AOIC | VTTI Terminals II B.V.

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Document governance, purpose and scope

This AOIC describes the administrative organisation and measures of internal control of the customs and excise aspects of the terminal operations of VTTI Terminals II B.V.

The AOIC describes:

The CGT team is responsible for the content and maintenance of this document. Any updates to the document are reviewed and processed by CGT. CGT applies the four-eyes principle to all document updates, meaning that any proposed changes are reviewed by another member of the CGT team before a new version is released.

CGT monitors business and legal developments that may require updates to the AOIC and implements such updates where appropriate. In addition, CGT conducts a comprehensive review of the AOIC on an annual basis to ensure that it remains accurate and up to date.

This AOIC serves as the overarching document and refers to supporting procedures and work instructions that describe specific topics in greater detail and provide practical guidance where applicable.

Definitions, abbreviations and acronyms

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AO/IC
 Document describing the Administrative Organization and Measures of Internal Control. Which is this document itself
BzCtrl.   
  Cloud based control tool to perform business controls in a structured and efficient manner
CS
      Customer Services team
ERP
 Enterprise Resource Planning system (Tomcat rebranded and upgraded to ATLAS)
GT&Cs
 General Terms and Conditions
HQ
 Headquarters
OPS
 Operations team
QOL
 Quality Online
C&ECustoms and excise
EUCustoms territory of the EU
HSHarmonised System, the global framework for commodity codes
CNCombined Nomenclature, the EU implementation of the HS
CMSCustoms Management System - software module with automated business rules, linked via an interface with ERP. Used for customs declaration purposes
HSEHealth, Safety and Environment
CGTHQ Customs and Global Trade team

The orange colored callouts in this document refer to a specific compliance risk. Each risk identified is included in VTTI’s Risk Register in BzCtrl. The risk register shows which measures have been implemented to mitigate the respective risk.

The blue colored callouts in this document refer to a procedure or other document that covers the relevant topic in more detail.

Introduction

VTTI is a global company operating in the energy storage sector. It manages and operates terminals for the storage and handling of bulk liquids. Its activities support the storage, distribution, and logistics of these products across international markets. VTTI owns energy storage terminals in EMEA, America's and the APAC region.

VTTI Terminals II B.V. is an intermediate holding entity within the VTTI group and holds the shares in various operational entities that operate terminal facilities.

Statutory relations are included here


VTTI Terminals II B.V. holds the authorisations and maintains the compliance framework for the following terminals:

Euro Tank Terminal (ETT)
Moezelweg 151
3198LS Europoort Rotterdam
The Netherlands

Eurotank Amsterdam (ETA)
Jan van Riebeeckhavenweg 9
1041 AD Amsterdam
The Netherlands

All other operational terminal entities maintain their own customs and excise authorisations, as well as their own customs compliance frameworks and have their own AO/IC.

The only exception concerns the customs warehouse at the following terminal:

VTT Vasiliko (VTTV)
Vasilikos Energy Centre
75 Mari
Larnaca 7736
Cyprus

This location falls within the scope of the cross-border customs warehouse authorisation held by VTTI Terminals II B.V. Even though VTTV maintains its own customs and excise authorisations, the authorisation of its customs warehouse is held by VTTI Terminals II B.V.

More details on how the C&E function for terminal services is organized from a group perspective is included here



Terminal operating model and goods flows

Terminal operating model and goods flows

Operations

From an operational and logistical perspective, the physical terminal process consists of the following steps:

  1. Arrival of incoming product at the terminal by a Mode of Transport (i.e. vessel, barge, truck, rail, or pipeline);
  2. Receipt of the product and transfer between the mode of transport and the storage tank;
  3. Storage of the product and, where applicable, blending, tank-to-tank transfers, or other limited handling operations;
  4. Loading of the product from the storage tank to the designated mode of transport for onward shipment;
  5. Dispatch of outgoing product from the terminal.

Each of these operational steps is initiated by VTTI's customer, who owns the product, through a nomination instruction.

-Overview operations _ flows of goodsUntitled (1)



The goods handled at the terminals comprise petroleum products, chemicals, and other energy-related commodities. These goods are generally classified under Chapters 22, 27, 29, and 38 of the Harmonized System (HS) and Combined Nomenclature (CN).

VTTI's customers operate in global supply chains. Consequently, the origin, customs status, and provenance of the products handled by VTTI may vary considerably, as do the countries of destination to which the products are dispatched.

Customs and excise

Customs and excise

Customs and Excise Authorisations

VTTI holds the following customs and excise authorisations to support its terminal operations and the associated customs and excise activities:



Copies of the customs and excise authorisations are maintained in BzCtrl under the VTTI Terminals II B.V. section (Files → Customs and Excise Licenses).


All customs authorisations listed above apply to the operations of ETT and ETA. The Customs Warehousing authorisation has a broader, cross-border scope and also covers the relevant operations of VTTI in Cyprus. The customs warehousing activities and related records at these locations are administered under a single cross-border authorisation, in accordance with the applicable conditions, controls and administrative requirements.

The Customs Warehousing authorisation permits the use of equivalent goods. The use of equivalent goods is subject to the specific conditions and control measures set out in the authorisation.

The practical application of equivalent goods, including the related control measures, is described in VTTI’s “Equivalent Goods” procedure.



The customs and excise authorisations are crucial to the continuity of VTTI's terminal operations. Their scope determines which operations the terminals can and cannot execute (e.g. which products can be stored or blended). As such, VTTI has implemented measures to prevent non-compliance with authorisation requirements, activities outside the scope of the authorisations, and the unintended expiry of an authorisation. 
See Risk R-01 in the Risk Register.


Customs and excise

Customs procedures

General principles

The customs and excise procedures applied at the terminals are aligned with the operational lifecycle of the goods involved. The operational processes are described in the Operations section of this AO/IC. This chapter describes the customs and excise procedures governing the movement, storage, processing and dispatch of the goods.

Throughout the terminal process, goods may be subject to customs supervision, excise duty suspension or be in free circulation, depending on their customs and excise status. The initial customs and excise treatment is determined upon first arrival at the terminal and may subsequently change during the lifecycle of the goods as a result of storage, blending, manufacturing, transshipment, importation or dispatch activities.

The customs and excise procedures described in this chapter are performed under the authorisations described in the preceding Customs and Excise Authorisations section.

Systems and User involvement

The administration and monitoring of customs and excise procedures is supported by an integrated process involving VTTI’s ERP System, its Customs Module and the relevant VTTI Users. Users register and maintain the operational activities and customs and excise-relevant data in the ERP System. Based on this information and predefined business rules, the Customs Module determines the applicable customs and excise treatment, performs compliance validations and initiates the required customs declarations, excise formalities and record-keeping actions.

Users review and follow up on the resulting system feedback, with Customs Specialists at the terminal or HQ providing support and specialist assessment where required by the nature or complexity of the transaction.

Incoming goods and goods receipt

Upon arrival, goods may enter the terminal under coverage of a Transit document (T1) or an electronic Administrative Document (e-AD). Union goods that are not subject to excise control may arrive without such a document. Goods arriving directly from locations outside the European Union may also arrive without a preceding customs or excise movement document and will be subject to the appropriate customs formalities upon arrival.

During the goods receipt process, VTTI records the arrival of the goods and performs the customs and excise actions associated with the preceding movement procedure. This may include the discharge or closure of transit procedures or excise movements and the registration of the goods and their customs and excise status within the terminal administration.

Storage and processing

Following receipt, the goods are assigned to the customs and excise treatment applicable to their status and intended storage and handling. Non-Union goods are generally placed under the Customs Warehousing procedure, Union goods subject to excise duty suspension are entered into the Excise Warehouse, and other Union goods are recorded in the Free Warehouse.

The terminal location is authorised as a customs warehouse, comprising of the complete infrastructure of tanks, pipelines, jetties and refinery. To optimize storage capacity and avoid disproportionate costs, accounting segregation is applied and non-Union and Union goods are commonly stored.

Non-Union goods may instead, or at a later stage, be released for free circulation. Following their release, the goods are entered into the Excise Warehouse or recorded in the Free Warehouse, depending on whether they are subject to excise duty suspension.

Where goods are blended, manufactured or otherwise processed, the applicable customs and excise treatment is determined based on the customs and excise status and technical characteristics of the goods involved, as well as the nature of the operation. Depending on the outcome of this assessment, the operation may be treated as storage, manufacturing in the Excise Warehouse or Free Warehouse, Usual Forms of Handling under the Customs Warehousing procedure, or Inward Processing.

Outgoing goods

Upon dispatch from the terminal, goods may leave under excise duty suspension covered by an e-AD, under the transit procedure covered by a T1 document, under an export or re-export procedure, or as Union goods in free circulation, where applicable. The required customs declarations, excise messages and supporting records are generated and maintained in accordance with the applicable legal requirements and authorisations.



The detailed functional and technical design of the ERP System and Customs Module, including the Parcel administration model, procedure determination logic, business rules and declaration processes, is described in Annex AO/IC ATLAS-CMS.


The flow chart below provides an overview of the customs and excise procedures that may apply throughout the lifecycle of goods handled at a VTTI terminal.



















































Customs and excise

Customs declarations and discharge of customs procedures


Nomination

VTTI submits customs declarations solely upon instruction from the customer. These instructions are provided through a nomination. The customer is responsible for providing VTTI with all data and documents (information) required to lodge a complete, correct and timely filed customs declaration. Where appropriate, CS performs reasonableness checks on the information provided by the customer before using that information to prepare and submit the customs declaration.

Declaration

VTTI holds an Entry in the Declarant's Records (EIDR) authorisation. EIDR is a customs declaration simplification that allows customs declarations to be lodged by entry in the declarant's records. Declarations are deemed to have been accepted by the customs authorities at the moment the goods are entered in the records. The use of EIDR shifts customs controls from pre-release declaration checks to post-clearance verification of the declarant's records, internal controls, and audit trail. Consequently, customs audits place increased emphasis on the completeness, accuracy, and traceability of entries in the records and on the effectiveness of the company's customs compliance framework.

VTTI applies the EIDR declaration process, to the greatest extent possible, for placing goods under the customs procedures release for free circulation, customs warehousing and inward processing.  VTTI does not apply the EIDR process when placing goods under the export or re-export procedure. For those declarations, a standard export or re-export declaration is submitted electronically. VTTI also does not use the EIDR procedure in situations where this is not permitted. For example, in cases where the release of goods for free circulation requires the presentation of a valid AGRIM certificate. Where EIDR is not used, VTTI lodges customs declarations directly into the declaration system of Customs. This process is embedded in VTTI's ERP and CMS and to a large extent automated.

The EIDR process consists of the following three steps:

  1. Presentation of the goods;
  2. Entry in the declarant's records;
  3. Submission of the supplementary declaration.

Presentation of the goods is the legal act of making goods available to Customs for control, while the presentation notification is the electronic message used to inform Customs that the goods have been presented. A presentation notification is lodged whenever goods are placed under a customs procedure requiring presentation of the goods. When goods are placed under successive customs procedures, Customs may waive the obligation to lodge a presentation notification. Dutch Customs waives this obligation at the second and further placements, provided that the goods are fully traceable in a single administration. This waiver is referred to as the Chain Arrangement (ketenregeling). The principal advantage of the Chain Arrangement is that physical customs controls (if any) can generally be limited to the arrival of the goods at the terminal when they are placed under the first customs procedure in the chain. A key condition for the application of the Chain Arrangement is that, at the first link in the chain, sufficient information and supporting documentation is available to enable Customs to perform any controls that may be required at later stages in the chain. For example, where goods are ultimately intended to be released for free circulation, Customs must be able to verify at the first placement in the chain that all relevant import requirements have been met.

VTTI applies the Chain Arrangement to the greatest extent possible, i.e. wherever the applicable conditions are met. Under the Chain Arrangement, VTTI only lodges a presentation notification when goods first arrive at the terminal and are placed under the customs warehouse procedure. The goods are not presented again when they are subsequently placed under another customs procedure. For example, goods arriving at the terminal are placed under the customs warehousing procedure, followed by inward processing, return to customs warehousing and are ultimately released into free circulation. In this chain, a presentation notification is only lodged when the goods arrive at the terminal and are placed under the customs warehousing procedure.

Entry in the declarant's records is the lodging of a customs declaration through an electronic entry in VTTI's records. At the time of entry, the particulars of the declaration must be available in VTTI's systems and thereby at the disposal of the customs authorities. The entry contains all information required for the application of the relevant customs procedure and serves as the basis for the subsequent supplementary declaration.
 

The supplementary declaration is lodged via the customs declaration system and must be submitted no later than 10 days after the goods have been entered into the declarant's records. The reference period is one calendar day, meaning that all goods entered into the records on a particular day must be covered by supplementary declarations submitted 10 days later. For example, goods entered into the records on 1 January must be covered by supplementary declarations submitted on 11 January. Failure to submit a supplementary declaration within the prescribed deadline constitutes a breach of the conditions of the EIDR authorisation. Depending on the circumstances, Customs may require corrective action, impose administrative penalties, increase compliance monitoring, or, in cases of repeated or serious non-compliance, suspend or revoke the authorisation. 

Each supplementary declaration relates to a single entry in the records. VTTI submits multiple supplementary declarations on a given day, depending on the volume of transactions. Supplementary declarations are not required for goods placed under the customs warehousing procedure.

Monitoring and discharge of customs and excise procedures

VTTI monitors the timely and correct discharge or closure of customs procedures, movements and declarations in which it is involved. This includes, among other things, monitoring confirmations of exit for export and re-export declarations, the discharge of transit movements and e-ADs, and the discharge of the inward processing procedure.

Monitoring and discharge of customs procedures is to a large extent automated and embedded in VTTI’s ERP system and CMS. The systems register the relevant customs procedures and movements, process messages received from the customs authorities, and identify procedures or movements that have not been discharged or closed within the applicable or expected period. For inward processing, declarations entering the procedure are linked to the subsequent declarations or records by which the procedure is discharged.

Open, overdue or otherwise exceptional items are made available for review by the user. The user investigates such items and, where required, obtains supporting information from the customer or other parties involved, submits follow-up messages or evidence to the competent authorities, and takes or initiates corrective action. Items remain subject to monitoring until they have been resolved or otherwise appropriately accounted for.


Automation

The processes for lodging a presentation notification, making an entry into the records, and lodging a supplementary declaration are embedded in VTTI’s ERP system and CMS and are, to a large extent, automated based on predefined business rules. Relevant declarations, messages, supporting records and control actions are archived in VTTI’s ERP system and CMS, which provide an audit trail of the processing and review activities performed. The automated process is subject to continuous monitoring and review by CS and CGT.

Review procedures

Automated processing is prevented where required information is missing or where errors, inconsistencies, or discrepancies are detected in customer-provided data or documentation. In such cases, CS and CGT review and resolve the issue before the relevant message, declaration, or entry is submitted or recorded.

 

The detailed functional and technical design of the ERP System and Customs Module, including the Parcel administration model, procedure determination logic, business rules and declaration processes, is described in Annex AO/IC ATLAS-CMS.



Customs and excise data elements

 
Customs and excise data elements

Introduction

Accurate and complete customs data is essential for maintaining VTTI’s customs records and preparing customs declarations. This chapter describes how the most important customs data elements are established and controlled.

When considering the allocation of risk and responsibility for determining these customs data elements, a distinction should be made between the public law and private law perspectives.

From a public law perspective, more specifically customs and excise legislation, VTTI bears responsibility towards the customs authorities for the accuracy and completeness of the information contained in any customs declaration it lodges and for the authenticity, accuracy and validity of the documents supporting the declaration. This responsibility applies regardless of whether the declaration is lodged in VTTI’s own name or on behalf of a customer under customs representation.

From a private law perspective, the customer is responsible for providing VTTI, in a timely manner, with the information and documentation required to determine the relevant customs data elements and to prepare a complete, correct and timely customs declaration. This responsibility is reflected in the general terms and conditions applicable between VTTI and its customers.

VTTI is generally not the owner, seller, purchaser, manufacturer or producer of the goods. Consequently, VTTI has limited independent visibility of the characteristics and composition of the goods, the underlying supply chain and transactions, the contractual arrangements between the parties involved, and the production or sourcing circumstances relevant to the determination of customs classification, value and origin. VTTI therefore necessarily relies to a significant extent on information and documentation provided by the customer.

From a practical perspective, the determination of customs data elements therefore requires cooperation between VTTI and the customer. The customer provides the relevant information and supporting documentation through the nomination process. On the basis of this information, VTTI determines or records the customs data elements required for its customs records and declarations in accordance with the procedures described in this chapter.

CS performs predefined completeness, consistency, sanity and reasonableness checks on the information and documentation provided by the customer. The nature and extent of these checks depend on the customs data element concerned, the information reasonably available to VTTI and the circumstances of the transaction. These checks do not replace the customer’s responsibility for assessing and substantiating facts and circumstances that are known to the customer but cannot reasonably be independently established by VTTI.

Where required information or documentation is missing, or where a reasonableness check identifies an apparent error, inconsistency or other reason for doubt, CS follows up with the customer before the relevant information is recorded or used in a customs declaration. Where appropriate, CS consults the Customs Specialists at the terminal to determine the required treatment or further action. Where the matter requires further specialist assessment due to its complexity, significance or potential compliance impact, the Customs Specialists at the terminal escalate the matter to CGT.

The relevant customs data elements, supporting information and documentation are recorded or archived in VTTI’s ERP system and CMS. These systems provide an audit trail between the customer’s nomination, the customs data used in VTTI’s administration and the resulting customs declarations.

Customs and excise data elements

Classification

The customer, as owner of the goods, is required to provide the CN code of the product that will be discharged and/or blended (i.e., the CN code of the end product in case of a blend). VTTI’s CS typically receives product analyses which are used to verify the CN code provided by the customer. The CN code provided by the customer is leading and is verified on the basis of incoming customs documentation and product analysis reports in accordance with attached procedure. Should the product analysis show characteristics that contradict with the customer’s nomination, CS will liaise with the customer before the goods are moved to ensure a correct customs declaration can be lodged.

A link to VTTI's "C&E Classification" procedure is included here


VTTI maintains a product database on the basis of the information received from VTTI’s customers and links the products to the appropriate tax treatment. Attached procedure provides specific details on how the product database is maintained.

A link to VTTI's “IT – Product masterdata” procedure is included here.

Customs and excise data elements

Customs value

When a parcel is registered in the terminal's ERP system, the value of that parcel is recorded by CS in line with the current market value. As such, all parcels registered in the ERP system are accompanied by a value.

The value becomes relevant for customs purposes when an import declaration is submitted. Where the applicable import duty rate is 0%, the goods qualify for preferential treatment upon import, or where a specific duty applies (i.e., duties are not calculated over the value but over another factor such as weight), the customs value declared serves a purely statistical purpose and has no financial impact. In such cases, VTTI has agreed with the customs authorities to use the market value registered for the parcel as the customs value.

If the import duty rate exceeds 0%, no preferential treatment applies or customs duties due are calculated on an ad valorem basis, the customs value will be determined in accordance with the general customs valuation framework of the UCC. This means that the customs value will in principle be determined in line with the transaction value method.


Customs and excise data elements

Origin

When an incoming parcel is registered in the terminal’s ERP system, the country of non-preferential origin indicated by the customer in the nomination is recorded by CS. The country of non-preferential origin must be provided before the goods can be accepted at the terminal. Any origin documentation provided by the customer is retained in the Document Management System and linked to the relevant parcel. CS performs a reasonableness check on the origin information and supporting documentation before relying on it for customs or compliance purposes.

Non-preferential origin is relevant for customs declarations and for the application of commercial policy measures, such as sanctions and anti-dumping duties. Where goods leave the terminal without having undergone processing or blending that may affect their origin, VTTI uses the non-preferential origin recorded for the relevant incoming parcel or parcels. Where goods have been blended or otherwise processed at the terminal, VTTI determines the non-preferential origin of the resulting product on the basis of the applicable origin rules and the information available in the terminal’s systems. Until that determination has been completed, no specific country of origin may be used for the resulting product.

Preferential origin becomes relevant where preferential tariff treatment is claimed upon import or where the customer requests a proof of preferential origin for an outbound shipment. For incoming goods, preferential tariff treatment is only claimed where the normally applicable import duty rate exceeds 0%, a preferential arrangement applies and a valid proof of origin is available. For outgoing goods, VTTI only issues, makes out or facilitates a proof of preferential origin where the originating status of the product has been established and substantiated under the applicable preferential arrangement. Where goods have been blended or processed at the terminal, this requires a separate assessment under the product-specific origin rules of the relevant arrangement.

VTTI relies on the origin information and supporting documentation provided by the customer for the goods and materials before their arrival at the terminal. VTTI supplements this information with its own records of the storage, movement, blending and processing activities performed at the terminal. Where the available information is incomplete, inconsistent or gives rise to doubt, VTTI will request clarification or additional supporting documentation. VTTI will not use an origin for customs or compliance purposes, claim preferential tariff treatment or issue, make out or facilitate origin documentation while material concerns remain unresolved.


More practical details on origin are included in VTTI's Origin procedure, which can be found here.



Customs and excise data elements

Quantities

Establishing the quantities of the goods VTTI handles is the responsibility of OPS. Quantities are typically established by means of ENRAF, VTTI’s automated gauging system which is certified. In case of specific reasons, the ENRAF readings turn out to be unreliable, the ENRAF reading can be overwritten with clear explanations as to why the reading was overwritten.

Safety & Security

Safety & Security

Certifications

Both ETT and ETA hold various safety and security certifications.


ETT holds certifications such as:

 

ETA holds certifications such as:


For ISO 9001 (ETA and ETT) and ISO 14001 and 45001 (ETA) both terminals are subject to internal and external audits. Internal audits are required according to the international standards and are implemented and executed by the VTTI Internal auditor or in cooperation with an independent consultant. In order to remain compliant with the standards, both terminals are also subject to external audits coordinated by the HSE department and executed by Lloyd’s Register. These external audits take place once per year.

 


Customer governance

This chapter describes VTTI's contractual relations and procedures for interaction with customers
Customer governance

Customer onboarding process

(tbd)

Stel voor hier een beschrijving op te nemen van de stappen die de terminals zetten bij onboarding van een nieuwe klant:
Customer governance

Contractual relations

The product handled at VTTI’s terminal is typically owned by VTTI’s customers. Part of the contracting phase is that the customer and the terminal map the activities anticipated and the products involved to ensure they are covered by VTTI’s authorisations (article 17.1 GT&C’s).
   
Part of VTTI’s services is handling customs and excise formalities on behalf of VTTI’s customers. To enable VTTI to handle these formalities in a compliant manner, the customer is required to provide VTTI timely with the correct and complete data needed to lodge a particular customs or excise declaration (article 17.2 GT&Cs).

VTTI's General Terms & Conditions are included here.


Customer governance

Customs representation

Most customs declarations lodged by VTTI are based on a customs authorisation held by VTTI:

As a consequence these customs declarations are lodged in VTTI’s own name and on VTTI’s own behalf (i.e., no customs representation is applied).

Only two types of declarations remain where VTTI might lodge a customs declaration on behalf of a customer:

Whether these two types of declarations can be filed under direct- or indirect customs representation depends on the country of establishment of the customer:


Where VTTI files (re-)export declarations on behalf of a customer not established in the EU, VTTI, in addition to acting as declarant, usually also assumes the role of exporter in the (re-)export declaration, as customs legislation requires the exporter to be established in the EU. Given that the exporter must have the power to determine, and must in fact have determined, that the goods are to be taken out of the customs territory, a mandate is required in order to fulfil the conditions for qualification as exporter.

Risk and Control Framework

Risk and Control Framework

Organization personnel

The terminals are managed by the local management team under the direction of the General Manager. The Commercial Manager reports to the General Manager and is responsible for commercial and related support functions, including customs. Responsibility for customs matters lies with the CSC Manager, who reports to the Commercial Manager.

ETT and ETA both have dedicated customs resources. The customs employees at the terminal are supported proactively and upon request by the CGT team at HQ.

Customs employees at the terminals have a hierarchical reporting line to the CSC Manager and a functional reporting line to CGT.

An organization chart of each terminal is included as annex:
ETT - Org chart.pdf 
ETA - Org chart.pdf 

More details on how the C&E function for terminal services is organized from a group perspective is included here.

Risk and Control Framework

Competence and professional qualifications

All employees engaged in customs-related activities have successfully completed training covering applicable customs legislation, aligned with and proportionate to their respective roles and levels of involvement.

To remain up to speed with relevant customs and excise legislation, all VTTI employees involved in customs and excise matters are also subject to a comprehensive, ongoing training program. The program can consist, among other things, of the following elements:


The CGT team is responsible for the training program and determines which trainings are followed by which employee.
Risk and Control Framework

Risk register

All customs and excise compliance risks identified by VTTI are centrally captured in a risk register. For each identified risk, appropriate mitigating measures are implemented. The risk register provides a clear overview of the relationship between risks and their corresponding controls, enabling visibility of both the identified risks and the measures in place to manage them at a glance. Mitigating measures may include internal controls, automated checks or validations within ERP systems, or specific work instructions.

The risk register is included here

Risk and Control Framework

Incident registration

An important element of VTTI’s control framework is incident registration. All employees involved in customs-related activities are trained to identify situations of (potential) non-compliance and to report these. Incidents are registered in the incident registry in BzCtrl.

Registered incidents are discussed by the terminal customs team during the weekly stand-up meeting. Where appropriate, the customs team implements corrective actions to address non-compliant situations. In addition, the team assesses whether further measures are required to reduce the risk of recurrence. Such measures may include additional employee training, updates to work instructions or procedures, improvements in ERP, or the implementation of enhanced internal controls.

Incidents that require additional attention or are relevant from an AEO perspective are reported to the CGT team.

On a quarterly basis, an incident review is conducted during which CGT and the CSC managers of ETA and ETT evaluate incidents from the preceding quarter, identify measures to mitigate the risk of recurrence, and define follow-up actions.
Risk and Control Framework

Computerization and administration

ERP

To ensure compliance with its authorisations, VTTI strongly relies on its ERP system and the measures of internal control therein.

VTTI currently operates an ERP system called ATLAS. ATLAS has been developed in-house to ensure it aligns closely with the specific requirements of the tank storage terminal business. All relevant activities are registered in Atlas.

ATLAS interacts with CMS, VTTI’s customs module, through an interface. Based on standardized, predefined business rules, CMS reviews data input, generates documentation, submits declarations, and provides feedback to the user.

A detailed description of the process governed through ATLAS and CMS is included here.


The previous ERP system, Tomcat, is currently still operational at a number of terminals awaiting the phased, terminal-by-terminal rollout of ATLAS.

The software specialists who manage the ERP system from a technical perspective are employed by VTTI Terminal support services B.V. and have their permanent place at the head office in Rotterdam, the Netherlands.

With regard to the operation of VTTI’s ERP system, the following procedures are relevant to hardware, software, and access control in order to prevent system outages and security breaches.

A detailed description of the IT Authorisation procedure is included here


A detailed description of the Data security procedure is included here


A detailed description of the Technical data procedure is included here


Quality online

Within the VTTI Group, the management system tool QOL is available worldwide as both a document management and reporting tool.

When it comes to customs and excise, QOL is used for:
  • storage of work instructions
  • HSE

BzCtrl.

VTTI uses BzCtrl. as its compliance platform specifically for customs, excise and AEO-compliance. Key functions are:
  • Domains and workspaces – BzCtrl. is structured into multiple domains and workspaces, allowing user‑specific access rights to be defined so that only elements relevant to a particular user are visible.
  • Risk register – All identified customs-related risks are centrally documented. The risk register plays a central role in VTTI’s control framework. Each risk is mitigated through measures designed to keep the risk manageable.
  • Document management – The AO/IC, procedures, work instructions, and other relevant customs & excise documents can be accessed and updated centrally in BzCtrl. BzCtrl includes a revision history function, allowing updates to be monitored and earlier versions to be retrieved. Access rights and authorization to make updates can be granted to specific individuals, or documents can be marked as private, limiting access to a defined group of colleagues.
  • Internal controls – Customs and excise related ICs are integrated in BzCtrl. They can be assigned to a specific user, including a fixed recurrence term, deadline and reviewer. The results of internal controls are made accessible via BzCtrl.’s dashboard function.
  • Incident register – Customs compliance incidents (at HQ or at one of the terminals) are registered centrally in BzCtrl, providing the CGT team with real-time insight, and enabling the team to take measures as needed.
  • Archiving – Documents relevant for customs & excise can be stored in the system. 
  • E-learnings – BzCtrl. is VTTI’s central tool for customs- and excise-related e‑learnings, which can be assigned to specific users based on content and role.
  • To-do – BzCtrl’s to‑do function makes the system suitable for use as a project management tool, enabling the tracking of actions, the setting of deadlines, and the assignment of actions to specific users.



Risk and Control Framework

Schematic overview

Schematically, VTTI's C&E control framework is set up as follows:

Control activities, monitoring and testing

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Control activities, monitoring and testing

Automated controls

VTTI is a technology driven organisation. As such, VTTI aims to automate controls where this is appropriate and useful. Automating controls helps enforcing responsible business operations and compliance with customs and excise legislation.

The automated controls and relating business rules are described in this annex.

Control activities, monitoring and testing

Manual controls

TBD

OUDE TEKST:

On a monthly basis, VTTI’s stocks are reconciled and the (monthly) supplementary declaration (GPA) is sent to Customs. 

A link to VTTI's "C&E - Customs monthly declaration GPA" procedure is included here.


The specific modalities of GPA of VTTI Terminals II B.V. related to the nature of goods (liquid bulk) are captured in the Work agreement with the Customs authorities. 

A link to "Work agreements GPA VTTI Terminals II BV" is included here.


Besides the above controls. several other controls are included in BzCtrl.
Control activities, monitoring and testing

AEO/self-monitoring and continuous improvement

VTTI has integrated the annual AEO-monitoring activities for all the EU-terminals in BzCtrl.

Audit trail
The availability of an adequate audit trail to ensure an efficient and effective audit based customs control. Separation Union from non-Union goods. SAQrev6 3.1 ISO 9001:2015, section 6. SAQrev6 3.2.2.
Accounting system
A satisfactory system of managing commercial and where appropriate, transport records, which allows appropriate customs controls (Articles 39 (b) UCC and 25 UCC IA). SAQrev6 - 3.2; ISO 9001:2015, section 6.
Compliance record
An appropriate record of compliance with customs requirements (Articles 39 (a) UCC and 24 UCC IA). Section 2 from the SAQrev6.
Customs routines
Ensuring compliance with regard to applying the appropriate customs procedures (Subsection 3.5 from SAQ rev6) and non-fiscal measures (Subsection 3.5.4 from SAQ rev6)
Flow of goods
A satisfactory system of managing the appropriate customs treatment of goods handled. SAQrev6 - 3.4; ISO 9001:2015, sections 6,and 7
General information
The purpose of this control is to verify that no crucial changes took place in relation to the organisation, operational licenses and measures of internal control. SAQrev6 Section 1.1 TAXUD/B2/047/2011-REV6
Information security
Procedures as regards back-up, recovery and fall-back and archiving options (Subsection 3.6 from SAQ), protection of computer systems (Subsection 3.7 from SAQrev6) and documentation security (Subsection 3.8 from SAQrev6).
Practical standards of competence or professional qualifications
Practical standards of competence or professional qualifications directly related to the activity carried out (Article 39 (d) UCC, Article 27 UCC IA, AEO Guidelines Part 2 Section IV)
Proven financial solvency
The purpose of this control is to validate that the company continues to meet the criteria around financial solvency. (Article 39 (c) UCC, Article 26 UCC IA, AEO Guidelines Part 2 Section III)