C-TPAT and Trade Best Practices

Customs-Trade Partnership Against Terrorism (C-TPAT)

Informing All Federal-Mogul Holdings Corporation Suppliers of Global Security Best Practices

Federal-Mogul Corporation is a participant in Customs-Trade Partnership Against Terrorism (CTPAT), Authorized Economic Operators (AEO) and Partners-in-Protection (PIP). As a participant, we have made a firm commitment to enhance the security of goods moving through our international supply chain. To implement this commitment, we are verifying whether our suppliers, vendors, and service providers have active security programs in place.

Your firm is receiving this request because you provide or supply our company with goods or services. It is an important issue for Federal-Mogul that our suppliers acknowledge and strive to integrate the philosophy of Federal-Mogul's Security Guidelines into their processes. Further, it is our expectation that suppliers will cooperate fully with our Certification Program and return their completed form.

As you know, the Security Initiatives are voluntary programs, and while Federal-Mogul expects its suppliers to share its commitment to security of the supply chain, it is your decision whether or not to join the program. We are attaching Federal-Mogul's security recommendations. These recommendations are broad and general in nature and not all of the recommendations may be appropriate for every service provider. Many providers already have extensive security measures in place, which will coincide with the recommendations listed below.

Please complete the Trade Best Practices and Security Initiative Form (C-TPAT, AEO, PIP) and return via email.

We sincerely appreciate your cooperation and request that your company join us in our efforts to improve our supply chain integrity by embracing the various Security Initiatives and complying with them to the best of your company's ability. Please contact me if you have any questions.

Wendy S. Himebaugh
Global Trade Compliance Sr. Manager
Federal-Mogul Corporation
Telephone: 248-354-7084
Fax: 248-354-8972

FACILITY SECURITY BEST PRACTICES

Federal-Mogul Corporation is participating in C-TPAT, AEO and PIP programs and is committed to enhancing its supply chain security to help prevent future terrorist attacks. While the program is voluntary, Federal-Mogul Corporation expects that its suppliers will develop and implement a sound plan to enhance their security procedures as well. To assist in that effort, Federal-Mogul Corporation provides these general recommendations that should be followed :

Physical Security :

All buildings should be constructed of materials that resist unlawful entry to protect against outside intrusion. Physical security should include :

• Adequate locking devices for external and internal doors, windows, gates, and fences.
• Walls or fences six feet or higher around the facility or other adequate security measures.
• Adequate lighting provided inside and outside the facility to include parking areas.
• Separate parking area for private vehicles separate from the shipping, loading dock, and cargo areas.
• Segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged, or otherwise fenced-in area.
• Having internal/external communications systems in place to contact internal security personnel or local law enforcement police as necessary.

Access Controls :

Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include :

• The positive identification of all employees, visitors and vendors.
• Limited issuance of keys or access cards, and recovery of those keys or cards when an employee resigns or is terminated.
• Visitors screening before being allowed entry to the factory.
• Procedures for challenging unauthorized/unidentified persons.

Procedural Security :

Measures for the handling of incoming and outgoing goods should include the protection against the introduction, exchange, or loss of any legal or illegal material. Security controls should include :

• Having a designated security officer to supervise the introduction/removal of cargo.
• Ensuring properly marked, weighed, counted, and documented products.
• Procedures for verifying seals on containers, trailers, and railcars.
• Procedures for detecting and reporting shortages and overages.
• Procedures for tracking the timely movement of incoming and outgoing goods.
• Proper storage of empty and full containers to prevent unauthorized access.
• Procedures to notify CBP and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company.

Personnel Security:

Companies should conduct employment screening and interviewing of prospective employees to include periodic background checks and application verifications.

Education and Training Awareness:

A security awareness program should be provided to employees including recognizing internal conspiracies, maintaining product integrity, and determining and addressing unauthorized access.