Control framework

The CGT team actively builds, maintains, and develops a professional network comprising industry professionals, customers, and relevant authorities to remain informed of CGT developments that may impact VTTI’s business. Relevant knowledge and functional developments are proactively translated into VTTI’s business practices.

Knowledge of legislative changes and relevant case law is kept up to date through this professional network and via a knowledge database maintained by the Federation of European Tank Storage Associations (FETSA) through BzCtrl.

BzCtrl is used to provide local managers and professionals with easy access to applicable legislation, policies, guidance documents, and training materials.

Projects

The timely involvement of the CGT team in projects is governed by the VTTI Project Lifecycle Guidelines, from the business development stage through to project commissioning or acquisition by VTTI. The latest version of the VTTI Project Lifecycle Guidelines is available in the QOL database.

Contracts

Given the substantial fiscal liabilities involved, VTTI’s General Terms and Conditions (GT&Cs) include shared responsibility between VTTI and its customers to ensure that all goods and activities related to the services provided are covered by the appropriate customs permits.

In general, VTTI terminals operate under one of the following models:

1. Customer-managed customs formalities
   The customer is responsible for customs formalities. VTTI has a derived responsibility to align its operational processes and record-keeping to support the customer’s compliance with applicable customs requirements.

2. VTTI-managed customs formalities
   VTTI is fiscally responsible for all customs formalities and holds the required permits.

All contracts must be reviewed and approved by the Legal team. For CGT-related matters, essential compliance provisions are embedded in the GT&Cs to ensure adherence to applicable customs and tax regulations.

Day-to-Day Operations

Depending on the extent to which CGT impacts terminal operations, an umbrella document—the Description of the Administrative Organization and Internal Control Measures (AO/IC)—is in place. This document describes how the terminal is organized from a CGT perspective and covers, among others, the organizational setup, roles and responsibilities, required competence levels and how these are ensured, the activities performed and goods handled, applicable permits, and internal control measures. The AO/IC forms the basis for licenses and license applications.

Terminal operations include inbound, storage, blending, and outbound activities. All such operations are governed by permits that require VTTI to be in control of its processes. This includes ensuring full visibility of the goods handled and their customs status (e.g. domestic versus bonded, excise-controlled versus non-excise-controlled).

A fundamental principle applicable to all terminals is that customers nominate the requested manipulations. Customers are responsible for providing complete and accurate data in a timely manner. This information is critical to ensure that validations and determinations are performed on the correct basis.

Customer Service (CS) teams receive the nominations, validate and enter the data into Tomcat/ATLAS, and prepare the Order/Activity such that all required information is available prior to execution. Based on the data included in the Order/Activity, Operations (OPS) teams perform a gatekeeper role by validating that the data aligns with the documentation accompanying the cargo.

Based on the validated input data, products and activities are assessed against the applicable permits in Tomcat/ATLAS, and the required customs and tax declarations are submitted.

In addition to the AO/IC, detailed procedures and work instructions are in place to safeguard compliance. Business controls are implemented to verify that procedures are followed and that they achieve the intended control objectives.