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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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