Xerox Supplier Security Requirements

Transcription

1 Xerox Supplier Security Requirements Suppliers who are involved in the manufacture, storage, and transportation of Xerox products ( Suppliers ) for Xerox Corporation and / or its subsidiaries under Xerox Corporation s control (collectively Xerox ) are required, at a minimum, to meet the following Xerox Supplier Security Requirements. 1. Supplier Security Requirements: The Xerox Supplier Security Requirements listed herein need to be present in the security / business processes and practices of Suppliers, as allowed by law, for the manufacture, storage, and transportation of Xerox products to satisfy requirements of the United States Customs-Trade Partnership Against Terrorism (C-TPAT) and the European Union Authorised Economic Operator (AEO) programs that Xerox participates in. a) Suppliers will notify Xerox in writing of C-TPAT, EU AEO or any other certification by foreign customs administrations supply chain security programs. Certification information can be ed to: CorporateSecurity@xerox.com b) Suppliers will notify Xerox in writing within five (5) business days in the event their C-TPAT, EU AEO certification or other certification is suspended, revoked or cancelled. c) Suppliers will include current and future criteria contained in the Xerox Supplier Security Requirements in their security / business process. Xerox Supplier Security Requirements are, in part, based on criteria found in C-TPAT and EU AEO guidelines. Criteria for the C-TPAT program can be found at the following link: d) Suppliers should also take steps designed to incorporate these Xerox Supplier Security Requirements into their agreements with their suppliers who manufacture, load, transit, accept, store, deliver, or otherwise affect the integrity of Xerox shipments e) In order to comply with Importer Security Filing requirements for ocean shipments under U.S. Customs and Border Protection regulations, Supplier will provide full cooperation and support as reasonably requested by Xerox, including without limitation, providing complete and accurate data to Xerox s applicable freight forwarder at least 48 hours prior to loading the shipment aboard a vessel destined for the U.S. Supplier shall indemnify and hold Xerox harmless from any fines, penalties, damages, costs and expenses levied against Xerox due to Supplier s failure to comply with the foregoing. 2. Container and Trailer Security and Inspection: Container and trailer integrity protects against the introduction of unauthorized material and/or persons and to prevent the unauthorized removal of material. At point of stuffing, procedures must be in place to properly inspect, seal and maintain the integrity of the shipping containers and trailers. A high security seal must be affixed to all loaded containers and trailers bound for Xerox that will cross an international border. All seals must meet or exceed the current PAS ISO standards for high security seals. a) Container Inspection: Documented procedures must be in place and followed to verify the physical integrity of the container structure prior to stuffing, to include the reliability of the locking mechanisms of the doors. The following seven-point inspection process must be followed and documented for all containers to ensure that there are no hidden compartments in which unauthorized material could be hidden: 1. Front wall 2. Left side 3. Right side 4. Floor 5. Ceiling/Roof 6. Inside/Outside doors 7. Outside /Undercarriage Xerox Supplier Security Requirements 01/25/2018) Page 1 of 5

2 b) Trailer Inspection: Procedures must be in place to verify the physical integrity of the trailer structure prior to stuffing, to include the reliability of the locking mechanisms of the doors. The following ten-point process must be followed and documented: 1. Fifth wheel area check natural compartment/skid plate 2. Exterior front/sides 3. Rear bumpers/doors 4. Front wall 5. Left side 6. Right side 7. Floor 8. Ceiling/Roof 9. Inside/Outside doors 10. Outside/Undercarriage c) Container and Trailer Seals: Written procedures must stipulate how seals are to be controlled and affixed to loaded containers and trailers, to include procedures for recognizing and reporting compromised seals and/or containers/trailers to Xerox and appropriate local authorities. Only designated Supplier employees should distribute container seals for integrity purposes. d) Removal of Container Seals: Suppliers who are accepting sealed shipments for Xerox must take steps to ensure the integrity of the seal prior removing it from a container/trailer. The seal must be inspected to ensure the number matches the information on the shipping documents. It must also be inspected for signs of tampering or compromise. If evidence of tampering or compromise is found, the container/trailer should not be opened until management and Xerox Corporate Security is notified. d) Container and Trailer Storage: Containers and trailers must be stored in a secure area to prevent unauthorized access and/or manipulation. Procedures must be in place for reporting and neutralizing unauthorized entry into containers/trailers or container storage areas. 3. Conveyance Security: Conveyances are defined as the combined tractor trailer/container. Conveyances must be secured to prevent against the introduction of non-manifested goods being added to them and to prevent unauthorized access to the actual container/trailer while they are under the control of the Supplier. a) Conveyance Security: Procedures must be in place to ensure that conveyances are capable of being effectively secured against the introduction of unauthorized material and persons. b) Conveyance Inspection: Procedures must be in place to ensure that potential places of concealment of illegal goods on conveyances (natural or hidden) are regularly inspected. All internal and external compartments and panels must be secured. c) Tracking and Monitoring of Conveyance: Procedures must be in place to track and accurately monitor activities relating to the movement of conveyances containing Xerox products both within the Supplier s premises and at handover points between the Supplier and external parties. The tracking and monitoring system can be via (a) electronic means (e.g., transponders, smart cards, electronic seals, videos, digital photos, mobile phones, radios and Global Positioning Systems (GPS)) or (b) activity logs, etc. d) Operators Guide: Operators of conveyances must be trained to maintain the security of the conveyances and the cargo at all times and to report any actual or suspicious incident to designated security department staff. Guidelines must be in place to train operators on: (1) Detail route planning for pick up and delivery; (2) Confidentiality of load, route and destination; (3) Policy on keys, parking area, refueling, and unscheduled stops; and (4) Installation and testing of security alarms and tracking devices, if any. e) Storage of Conveyance: Conveyances must be stored in a secure area and/or manner as to prevent unauthorized access and/or tampering. Xerox Supplier Security Requirements 01/25/2018) Page 2 of 5

3 4. Physical Access Controls: Access controls prevent unauthorized entry to facilities, maintain control of Supplier s employees and visitors, and protect company assets. Access control processes must include a method to establish the positive identification of all Supplier employees, visitors, and vendors at all points of entry. a) Supplier Employees: An employee identification system must be in place for positive identification and access control purposes. Supplier employees should only be given access to those areas necessary for the performance of their duties. Company management or security personnel for Supplier must adequately control the issuance and removal of Supplier employee, visitor and vendor identification badges. Procedures for the issuance, removal and changing of access devices (e.g. keys, key cards, etc.) must be documented. b) Visitors: Visitors must present photo identification for documentation purposes upon arrival. All visitors should be escorted and visibly display temporary identification. A visitors log must be retained for at least 30 days. c) Driver Identification: All drivers of inbound or outbound loads must be identified using a government issued photo ID (driver s license) and recorded on a log. d) Deliveries (including mail): Proper vendor ID and/or photo identification must be presented for documentation purposes upon arrival by all vendors. Arriving packages and mail should be periodically screened before being disseminated e) Challenging and Removing Unauthorized Persons: Procedures must be in place to identify, challenge and address unauthorized/unidentified persons. 5. Personnel Security: Processes must be in place to screen prospective employees of Supplier and to periodically check current employees of Supplier, including those set forth below, as permitted by applicable law. The purpose is to verify the prospective employee s identity and that their background and employment experience does not demonstrate unethical or illegal conduct that would affect their performance of assigned duties. In the event a Supplier s contract with Xerox contains additional pre-employment verification, background check and/or drug screening requirements, the Supplier must comply with such requirements as permitted by applicable law and, if such requirements conflict with those contained in these Xerox Supplier Security Requirements, the Supplier s contract with Xerox shall take precedence. a) Pre-Employment Verification: Application information, such as employment history, references, and job performance, must be verified prior to employment. b) Background Checks / Investigations: Consistent with governmental regulations, background checks and investigations should be conducted for prospective employees of Supplier. c) Personnel Termination Procedures: Companies must have procedures in place to remove identification, facility, and system access for terminated employees of Supplier. 6. Procedural Security: Security measures must be in place to ensure the integrity and security of processes relevant to the transportation, handling, and storage of cargo in the supply chain. a) Documentation Processing: Procedures must be in place to ensure that all information used in the clearing of merchandise/cargo is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information. Documentation control must include safeguarding computer access and information. b) Manifesting Procedures: To help ensure the integrity of shipments, procedures must be in place to ensure that information required to support the shipping of products to Xerox is provided to Xerox and other entities as required to support the shipment process and is reported accurately and timely. Xerox Supplier Security Requirements 01/25/2018) Page 3 of 5

4 c) Shipping & Receiving: Arriving cargo must be reconciled against information on the cargo manifest. The cargo should be accurately described, and the weights, labels, marks and piece count indicated and verified. Departing cargo should be verified against purchase or delivery orders. Drivers delivering or receiving cargo must be positively identified before cargo is received or released. d) Storage of Xerox Products: Storage of finished Xerox products must be separated by a physical barrier from Xerox products staged on loading docks awaiting shipment. e) Cargo Discrepancies: All shortages, overages, and other significant discrepancies or anomalies must be resolved and/or investigated appropriately. Applicable law enforcement agencies must be notified if illegal or suspicious activities are detected, as appropriate. f) Property Control: Controls must be in place to control the removal of property. g) Losses & Incidents: All losses and other incidents concerning Xerox products must be reported to Xerox Corporate Security (CorporateSecurity@xerox.com) or ) within 1 business day. Supplier must fully investigate losses and other incidents concerning Xerox products under their control. 7. Physical Security: Facilities must have physical barriers and deterrents that guard against unauthorized access. Physical security criteria include: a) Fencing: As practicable, perimeter fencing should enclose the areas around cargo handling and storage facilities. Interior fencing within a cargo handling structure should be used to segregate domestic, international, high value, and hazardous cargo. All fencing must be regularly inspected for integrity and damage. b) Gates and Gate Houses: Gates used to control access through which vehicles and/or personnel enter or exit must be manned and/or monitored. The number of gates should be kept to the minimum necessary for proper access and safety. c) Parking: Private passenger vehicles should be prohibited from parking without authorization in or adjacent to cargo handling and storage area. d) Building Structure: Buildings must be constructed of materials that resist unlawful entry. The integrity of structures must be maintained by periodic inspection and repair. e) Locking Devices and Key Controls: All external and internal windows, gates and fences must be secured with locking devices. Management or security personnel must control the issuance of all locks and keys. f) Lighting: Adequate lighting must be provided inside and outside the facility including the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas. g) Alarms Systems & Video Surveillance Cameras: Alarm systems and video surveillance cameras utilized to monitor premises and prevent unauthorized access to cargo handling and storage areas must be functioning and maintained. CCTV images must be maintained for at least 60 days. 8. Security Training and Threat Awareness: A threat awareness program must be in place and maintained to recognize and foster awareness of the threat posed to Xerox products at each point in the supply chain. Supplier s employees must be made aware of the procedures the Supplier has in place to address a situation and how to report it. Additional training should be provided to Supplier employees in the shipping and receiving areas, as well as those receiving and opening mail. a) Specific training should be offered to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls. b) A process for reporting security incidents should be in place and made available to all employees. Xerox Supplier Security Requirements 01/25/2018) Page 4 of 5

5 9. Information Technology Security: a) Password Protection: Automated systems must use individually assigned accounts that require a periodic change of password. IT security policies, procedures and standards must be in place and provided to Supplier s employees in the form of training. b) Accountability: A system must be in place to identify the abuse of IT including improper access, tampering or the altering of business data. All system violators must be subject to disciplinary actions for abuse, as permitted by applicable law. 10. Compliance Process: Xerox will assess a Supplier s compliance with these Xerox Supplier Security Requirements through an online self assessment completed by the Supplier and through a physical audit. a) Self Assessments: Suppliers will complete an online security assessment via the Xerox Supplier Security Assessment Tool (XSSAT) that measures compliance with these Xerox Supplier Security Requirements. Follow up online assessments will be required once per year, or more frequently in the event there is a material change to a Supplier s scope of work for Xerox, a significant change in a Supplier s security process, or at the request of Xerox. The survey can be initiated by completing a Self Assessment Initiation Form found at: b) Audit: Suppliers will provide Xerox and any agent of Xerox, access, upon reasonable notice, to their records and facilities in connection with an audit to determine compliance with these Xerox Supplier Security Requirements. c) Non-Compliance with Xerox Supplier Security Requirements: Suppliers shall identify areas of its operations that are found to be in non-compliance based on the online security assessment and / or Xerox audit and promptly develop and implement a plan to correct such non-compliance. 11. Questions: Suppliers should contact Xerox with any questions or requests for exceptions to these Xerox Supplier Security Requirements to Xerox Corporate Security (CorporateSecurity@xerox.com). Any exceptions granted by Xerox to these Xerox Supplier Security Requirements shall be made in writing (including without limitation, or other electronic format) by Xerox Corporate Security. 12. DISCLAIMER: THESE XEROX SUPPLIER SECURITY REQUIREMENTS ARE MINIMUM REQUIREMENTS TO BE A SUPPLIER TO XEROX AND SHALL ONLY BE FOLLOWED AS PERMITTED BY APPLICABLE LAW. XEROX DOES NOT REPRESENT OR WARRANT THAT COMPLYING WITH THESE XEROX SUPPLIER SECURITY REQUIREMENTS WILL BE ADEQUATE TO ADDRESS A SUPPLIER S SECURITY NEEDS. Xerox Supplier Security Requirements 01/25/2018) Page 5 of 5