Subsection 6.11: Staff safety

In order to meet the criterion mentioned in Article 28, paragraph 1, letters e) and g) of the AE CAU, you must:

1. have carried out, to the extent permitted by national law, security screening of potential future employees who may occupy security-sensitive positions and, periodically and where circumstances warrant, carry out general checks on employees currently occupying such positions;
2. Ensure that personnel whose responsibilities relate to security issues regularly participate in awareness-raising programmes on such issues.

6.11.1, a), b) and c)

Your hiring policy should reflect your security requirements based on your risk assessment. Their procedures must provide for:

• background checks on new or existing employees who will be occupying or being transferred to security-sensitive positions,
• obtaining references and using them when carrying out recruitment,
• the identification of security-critical positions and the implementation of the necessary controls to determine the existence of served or unserved sentences,
• the obligation of employees to notify their superior of police warnings, bail situations, pending court proceedings or convictions,
• the removal of access to computer equipment and the return of the security pass in the event of leaving the company or being dismissed,
• notification by employees of any other employment they perform.

All compliance controls must be duly recorded by signature and date in the record of controls carried out.

6.11.2. a) and b)

The appropriate procedures must be provided for in the documents mentioned in question 6.1.2, a) and b). The latter must establish the methods for monitoring new employees before they are hired, as well as an initial and professional training process that instructs them on the company's safety instructions. All new employees must confirm, by signing, that they have understood these instructions. The procedures must also cover the measures to be taken if existing staff are transferred to security-sensitive areas.

6.11.3, a), b), c) and d)

All employees must receive appropriate training on compliance with safety and security requirements, such as security protocols, detection of intrusion or tampering with goods, and incident reporting, as well as risks associated with the international supply chain. A unit or group of people (internal or external) responsible for staff training should be created. If changes occur, this training will need to be updated, and a record of all training activities must be kept.

If training is provided by an external provider, an appropriate service level agreement must be reached. Please also refer to question 6.12.1.

6.11.4. a) and b)

The company must establish safety requirements regarding the use of temporary staff. Your procedures must provide for:

• the conclusion of contracts with employment agencies detailing the level of intensity of the security checks that staff must undergo before and after recruitment,
• exclusive recourse to known agencies that meet the established requirements,
• the application of similar safety standards to temporary and permanent employees (see note 6.11.1).

During the audit visit, you must make these contracts available to the auditor.

The customs authority expects all temporary employees to be subject to the same standards as those for permanent employees. Since these types of staff are often recruited through external temporary employment agencies, service level agreements (see also question 6.12) must be entered into with these agencies, and procedures must be in place to ensure that these agencies adhere to the requirements set out in the agreements and that you record them.