2. Sandler & Travis Trade Advisory Services, Inc. Reducing Risk Through Internal Training: Measurement tools to assess training success WESCCON October 16, 2004

3. Sandler & Travis Trade Advisory Services, Inc. What Areas Need to be Measured? Internal Training Programs Procedures & Internal Controls Employee Performance & Expertise Management Oversight

4. Sandler & Travis Trade Advisory Services, Inc. Who Will Measure?  Company (Internal)  Customs & Border Protection  Customers

5. Sandler & Travis Trade Advisory Services, Inc. Company: Internal Compliance Management

6. Sandler & Travis Trade Advisory Services, Inc. Internal Training Programs Subject Matter Curriculum: Various levels (competencies) for personnel Continuing education requirement Effectiveness: Testing on subject matter Job security and advancement dependent upon completion and passing of courses Attendance Lists Review of Internal Procedures

7. Sandler & Travis Trade Advisory Services, Inc. Procedures & Internal Controls Testing of documented processes Internal (or external) audit of key areas Entry preparation Classification & Preference Programs Valuation Recordkeeping Financial obligations Corporate responsibilities Desk level procedures

8. Sandler & Travis Trade Advisory Services, Inc. Employee Performance & Expertise Knowledge of Compliance Areas Commiserate with position Completion of training courses (internal and external) Competency (performance) Random sampling of entries Audit of key areas Adherence to procedures Account Relations Speak to their accounts regarding customer service levels

9. Sandler & Travis Trade Advisory Services, Inc. Management Oversight Document review of competencies and weaknesses (internal audits; personnel growth) Implementation of improvement plans

10. Sandler & Travis Trade Advisory Services, Inc. Customs & Border Protection (CBP) Oversight

11. Sandler & Travis Trade Advisory Services, Inc. CBP Oversight Broker Audits Corporate obligations Transaction review Procedures testing Training programs Client Focused Assessments Relationship defined Review of client SOP Testing of compliance area expertise where client uses broker as their “expert” for reasonable care Entry preparation

12. Sandler & Travis Trade Advisory Services, Inc. Your Customers

13. Sandler & Travis Trade Advisory Services, Inc. The Customer! Relationship – Entry filer or compliance partner? Do they rely on your company to be their “experts” in classification, valuation and preference programs? Do you regularly review these areas of compliance with your customers? During their Focused Assessment, will they hold the broker responsible for the accuracy of their entries? Ultimately, the customer will decide how effective your internal processes and training programs are!!! Definitive success measurement: $$$

14. Sandler & Travis Trade Advisory Services, Inc.