Additional Measures of Internal Control

In addition to the internal control measures embedded within VTTI’s Terminal Management System, BzCtrl. is implemented as a dedicated compliance tool to support and govern CGT compliance.

BzCtrl. is currently used for the following purposes:

1. (Bi-)weekly stand-up meetings
   Short (maximum 15-minute) meetings with terminals to enable the CSC Manager to track CGT-related action items and to ensure ongoing involvement of the HQ CGT team.

2. Periodic controls (automatically scheduled) and KPIs, including:
   a. Monthly stock reconciliations, forming the basis for monthly customs declarations;
   b. Bi-weekly verification of the discharge of outgoing documents and monitoring of follow-up actions;
   c. Periodic incident reviews to identify structural root causes and to feed outcomes into training and process optimization.

3. Annual AEO compliance monitoring controls
   Controls based on FETSA industry standards to ensure continued compliance with the requirements of the AEO authorisation, which serves as an umbrella license for all customs-related permits.

4. Training and awareness
   A basic set of e-learning modules based on FETSA industry standards, supplemented by VTTI-specific e-learning programs tailored to various roles and the full UCC learning program as offered by the European Commission.