary to move the cars. However, a security guard or trained supervisor should
monitor all loading activities.

O Private Parking Area: If possible, cars should be moved during loading and unloading. At all
other times cars may be parked near the loading area, but access should be restricted to
Authorized persons only.

O Public Parking or Street Loading: If the conveyance is parked on a public area, employees
should walk the cargo into the conveyance and not leave them stacked on the street.

ABOVE: Portable fencing

LEFT: A private vehicle is parked less than 10 meters from the loading dock.

RIGHT: No private vehicles are parked near the loading dock.

Factories should use floodlights to illuminate the parking lot.

It is best to paint “No Parking for private vehicles” on the ground in a 10-meter zone from the
loading gates.
Signs stating “No parking for private vehicles” should be attached to walls.

LEFT: Floodlights

The factory must have an internal communications system in place to contact security personnel
and/or local law enforcement.

Employees must be made aware of how to reach security personnel. Posters should be posted
throughout the work floor and in other areas of the factories premises.

The factory must have a means of communication on the premises that is accessible by at least
one person present at all times. For example, if there is only one phone on the premises, in the
manager’s office, which is locked after the manager leaves, at least one person of those that stay
longer must have a key to the office.
Acceptable communication devices:
I. To reach internal security personnel:
1. Face-to-face communication
2. Walkie-talkies/ Radios
3. Emergency buttons
4. Intercom
5. Regular phones
6. Mobile phones
ii. To reach local law enforcement:
1. Regular phones

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2. Mobile phones
3. Radios
4. Communication system connected directly to local police station

Additional Security Suggestions

Ideal alarm systems are the ones that automatically alert a third-party security provider or local
law enforcement if security has been breached. It is recommended that such alarm systems are
equipped with wireless back up to ensure that they function even if main telephone lines have
been compromised.

The communications system should be functional even under hardened circumstances. For
example, facilities should have several “old-fashioned” phones that do not rely on electric power
to function. Facilities should have back-up batteries for prolonged use of walkie-talkie and
mobile phones.

A factory should have a back-up communication system in case the primary system fails due to
a mechanical problem (power outage) or from manipulation (clipped phone lines).

The functionality of the communications system should be tested on a daily basis and
professionally maintained on a semi-annual basis. Maintenance records should be maintained

Additional Security Suggestions for “Physical Security” Location:

When considering opening a new production site, the following should be taken into account
when searching for a location:

Response time: How far is the site from the nearest police station/ private security service?
Area crime rate: If possible, obtain statistics from police station or ask other businesses in the
area.
Access to transit systems: Are the roadways leading to major roads or ports considered safe?

Neighboring businesses: what types of businesses are in this area?


Is there a chance for cooperating in security matters?

The facility perimeter should be surrounded by a fence or wall.

The facility’s perimeter should be cleared of vegetation and debris that could be used to breach
fences.

“No trespassing” signs should be posted at regular intervals along the fence/wall.

Routine security patrols of the perimeter, at alternating times, combined with surveillance, anti-
intrusion devices and lighting are recommended.

Fencing should be 8 feet (2.4 m) high and, if not constructed of solid material, use at least 9-
guage galvanized steel of 2 inch (5.08 cm) wide chain link construction topped with an
additional 2 foot (0.61 m) barbed wire outrigger consisting of 3 strands of 9-guage galvanized
barbed wire at a 45-degree outward angle above the fence. The bottom of the fence should be
No more than 2 inches (5.08 cm) from the ground.

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Security Equipment:

The factory should be equipped with an anti-intrusion alarm system

All access points (doors, windows, dock door etc.) should be connected to the alarm system.
Motion detection devices should be activated in sensitive areas (packing area, warehouse) after
business hours.

The alarm system should have back-up power (for power loss or failure) and wireless backup
(for telecommunication system failure). It should connect to either local law enforcement or to a
private security company.

Access to the control room and the alarm system itself should be highly and selectively
restricted.

The alarm system should be tested internally on a weekly basis and professionally maintained on
a semi-annual basis. Maintenance records are to be maintained.

Alarm codes must be secure. When an employee who has knowledge of any alarm codes is
terminated, the codes must be changed. This act should be recorded in the “Terminated
Employee Checklist”

Detailed records of alarms (even accidental triggering) should be maintained for at least 60 days.

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Closed Circuit Television System/ Surveillance Cameras.

As an added security measure, the factory building and its perimeter should be outfitted with
security cameras feeding real-time pictures to a control room where pictures are monitored by a
guard and recorded by a recording device.

Such tapes should be maintained in a secure location for at least 30 days

All CCTV images should be recorded in real time and no more than 16 cameras should be
recorded per disk or tape. If the facility uses a VCR, there should be no more than 12 hours of
images on one tape.
There should be a quarterly preventive maintenance of equipment (alarms and video cameras).
Records of this maintenance should be kept on file.6
Sophisticated cameras can record even without adequate lighting.

However, most models depend on adequate illumination in order to deliver a clear picture. Thus,
illumination must be considered when installing cameras.

If you consider buying a new CCTV system, opt for a color rendition system.

Cameras are a very useful tool to monitor and record access to restricted areas (warehouses,
packing area, loading area).

By posting the number of employees that work in the packing loading department allows a
security guard or supervisor who is entering the workstation or monitoring the area through
cameras, to easily identify when there are unauthorized individuals present.

The security staff member monitoring the cameras should consistently evaluate the activity
within restricted areas. If suspicious activity occurs or there is an unaccounted overage in
employees, the security staff member should notify either the factory manager or local law
Enforcement."

Key controls:
i. When keys are given to employees, this act should be noted in a key logbook

ii. Keys must be returned when an employee is terminated. If a key is not returned, the locks
must be changed.

iii. High-security keys (keys that cannot be duplicated) should be used.

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Security personnel:
The factory should have security personnel to patrol the grounds and ensure the physical security
of the premises.

o Management can verify that security personnel is indeed going on regular rounds of the
premises by using a DETEX style watchmen’s clock system, which allows for recording when a
security guard was at a given point. Detex devices can be obtained from a variety of companies
such as

o If security personnel are not feasible (high personnel costs, small size of factory), a member of
the factory should be designated as person in charge of security. This person should receive
special training

7. Access Controls

Employees must have a factory issued photo identification badge and this badge must be visible
at all times while on factory grounds.

At a minimum, employees must be issued a cardboard badge, which bears their name,
department, and photo.

Employees must be told during orientation to wear the badge at all times while on the on the
premises.

The facility should have procedures in place to remove identification, facility, and system
access for terminated employees (badges, keycards, etc.) ABOVE: Examples of acceptable
employee badges

Additional Security Suggestions: Examples of Visitor’s badges:

While “homemade” cardboard badges are acceptable.


It is recommend laminated plastic badges, as bearing company logos etc. as those are more
difficult to forge.

Many companies chose to combine identification badges with timekeeping purposes, making
employees swipe their machine-readable badges to record their time-in and time-out.

It is best to have badges issued in different colors to identify different employment status
(permanent versus temporary employee), different positions (senior staff versus workers) and
different workstations (packing versus sewing). This color-coded system allows for easily

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identifying an employee in a restricted zone. For example an employee wearing a pink badge
(which identifies ironing workers) should not be found in the cartooning area (where packing
employees wear blue badges).

Employees should be informed to take good care of their badge and never to lend their badge to
anyone. They must report a lost or stolen badge to security.

Visitors and vendors must present photo identification to be verified and logged by security
personnel before receiving a visitor’s badge.

All non–employees wishing to gain access to the premises, must present an identification
document (driver’s license, national identity card, passport, etc.)

This document is to be verified by the security guard/receptionist.

After their identity has been verified, visitors must sign the visitor’s log.

Visitors must receive a visitor’s badge to display at all times while on the factory premises.
The badge has to be visually different (e.g. different color) from the employee badges.

Company management or security personnel must control the issuance and removal of
employee, visitor and vendor identification badges.

Additional Security Suggestions (Standard 2):

The identity and company affiliation of visitors, vendors, contractors etc. can be verified by
calling their company.

Visitor’s logs should be kept in a secure location for at least 6 months.

A poster stating, “All visitors must sign the visitor’s log”, should be posted in the reception
area.

The best types of visitor’s badges are:

Personalized badges that are printed out on stickers for the visitor, bearing his/her name and the
date of the visit. These stickers do not have to be returned.

Reusable visitor’s badges, specific to the company (and difficult to forge). These badges have
numbers and the number of the badge issued to the visitor is logged on the visitor’s log. The
badge must be returned at the end of the visit.

Visitor’s badges can also be used to classify visitors into different groups. For example, some
visitor badges could be colored red and bear “Must be escorted”, indicating that this visitor must
be escorted at all times, and other passes could be colored green, meaning that this visitor does
not have to be escorted at all times.

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3. The facility must have procedures to verify the identity and authorize all
Persons entering the packing and loading areas

Sample Procedures: A security guard must be stationed at the access point to the packing area
at all times during business hours (the access point is to be locked during non-business hours).

The guard is to verify that each employee attempting to enter the packing area is indeed wearing
an employee badge, which identifies him/her as a packing area employee. A security guard must
be stationed at the access point to the loading area at all times during business hours (the access
Point is to be locked during non-business hours).

The guard is to verify that each employee attempting to enter the loading area is indeed wearing
an employee badge, which identifies him/her as a loading area employee.

A company employee must monitor the visitor throughout the visit. The degree of monitoring
should be determined by the type of visitor. For example, a QC person who has been visiting this
facility for several years several times per months, needs less monitoring than a person who is a
potential buyer and who has never been at this facility (the latter should be escorted at all times).

All security personnel should be notified when a visitor is on factory grounds. The supervisors
in the areas where the visitor will be accessing should also be notified. In addition, if no one is
assigned to escort the visitor the supervisor in that area of the facility is responsible for
monitoring the visitor (keeping an eye on them).
The head security person and/or supervisor responsible for the visitor should know where that
person is at all times, while they are on factory grounds.
All visitors should be escorted and monitored in restricted areas by an individual that is
authorized to access that area.

It is best to escort all visitors at all times.

If a visitor is not escorted at all times and the facility is equipped with a CCTV system, the
person monitoring the CCTV system should be alerted to the visitor’s presence so that the CCTV
monitor can keep “an eye” on the visitor. Security guards should also be alerted for the same
reason.

The facility must have procedures in place to challenge unauthorized/ unidentified persons
Required:

The factory must establish in writing how to deal with unidentified/unauthorized persons on
the premises in general and in restricted areas in particular.

Sample Procedures: If an unauthorized or unidentified person is discovered on the premises or


in a restricted area, Security or Management must be notified immediately. The unidentified
person(s) must be detained and questioned. An investigation is to follow, and if necessary, law
17
enforcement has to be notified. An incident report must be written and the breach of security and
corrective action must be addressed.

Additional Security Suggestions (Standard 6):

There should be different procedures for different circumstances:

An unidentified person in a non-restricted zone on the premises during business hours

An unidentified person in a non-restricted zone on the premises during non business hours

An unauthorized employee in a non-restricted zone on the premises during non-business hours

An unauthorized visitor in a restricted area

An unauthorized employee in a restricted area

6. Employees must be physically checked and their identity must be verified by security
personnel before being allowed onto factory grounds

Required:
Each and every employee entering the premises must be verified. The following are
Different options:

Security guard or a management representative is stationed at the access point to


The premises and checks each employee’s badge._

Employees can use swipe cards to access the premises.

Employees have a key/keycard/code to open an access point.

Access is remotely controlled via CCTV and Intercom. Employees ring a doorbell and identify
themselves orally via Intercom. Their identity is verified physically via CCTV.

Employees are registered in a biometric access control system (iris scan, hand scan etc.) which
needs to be passed on order to gain access to the premises).

ABOVE: Biometric access control solutions

Additional Security Suggestions (Standard 6):

The factory should have access control procedures in place. There should be one set of
procedures used for regular business hours and a separate set used for after business hours.

Access for non-business hours should be restricted. A facility should either establish
procedures on what positions can have access (senior management, office employees etc.) or
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what persons (by drawing up a list of pre approved names). Anyone entering the facility after
hours should sign in with the guard

8. Procedural Security Container loading

1. A factory security guard must supervise the loading of merchandise into the
vehicle/container destined to our consolidator/carrier/freight forwarder. For approved
factory loads, the security officer is also responsible for inspecting the container prior to
Loading to verify that it is secure and empty. If abnormalities are discovered,
management must review prior to releasing the freight

Required:
For transport to the consolidator’s premises:

A security guard or a senior manager must supervise the loading of finished goods into the
vehicle.

The security guard or senior manager may not help with the loading; his or her sole duty must be
to observe and supervise the loading process.

For approved factory loads:

In addition to the supervision duties as outlined above, a security guard or senior manager must
examine the container to check for hidden compartments and for structural serviceability prior to
loading, following these guidelines:

Areas of inspection:
Front wall
Left side/ Right side
Floor/ Ceiling/ Roof
Inside/ Outside doors
Outside/ Undercarriage

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Container Check list before loading

Hidden Compartments:

1: Check for the odor of fresh paint, burnt wood, or body filler.

2: Check for sign of fresh paint, welding burns, and variances in wall texture.

3: Structural Serviceability: Check for cracks in the front and rear corner posts.

4: Check to see if the panels are holed cut, torn or cracked; missing loose parts or fasteners

5: Perform the Light Leak Test for the interior: Check for light penetration through defects in
door gaskets, holes, damaged welds, damaged or separated floor boards, and loose or missing
fasteners. This inspection is performed from the interior with the doors completely closed and
secured.

6: On the door end, inspect the locking bars (rods), including brackets, guides, and cams, and
look for any deformation such as a bend, bow, dent, etc. that impairs door operation or secure
closure.

7: On the understructure, inspect the cross members, outriggers and attachments for holes.

8: On the understructure, inspect floorboards, panels or planks for tears, cracks, or cuts.

If any abnormalities related to the container are discovered, management must review these,
prior to releasing the freight.

If the container is not empty or not structurally safe, a new container must be requested and
the questionable container may not be used to transport merchandise.

Factories should require that empty containers be sealed before they leave the
consolidator’s/shipping lines depot en route to the factory. The factory should verify that the seal
(number) is still the same as the seal (number) that was originally applied.

Container Inspection Guidelines from the Carrier Initiative Program:

o False Front Walls: When examining a normal front wall of a dry van container, both corner
blocks and the corrugation between the marking panels and the front wall are visible. False walls
have been detected where the smuggler has manufactured corner blocks but the false wall was
flush against the marking panel. The false wall may be of the same type of corrugated metal as
the legitimate front wall. Inspectors need to look for signs of alteration such as: fresh paint,

20
welding burns on either the interior or exterior of the container wall, variances in wall texture or
lack of corrugation, the odor of fresh paint, burnt wood or body filler.

Container Inspection Guidelines from the Carrier Initiative Program:

LEFT: A false wall is being removed

1: False Floors: The floors in unaltered containers are normally flush with the front door frame.
If the floorboards protrude above the level of the frame or appear new, not level or slanting
upward toward the front wall of the container, a possible false floor may exist. Another method
of detecting a false floor is to reach for the ceiling of the container upon entering and then walk
towards the front wall. A change in height or the ability to touch the ceiling should be evident if
the floor has been altered.

2: False Ceilings: The construction of a false ceiling may be either internal or external. The
external false ceiling, or false roof, can be detected by observing the distance between the top of
the corner block and the top of the roof. Normally, the roof is slightly below or flush with the top
of the corner blocks. If the roof is above the corner blocks, then a false roof is possible. An
internally constructed false ceiling can be detected by reaching for the ceiling. When a false
ceiling – or floor – exists, a change in height or the ability to touch the roof should be noticed.
Other signs to look for are: fresh paint, obscured corner blocks, welding burns, etc.

3: Container Frames: Container frames that are used to conceal contraband are the most
difficult to detect. In the absence of other signs, the only way to detect concealment is by drilling
the frame and probing.

2. The facility must have procedures to ensure the timely movement of finished goods from
the factory to the carrier/consolidator/freight forwarder. If there are abnormalities, FMG
and local law enforcement must be notified

The factory can choose between several ways of fulfilling this requirement:

1: They may elect to have a factory representative accompany the shipment to the consolidator
by riding along with the driver on the truck.

2: They may elect to monitor the movement of goods by calling the destination (consolidator or
port) after the amount of time that one could reasonably expect the transit to take and verify
whether the vehicle has arrived. If this is not the case, and the transport arrives late, the driver
must be questioned as to possible reasons such as inclement weather, heavy traffic, accidents,
Mechanical failures etc. All communication must be tracked on the monitoring logbook

Sample procedures “Escort”: No shipment or merchandise may leave the premises without a
factory representative escorting the goods and driving along in the cabin of the truck. The factory
representative must be either a member of the security personnel or management. The factory

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representative is to be equipped with a communication device such as a mobile phone and is to
be instructed to contact the factory in case of any problems.

Sample procedures “Remote Monitoring”: Security/ Management must monitor the


movement of goods to the next link in the supply chain by contacting this entity and enquiring
about the timely arrival of the conveyance. Inquiries and results must be noted in the monitoring
logbook.

Container Inspection Guidelines from the Carrier Initiative Program:

Factories should require that their truckloads do not pick up additional shipments at other
factories in route to the consolidator.

If a factory has its own fleet of vehicles and employs the drivers directly; it should issue
mobile phones to the drivers, so that drivers can call for help if necessary without abandoning the
vehicle.

If a factory has its own fleet of vehicles; it should consider outfitting the vehicles with GPS
technology to be able to track the vehicles in transit.

If the factory has its own fleet of vehicles; it should always use hard-sided, hard top trucks for
transporting

9: During the loading/unloading of cargo, the facility must have procedures to match the actual
product count with the accompanying shipping documentation. Management must review any
discrepancies before the shipment in question is released

A supervisor must observe all loading and unloading activities in order to ensure that the
actual product count is exactly the same as reflected on the shipping papers.

When products are being unloaded and the count does not match, the source of those
products must be notified and the products may not be introduced into the factory’s stock until
management has reviewed the discrepancies and determined that they are not suspicious.

Sample Procedures: Whenever cargo is unloaded or loaded, quantities must be counted and
cross-referenced with the relevant documentation. Management must review any discrepancies.

13: In case of shortages and overages, an investigation into causes must follow. The investigation
and its results should be documented.

A factory should have all product counts conducted by at least 2 persons to ensure accuracy.

Loading checklist is another tool to ensure product count accuracy.

The supervisor should sign the Bill of Lading after loading/unloading, and mark the product
count next to his/her signature.

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Container Inspection Guidelines from the Carrier Initiative Program:
Seal Procedure:

The factory must have procedures for verifying seals on containers, trailers, and railcars

For incoming raw materials: The factory must verify that the seal is intact and that the seal
number matches the number stated on the Bill of Lading. If the seal has been broken, security
has been breached. The only exception would be if the seal had been broken for valid inspection
purposes (customs officials, police) and if the officials would have noted this inspection on the

Bill of Lading.
For outgoing materials:
o Full container Loads: For FMG approved factory loads follow the sealing practices as
prescribed by Buyer
o For non-factory loads (freight being transported to the consolidator for containerization): If
your land carrier provides a hard-sided, hard-top or boxed truck (see picture), then proper sealing
procedures must be followed.

ABOVE: Hard-sided, Hard-top or boxed trucks


Sample Procedures: In case of factory loads, seals must be placed on the fully loaded
container. The seal number must be recorded onto the Bill of Lading. The driver is to be
provided with an additional seal. If the original seal is broken in transit (by a government
official), the authority (Police or Customs) that demanded access to the container must note/mark
this on the Bill of Lading. The driver is then to apply the spare seal on the container and record
the new seal number on the Bill of Lading. In case of transport of boxed trucks or vans the same
procedures apply.

When choosing seals, keep the following in mind:

The easiest to break and tamper with are indicative seals, which have the sole purpose of
providing information if a container or truck doors have been opened at a certain stage of the
journey.
The next group is barrier seals of many grades and various shapes, such as steel bolts, cables
and flat metal strips. These seals cannot be ripped off bare handed by an impulsive burglar, nor
twisted off using a small crowbar, screwdriver or similar tool. Barrier seals provide good
evidence if container doors have been opened between the shipping point and the final
destination check. These seals also require heavier tools to be removed or cut off and the most
common one used and capable to do it are the double lever shears. It is quite easy to get hold of
such a tool and for a professional burglar it takes only seconds to cut those barrier seals and get
access into the container or truck, without causing any noise, or involving excess time or effort.
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To provide real tamper evidence, seals on containers and trucks must be applied on the door
rods, in order to unite those and not to enable opening without breaking the seal. Such sealing is
achieved by the use of long type cable seals or interlocking bars. There are many types of cable
seals on the market, which provide this solution, and all are classified as barrier seals, because
cables cannot be defeated easily and to be removed, tools are required. However such tools are
also easily available and concealable by thieves, therefore cable seals applied on the door rods
provide tamper evidence, but are not a real physical deterrent to prevent cargo theft.

Interlocking solid steel bars which join firmly the inner rods of a container or truck doors are a
class by themselves and those accepted by customs as High Security seals are not only seals but
also provide strong physical prevention.

Truck drivers and their helpers are prohibited from actively participating in the loading of
freight. For full container loads, drivers and their helpers are not allowed access to the loading
area until the loading process is complete. However, the truck drivers are allowed a final
inspection.

Required:

For less than container loads:

o Truck Drivers and their helpers may be present during loading, but they cannot actively
participate in the loading process (i.e. by moving shipping cartons)

o Truck drivers and their helpers may advice the factory loaders on how to most efficiently load
the conveyance.
o They are allowed a product count/inspection.

For full container loads:


o Truck drivers and their helpers are not permitted in the loading zone while loading activities
take place.
o They are allowed a final visual inspection before the container is being locked and sealed.

Additional Security Suggestions (Standard): For less than container loads:


o The loading supervisor should remind drivers and their helpers that they may not be helping in
the loading process.
For full container loads:
o The factory should designate a waiting area for truck drivers (canteen, reception area etc.)
o The factory should post signs, reminding truck drivers that they cannot be in the loading area

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Security Policy Instructional Document provides an idea of different points to consider
for a security policy. Every factory must develop an individual security policy to match the
factory’s specific requirements. When drafting their security policy, a factory must ensure that
all points of the CT-Pat Security Standards for Factories are addressed.

Security Standards for Factories. Written procedures are a very useful means of achieving
efficient and consistent practices. They allow for easy training of new hires and provide a useful
reference tool in emergency situations when there may not be time to devise a plan.

 Other areas that should be addressed by a security policy are:


o What to do in case of bomb threats?
o What to do in case of political unrest/ riots?
o How to secure a potential crime scene until law enforcement arrives?
o How to communicate quickly and effectively with suppliers and buyers in a
Crisis situation?
o Etc.

7. Loaded containers, which are not moved immediately, must be stored in


a secure area. Unloaded containers must be stored in a secure manner.

Required:
Loaded containers must be stored on the factory premises, which have to be surrounded by a
fence or wall. If this is not possible, loaded containers must be stored in another secured (fenced
in) lot. If this is not possible, they may be stored on public premises, only if they are guarded at
all times.

Whenever loaded containers are stored; they have to be locked and sealed.

Empty container must be stored in a secure manner, i.e. they can be stored either on a secure
area on the premises, or, if that is not feasible they can be stored off the grounds, provided they
are secured by seals.

Loaded and unloaded containers should be stored door-to-door or with the door facing a wall in
order to prevent access.

Both loaded and unloaded containers should be sealed prior to being stored.

8. The factory must notify local law enforcement agencies in the event illegal activities or
suspicious behavior is suspected or detected

Required:
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The facility must notify law enforcement if illegal activities are suspected or detected.
The facility must notify law enforcement if an employee is found involved in an illegal activity
that could potentially compromise the security of merchandise.
The facility must notify law enforcement if an unauthorized person is found in a restricted area
and no satisfying explanation can be given.
The factory should keep track of any incident where law enforcement was involved.
The factory should communicate any security breaches in regards to merchandise.

The factory must have verification procedures in place so that all shipments are properly
labeled, marked, weighed, counted, and documented.

Required:
The factory must establish in writing who is authorized to complete and/or sign shipping
documents.
Sample Procedures: Only the shipping supervisor or Management are authorized to make
minor (less than +/- 5%) quantity changes in shipping documents If major (more than +/- 5%)
changes are required, authorized office staff must make these changes and a new form must be
Printed.

It is recommended that all changes, no matter how small, result in a new document being
printed.

The factory should clearly identify which positions may make changes onto shipping
documents (supervisors, controller etc.) and who may not (regular loading employees etc.)

The factory should not accept any deliveries without an advance appointment

The factory should have procedures and practices in place to monitor any subcontractors they
may have to ensure that all subcontractors implement be notified if subcontractors are to be used
for the production of any its merchandise. Factories may not work with unauthorized
subcontractors.

The factory should have procedures on screening mail. For example: Mail and packages are to
be delivered only to the security guard in the gatehouse. Before passing the mail along to the
office, the security guard is to do a preliminary check to ensure that mail and packages do not
contain any explosive or chemical/biological agents. The following are indicators of suspicious
mail (but they do not necessarily mean that the mail or package in question is dangerous):

o Foreign mail, airmail and special delivery. _


o Restrictive markings, such as confidential, personal, etc.
o Excessive postage. (Usually stamps - not meter strips).
o Handwritten or poorly typed addresses.
o Incorrect titles.
o Titles, but no names.
o Misspellings of common words.
o Oily stains or discoloration.
o No return address.
o Excessive weight.
o Rigid envelope.
o Lopsided or uneven envelope.
o Protruding wires or tinfoil.
26
o Excessive security materials, such as masking tape, string, etc.
o Visual distractions.9
o Unknown powered substance on outside of item
o Ticking sound
o A city or state in the postmark that does not match the return

Personnel Security

1. The factory should conduct pre-employment screening of all prospective employees,


including contract and temporary employees.

All employees should complete an application to be maintained on file.


Required:
Each candidate must complete a written application.

The application should be maintained in the employee’s file.

The hiring manager or another senior company official must interview the candidate

All files should be maintained for 3-6 following the termination of employment

Management should track all employees’ “START DATE” and “END DATE” at the facility,
especially for temporary workers.

The hiring manager or another senior company official should interview the candidate

The hiring manager or another senior company official should conduct a reference check on the
candidate and record his/her findings in writing.

The hiring manager or another senior company official should verify that the information on
the application is accurate

If possible, the hiring manager or another senior official must conduct a background check on
the candidate, must be recorded, for example on the background check form. The background
check may be outsourced to third party investigation companies.

Upon hire, fingerprints of employees should be made. Not only will they act as a deterrent, but
they will also be useful for criminal background checks and in case of future investigations,
should any incidents occur at the factory.

Upon hire, employees should submit 2 recent pictures, or the factory should take pictures. The
pictures are to be maintained in the employee file. Again, this practice acts as a deterrent and will
facilitate investigations should an incident ever occur.

If imported workers are hired, they should only be hired through companies that conduct
background checks on the workers in their homeland.

27
Factories should vary their hiring procedures according to a person’s job functions. For certain
employees who have special access (IT managers, security guards etc.) more stringent hiring
procedures should be used.

If a background check or reference check reveals negative information on the candidate, the
offer for employment may have to be withdrawn.

Temporary Employees:

Temporary employees should undergo the same hiring practices as other employees, which
includes; filling out an application and providing a copy of their photo identification.

If temporary employees are hired through an agency the facility should request the agency
provide a statement explaining their hiring practices, to ensure they are compliant with security
standard.

Management should track all employees’ “START DATE” and “END DATE” at the facility,
especially for temporary workers.

The hiring manager must make a copy of the employee’s official identification document. For
a list of approved identification documents per country law requirement.

The copy is to be kept in the employee’s file.

This rule applies to all persons on the company’s payroll, including temporary workers.

For special employees, such as security guards, a copy of their licenses, certifications, training
records etc. should also be made and maintained in the employee file.

The validity of the identification document should be verified with the agency that supposedly
issued the document.

“Personnel Security”:
The factory should conduct internal audits of its hiring practices. A senior management
representative should periodically check employee files for completeness and accuracy.
Results of such internal audits should be recorded and maintained. If internal audits reveal
deficiencies, the facility should address those by implementing corrective actions.

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10. Information Technology
1. The factory protects its IT system from illegal use and access through the use of firewalls,
employee passwords, and anti-virus software.

The factory must use anti-virus software and a firewall to protect its IT system

The factory must require login/password combinations to access its IT system. Additional

The following security measures are also recommended:

Locked key server environment: The physical protection of the server and equipment. It should
be stored behind a locked door.128-bit encryption: The highest level of protection possible for
one’s Internet communications and transactions. Encryption electronically scrambles information
to minimize the risk that outside parties can view or alter that information when it is Transmitted.

Public Key Infrastructure (PKI): Method to protect confidential / secret electronic message sent
over the Internet. The message sender holds the private key, and may distribute the public key to
those who will receive the message. The receiver uses the public key to decrypt the message. _

Virtual Private Network: This method encrypts or scrambles all your network communications
in an effort to provide security to the network and ensures privacy.

2. The factory backs-up data on a regular basis

The factory must back up data in order to ensure that records still exist even if the main IT
system is disabled (virus attack, fire at the factory etc.).

Data can be backed up in a variety of means, ranging from less sophisticated methods such as
floppy disk or CD-Rom to more sophisticated means such as an off-site backup server.

Computer systems that create or update mission critical data on a daily basis should to be
backed up on a daily basis.

All software, whether purchased or created, should to be protected by at least one full backup.

System data should be backed up with at least one generation per month.

All application data should be protected by weekly full backup using the three generation

29
principle.

All protocol data are to be protected by means of a full weekly backup using the three-
generation principle.

Information Technology

A data backup policy should be available to determine how the generated data backups should
be documented. Documentation is necessary for orderly and efficient data backup. The following
items are to be documented for each generated data backup:

1. Date of data backup

2. Type of data backup (incremental, full)

3. Number of generations

4. Responsibility for data backup

5. Extent of data backup (files/directories)

6. Data media on which the operational data are stored

7. Data media on which the backup data are stored

8. Data backup hardware and software (with version number)

9. Data backup parameters (type of data backup etc.)

10. Storage location of backup copies

Daily backup should be performed after office-hours when computer usage is low Backup data
should be stored in a tape backup drive as it provides capacity and mobility; hard disk is another
viable option. For a large corporation, backup severs and off-site storage are strongly
recommended.

Backed-up data should be stored at a secure offsite location.


o All backup media should be stored at a safe and secure location. All weekly backup media
should be stored in a fireproof safe. All software full backup

3. The factory has procedures so that employees change their passwords on a periodic basis
Required:

All employees having access to the computer system must change their passwords at least
twice per year.
30
Sample procedures: Employees must change their passwords at least semiannually.

Network administrators should have responsibility to notify computer users regarding


password changes. The network administrator should specify the frequency of password change
and the dates of change, and the server operating software will remind employees about the
change.
Employees who fail to change their passwords within the given period should have their access
to the computer network blocked until unlocked by the system administrator.
Information Technology
Passwords should be a combination of letters and numbers, at least 6 characters long.
Passwords should never be “obvious”, such as choosing birth dates, city names etc.

Employees should change their passwords more often if there is a risk that the privacy of the
password has been compromised. If an employee suspects that another person may have
discovered the password, a new password should be used immediately.

4. The factory has policies to determine which employees are authorized access to its IT
system

The factory must have written procedures to establish which employees are authorized access
to its IT system.
Sample procedures: Only employees from the following departments are authorized access to
the IT system: office support, payroll, warehousing, orders, and sales.

The facility should grant user rights based on job functions. For example, an employee who is
only responsible for payroll should not have access to invoicing or order forms.

When a new employee is hired, his or her immediate supervisor must determine if the
employee needs access to the IT system. If it is determined that the employee needs access, the
supervisor must request access for this employee. The supervisor should send a written request
form to the IT Manager, specifying the employees name and which applications he/or she needs
access to.

Additional Security Suggestions for “Information Technology”

The factory should have written disaster recovery procedures to salvage the computer network
and its data.

The IT team should rehearse the disaster recovery procedures at least once a year.

A disaster recovery plan can be defined as the on-going process of planning, developing and
implementing disaster recovery management procedures and processes to ensure the efficient
and effective resumption of vital company functions in the event of an unscheduled interruption.
All disaster recovery plans must contain the following elements:

o Critical application assessment


o Backup procedures
o Recovery procedures
o Implementation procedures
31
o Test procedures
o Plan maintenance

Information Technology

The IT disaster recovery procedures should be part of the facility’s business disaster recovery
plan.

A member of the senior management team should be appointed to lead the IT disaster recovery
team.

The IT disaster recovery team should identify the components of the facility’s network
framework in order to create and update contingency procedures.

The IT disaster recovery team should conduct and document a risk assessment analysis of the
facility’s IT system.

The IT disaster recovery team should evaluate, prioritize critical and secondary business
functions to be supported.

The IT disaster recovery team should develop, maintain and document written strategic recovery
procedures for all critical and secondary business functions.

The IT disaster recovery team should develop, maintain and distribute listings of individuals of
each critical and secondary business function who can help the facility to recover from the
disaster.

The IT disaster recovery team should develop, maintain and deliver a written IT contingency
plan training program to all IT employees and the person-in-charge of each critical and
secondary business function.

The IT disaster recovery team should test all aspects of the IT contingency plan -- at least
annually. This is critical to the contingency plan's success.

The IT disaster recovery team should develop, maintain and document an effective annual
reassessment of the IT contingency plan.

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11. Education and Training

1. The factory must have a mandatory security program for its employees to
cover recognizing internal conspiracies, maintaining product integrity, and
challenging unauthorized access

The facility should designate certain employee (i.e. line supervisors), not just security guards
need to be trained in basic security procedures. Employees should be encouraged through a
recognition/incentive program to alert supervisors, security guards and law enforcement if there
is a security breech.

All employees should be made aware of which employees have security training and the proper
procedures for reports security breeches.

The necessary training procedures include: Recognizing internal conspiracies:

Employees should be aware of their coworkers and any unauthorized personnel planning or
attempting to commit the following:

Introduction of unauthorized toxins, explosives, weapons or otherwise hazardous materials into


the products, cargo or workspace

Destruction to cargo or products / Theft

Use of materials in a destructive or dangerous manner, or any way that is not consistent with
approved manufacturing procedures

Maintaining Product integrity: Employees should seek to protect products and cargo from
destruction or damage. Employees should ensure that products are handled and stored in a proper
fashion by authorized personnel.

Challenging unauthorized access: Employees must be instructed that they should immediately
alert security or their supervisor if they notice any person on the premises who is not wearing an
employee or visitors badge.

They should also alert security or their supervisor if they notice an employee in a restricted area
and the employee does not work in this area.

The security training should also include an established Threat Awareness program instructing
employees how to recognize threats posed by terrorists and contraband smugglers.

33
The Threat Awareness program should include routine briefings and issuances of memoranda
illustrating smuggling trends, seizures and information on terrorist threats along the logistical
chain.

Factories should document the security-training program for easy verification. Employees should
sign an attendee sheet (see Appendix of Forms, Form L). Before each meeting, an agenda should
be prepared (see Appendix of Forms, Form M).

Education and Training

It is recommended to conduct security training during the “new employee orientation” and to
have a semi-annual refresher session before/or after the fire drill.

To ensure that all employees understand what was communicated in the training, have
employees complete a short quiz and keep the result in the employee file.

Factories should employ creative teaching methods when conducting security training to
include interactive exercises and role playing to ensure that employees are not just passively
taking in the training and that they are actively learning.

Factories should conduct incident response training. Whenever a security breach has taken
place, the issue should be communicated to all employees and employees should be educated in
practices on how to avoid similar problems in the future.

Factories should ensure that security guards receive specialized training. The training can be
provided by the agency that supplies the security guards, or by third parties that specialize in the
training of security officials. Training topics should cover the following areas:

o Bomb threats
o Communications
o Company orientation and policies
o CPR
o Crowd control
o Customer service and public relations
o Emergency response procedures
o Ethics, honesty, professional image and proper conduct
o Fire prevention and control
o Fire equipment
o First Aid
o Harassment and discrimination
o Information security
o Legal aspects of security
o Lock and key control
o Note-taking/report writing
o Patrol techniques and observing unusual circumstances
o Physical security and access control
o Preserving the incident scene
o Safety awareness
o Security awareness
o Substance abuse
34
o Technology in security
o Testimony
o Theft prevention
o Traffic control and parking lot security
o Urban terrorism
o Use of force and force continuum
o Workplace violence

2. The factory must encourage active employee participation in its security


procedures through the use of recognition.

Employees who point out suspicions to management must be recognized for their active
participation in the security program. The same applies for employees who find cartons that have
been tampered with, who discover and report internal conspiracies, who alert security to an
unidentified person on the premises etc.
Recognition can take many forms:

o Making this employee “Employee of the Month”

o Pointing out this employee as a positive example during employee meetings

o Granting the employee an extra paid holiday

o Providing a non-monetary bonus (product samples, movie tickets etc.)

Additional Security Suggestions

A factory should try to involve every employee in creating a secure production environment. It
should be emphasized that security does concern every one on the premises that the workers’
jobs are at stake if any dangerous cargo ever originates from this facility, and that each and every
person can make a difference. It is important to communicate that security is a team effort and
that management is supporting an enhanced security program.

Additional Security Suggestions for “Education and Training”

Factories should have an easily accessible drop box/ letter-box where employees can voice
suspicions anonymously.

The factory should designate a senior level employee to keep up with the latest developments
in terms of Customs Initiatives and new regulations, terrorism threat levels, and security
techniques. This person is encouraged to attend seminars and workshops.

Factories should join security initiatives open to them, such as regional and industry initiatives.
These programs provide very good training opportunities and a offer a chance to keep up with
the latest (security) developments.

The factory should conduct internal audits of its security practices and maintain records of
these audit findings and corrective actions that have been implemented as a result of such audits.

Factories should consider getting independent security consultations from third party providers.
35
12. Appendix of Forms Form A: Employee Badge
Company: ________________________
Employee Name: ___________________
Department: ________
PHOTO
Form B: Restricted Area Access List
Location:
Access granted to:
Name Position
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

Form C: Key Log Form


Key
Issued by
Key
Issued to
Date
Issued
Date
Returned
Key
number(s)
Key use
/Key
description
Notes
(lost key; changed locks,
etc.)
Signature of
36
key issuer
Signature
of key
receiver
1
2

Form D: Non-Business Hours Access List


Security Guard(s) on duty:
_____________________________________________________________________________
Date: ______________________________________________
Name of person seeking
access (print)
Reason Time-in Time-out Signature
1
2
3
4
5

Form E: Visitor Log


Date Visitor’s Name (Print)
Name of contact person at
Factory and/ or Reason for
Visit
Time-In Time-
Out
Signature of
Visitor
Signature of
Employee
monitoring the
Visitor
1
2
3
4
5
6

Form F: Vehicle Log


Date Time-in Time-out Company Driver Name Pick-up or
Delivery
Vehicle type
and Color License Plate
1
2
3
37
4
5
6
7
8
9
10

From G: Transit Monitoring Log Form


Date Shipment
Number
Conveyance
License Plate
Time
Conveyance left factory
Time conveyance arrived at destination
Reasonable
Time
Actual
Time Reasons for Delay
Signature of
Monitoring
Employee
1
2
3

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Form H: Written Application
Applicants Personal Information Sheet

EMPLOYEE START DATE: ______________


EMPLOYEE END DATE: _____________
Date: ______________________________________________
Applying for (position): _______________________________
Applicant’s Name: ____________________________________
Address: __________________________________________________________
Phone: __________________________________________________________
Have you resided at this address for at least 5 years? : Yes 0 No 0
If no, please provide previous address/ addresses:
Previous Address:__________________________________________________
From (date) ________________________ to (date) ______________________
Previous Address:__________________________________________________
From (date) ________________________ to (date) ______________________
Previous Address:__________________________________________________
From (date) ________________________ to (date) ______________________
Education (list school/s and addresses:
Previous Employment:
Company Name: ____________________
Address: _____________________________________________________
Supervisor Name:____________________
Employed from (date)___________ to (date)_______
Position:_________________________________
Company Name: ____________________
Address: _____________________________________________________
Supervisor Name:____________________
Employed from (date)___________ to (date)_______
Position:_________________________________
Relationship with this person: _______________________
Address:_______________________________________________________
Answer this question only if it is legal to ask the question:
Have you ever been arrested? _________
If yes, when and where: _______________
Reason: __________________________
I hereby certify that the above information is true and correct to the best of my knowledge. I
authorize _______________(Company Name) and its officials, as well as third party
investigation companies, to verify all information provided in this application to the extent of the
law. I understand that if any part of this background investigation is illegal, this part will not be
investigated.
Applicant’s Signature: __________________________________
Location and Date: _____________________________________
***********************************************************************
39
Company use only:
Application reviewed by: ________________________
Interview conducted by:_________________________
Reference Checks conducted by:___________________________
Background checks conducted by:___________________________

Form I: Reference Check

Reference Checks conducted by: _________________________________


Residence verification:
Name, Position, Company: ______________________________________
Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________

Name, Position, Company: ______________________________________


Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________
Employment Verification:

Name, Position, Company: ______________________________________


Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________

Name, Position, Company: ______________________________________


Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________
Education Verification:

Name, Position, Company: ______________________________________


Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________

Name, Position, Company: ______________________________________


Contacted on (date): ______________
Contacted by (phone, email, fax, mail, meeting etc.): __________________
Results: ______________________________________________________

40
Form J: Background check
Credit Check
Conducted Yes No
If yes, conducted by: _______________________________________
Conducted on: ____________________________________________
Results: __________________________________________________
Copy attached: Yes No

Drug Screening
Conducted Yes No
If yes, conducted by: ______________________________________
Conducted on: ____________________________________________
Results: __________________________________________________
Copy attached: Yes No

Criminal Background Check (Police Records)


Conducted Yes No
If yes, conducted by: _______________________________________
Conducted on: ____________________________________________
Results: __________________________________________________
Copy attached: Yes No

Form K: Terminated Employee Checklist


Employee Name: _____________________________________
Position(s) held: _____________________________________
Started on: __________________________________________
Terminated on: _______________________________________
Checklist completed by: _______________________________
Item Issued (Yes/No) Returned (Yes/No)
Uniform
Employee Badge
Key 1
Key 2
Key 3
Key 4
Company credit card
Confidential / Company
Documents
Business Cards
Item Issued (Yes/ No) Changed on Changed By
Alarm Code 1
Alarm Code 2
IT access Code

41
Form L: Training Attendee Sheet

Date: __________________

Conducted by:________________________

Topics Covered:
________________________________________________________________________
________________________________________________________________________
Employee Name (Print) Employee Signature
1
2
3
4
5
6
7
8
9
10

Form M: Training Agenda


Training held on (Date): _______________________________________________
Type of Training: ____________________________________________________
Special Reasons: _____________________________________________________
Topics to be discussed:
1. _________________________________________________________________
2. _________________________________________________________________
3. _________________________________________________________________
4. _________________________________________________________________
5. __________________________________________________________________
6. __________________________________________________________________
7. __________________________________________________________________
8. __________________________________________________________________
9. __________________________________________________________________
10. __________________________________________________________________

42
Form N: Security Quiz

Employee Name: _____________________________________________

Date: _______________________________________________________

Question Answer

1 What should you do when you notice someone on the premises not wearing an
Employee or visitors badge?

A I approach the person and ask what they are doing

B I notify the closest security guard

C I trigger the fire alarm

2 What should you do when you notice that the tape on one of the finished goods shipping
cartons has come off?

A I get more tape and close it

B I don’t do anything

C I tell my supervisor that this cartons may have been tampered with

3 What should you do if one of your coworkers asks you if you were interested in making a little
extra money on the side by taking a few products from the premises?

A I call police

B I don’t tell

C I inform my supervisor/manager.

43
Factory Security Policy

The following questions will help you describe how you address each of the Factory Security
requirements. Draft the answers to the questions in the form of procedures that can be
documented and communicated to the employees of the factory. Once completed this can serve
as the internal factory security policy.

PHYSICAL SECURITY
PERIMETER: Where is the entrance to the facility?

What security controls are utilized at the facility entrance to monitor the entry and exit of persons
and vehicles?

What are the procedures for maintaining security at the facility entrance?
LOCKS:

How does the facility ensure that doors and windows are locked when the facility is closed?
Who is responsible?
Answer:

CARGO STORAGE:

How does the facility segregate international and domestic goods/cargo in the warehouse?

How does the facility restrict access to hazardous goods/cargo?

Who is responsible for this?

What mechanisms are used? (Barriers? CCTV? Guards? Etc.)

Who is authorized to access different types of cargo and areas?


Answer:

PACKING AND LOADING:

How does the facility ensure that unauthorized personnel do not enter the packing and loading
areas?

Who is responsible to ensure this?

What mechanisms are used?


(Examples: Security guard who checks badges; CCTV that is monitored; Locked and fenced
area; etc.) If guards are responsible, when are they posted?

44
What types of employees are allowed to enter each of these areas?
Is this documented in any way? Answer:

How does the facility maintain security around the loading area during loading?
What mechanisms are in place?
Who is responsible? Answer:

MAINTAINING CCTV SYSTEMS:

If CCTV is used, who is responsible for monitoring areas where cameras are posted?

What are the procedures when inappropriate activity is detected?

How long are tapes archived?

Who is responsible for this?

Who is responsible for maintenance of this equipment?

Where is the equipment stored?

Who has access to this area? Is it secured?

Answer:

If alarms are used, who has the alarm code?

Who has access to the area where the equipment is stored?

How is that area secured?

What are the procedures in the event of a break-in?


Answer:

TRACKING KEYS:

Who has keys to the facility?


What is the process for giving out a new set of keys?
Is there a log that documents people who have keys?
Answer:

PARKING FOR PRIVATE OR VISITORS VEHICLES:

Is private parking for employees or guest vehicles available?

Are there assigned parking spaces?

Who is responsible to monitor the Parking Area?

Are there procedures in place to challenge unauthorized vehicles?

45
Are all incidents documented?

If so where are these records kept?

How long are they kept?

Who is responsible to maintain these documents?

ACCESS CONTROLS
EMPLOYEE BADGES:

What is the process for creating badges for new employees?

What information needs to be included on a badge?

Who makes and controls the badges?

What do different badges look like for different types of employees with different levels of
access?

Which badges permit employees to enter restricted areas?

What is the procedure for collecting identification, facility, and system access for terminated
employees (badges, keycards, etc.)?
Answer:

VISITOR ACCESS CONTROLS:

What is the procedure for visitors to the facility?

What type of photo identification is required to be presented by visitors?

What are the access points of the facility for visitors?

Who is responsible to ensure that visitors have access to their approved area?

What type of information is recorded on visitor logs?

How long is that kept, and where is it stored?

Who has access to, is responsible for the distribution and the return of visitor’s
badges?

What is the procedure for visitors who do not have photo identification?

Are visitors monitored when they enter the facility?

Who is responsible for this?

Who is informed of the presence of visitors?

Which visitors require closer supervision?


46
In which areas of the facility are visitors prohibited from being unaccompanied?
Answer:

CHALLENGING UNAUTHORIZED PERSONS:

What is the procedure for challenging unauthorized personnel, or visitors who are not wearing a
badge?

What are workers required to do?

What are managers and security guards required to do?

Which areas of the facility are restricted?

What is the process for correcting areas of weakest security?

EMPLOYEE ACCESS CONTROLS:

How are employees verified upon entry? (Examples: Security guard checking badges,
swipe cards, key code, etc.)

How is area access determined?


Answer:

PROCEDURAL SECURITY LOADING PROCEDURES?

What are the security practices related to loading?


Who is responsible for supervising the loading process?
How are containers inspected?
What are the criteria upon which containers are evaluated?
Who is responsible for this?
What is the procedure when abnormalities are found?
Answer:

CARGO TRACKING PROCEDURES:


How does the facility ensure that goods are transported to the port or consolidator in a
timely manner?
Are there different procedures for different situations?
Who is responsible for this?
Is this documented?
Where is documentation kept, and for how long?
What is the procedure when abnormalities are found?
Answer:

47
CARGO VERIFICATION PROCEDURES:

What are the procedures for matching the product count with the shipping documentation?

Who is responsible for this?

How is this documented?

What is the procedure for abnormalities or discrepancies?


Answer:

What are the procedures to verify that all shipments are properly labeled, marked, weighed,
counted, and documented?

Who is responsible for this?


Answer:

SEAL VERIFICATION PROCEDURES:

What are the procedures for verifying seals?


Who is responsible for this?
How is this documented?
What is the procedure when abnormalities are detected?
Answer:

PROHIBITING TRUCK DRIVERS FROM LOADING ACTIVITIES:

What is the policy for truck drivers during loading?


Who is responsible for ensuring that truckers do not participate in loading?
Answer:

ILLEGAL ACTIVITY DETECTION PROCEDURES:

What is the procedure of informing authorities when illegal activities are detected?
What is the chain of command for reporting?
Answer:

48
SHIPPING DOCUMENTATION AUTHORIZATION:

Who is responsible for the creation of all shipping documents?

What are the procedures to prevent unauthorized personnel from accessing shipping documents?

Who is responsible for this? Who is authorized to sign documentation?


Answer:

CONTAINER STORAGE:

What are the procedures for storing empty containers?

Who is responsible to ensure that they are locked and in a secure area?
Are there procedures in place to re-inspect stored containers prior to loading?

Who is responsible for re-inspections?

PERSONNEL SECURITY PRE-EMPLOYMENT SCREENING AND HIRING:

What is the procedure for screening new employees?

Who is responsible for this?

What type of documentation is required to be completed by new employees?

How long is this documentation maintained?

Who is responsible for interviews?


Are there different levels of screening for different types of employees?

Who has access to employee files?

How is access restricted?


Answer:

49
INFORMATION TECHNOLOGY SECURITY COMPUTER NETWORK SECURITY
PROCEDURES:

What are the procedures for securing the computer network?

Who is responsible for this?

Who has access to passwords?

How often are passwords required to be changed?

How is the system backed up?

How often?

How long are tapes archived?

How often is antivirus software updated?

Where is the hardware stored?

Who has access to this?

How is access restricted?


Answer:

EDUCATION AND TRAINING EMPLOYEE SECURITY TRAINING:


How are employees trained about security? Who is responsible for the training and training
materials?
How often are employees required to be trained?
Answer:

50
Security Posters
Poster A

No Parking for Private Vehicles

Poster B:
RESTRICTED ACCESS FOR AUTHORIZED PERSONNEL ONLY

Poster C:

THIS FACILITY IS EQUIPPED WITH A VIDEO SURVEILLANCE


SYSTEM. YOU ARE SUBJECT TO RECORDING.

Poster D:

ALL VISITORS MUST SIGN THE VISITOR LOG

Poster E:
ALL EMPLOYEES, VISITORS, AND THEIR BELONGINGS
(INCLUDING VEHICLES) ARE SUBJECT TO SEARCH.

Poster F:

TRUCK DRIVERS AND THEIR HELPER CANNOT BE IN THE


LOADING AREA. THEY MUST WAIT NEAR THE SECURITY ARE
UNTIL THE LOADING IS COMPLETE.

Poster G:
51
FOR SECURITY CALL:
Mbl :
Ext :

Poster H:
NO TRESPASSING / No Smoking / No Spitting

14. Acceptable forms of Identification and Security Background


Checks that must be copied at time of hire

One of the following documents is an acceptable identification document for all


countries:
1 : Valid Passport
2: Driver’s license with photo
3: National identity card with photo

IDENTIFICATION DOCUMENT SECURITY BACKGROUND CHECKS

FOR INDIA
1: Birth Certificate

2: School Leaving Certificate

3: Voter I.D. Card

4: Age Verification Certificate

5: Medical Certificate (through registered doctor)

6: Driver’s License

7: Ration Card

8: Dental Certificate

9: Affidavit from Panchayat Raj (village elder)


52
10: Affidavit from Notary of the Public

11: School records (offer proof of age and educational background)

12: Police Records: If the person is not able to give any valid reference.

END OF SECURITY MANUAL -

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