One of our critical roles as trade compliance professionals is to get out there and provide training to other process stakeholders (internal and external) on a periodic basis. However, this critical and fundamental objective is often overlooked or neglected for a variety of reasons:
- We’re too busy with normal operations
- We don’t have the resources necessary to develop and administer training
- We can’t get an audience or on the agenda with the group or groups that need training
- Our company does not embrace compliance training
- Our leader is a shy introvert and is presentation averse
- Training requires travel and we have no budget
- We have a corporate training department that handles all training
No matter what the reason, you should never underestimate the value of training. While it’s difficult to quantify and qualify “problem or penalty avoidance”, if you have successfully used training to correct potential compliance problems, keep track of those achievements and report them to management.
If you’ve had the opportunity to hear me speak publicly, you might remember that I fervently believe that to be successful in our “trade compliance mission” our trade compliance tentacles must reach out and touch, interact, communicate with and/or control a variety of internal and external stakeholders. The slide below depicts vital internal and external stakeholders and has been previously instrumental in opening the eyes of many senior executives. If you would like a copy of this in a PowerPoint format please don’t hesitate to send your request to [email protected].
My motto in a past life at a very large retail importer was, “I’ll speak or talk to anyone who will listen.” Not necessarily to promote our self-worth to the company, but to help our internal and external stakeholders understand the complexities of our business and to help us strategize how we can best accomplish our compliance mission. When given the opportunity to address a department meeting or large group I always did my best to keep the talks entertaining and informative. For example, when addressing the Buyers, Merchants or Sourcing group, I had a cart of past products that had caused us problems with U.S. Customs and Border Protection (CBP) or some other federal agency. The product examples were not there to embarrass anyone (although it was known as the “Product Hall of Shame”), but they were instrumental in helping me explain just how complex our business really is. I would hold up a product and tell them about arguments we had with CBP on tariff classification, or I would have examples of items that had cause problems with the Consumer Products Safety Commission (CPSC) or had unintentionally violated another company’s intellectual property. Along the way I would tell a few other humorous stories about past CBP issues and before too long, I became one of the most sought after speakers in the company; some departments who asked me to speak weren’t even compliance stakeholders! I did not want to be viewed by them as the “crabby compliance curmudgeon” that would always tell them, “No” with no reasoning behind the answer. I wanted them to know that we were their “partners” and “consultants” in matters related to global shipping and encouraged them to contact us any time they had questions. Training helps you stay in the sub-consciousness or psyche of those persons or departments that you rely on to perform flawlessly in the name of your compliance objectives. Mistakes or missteps by them may cause compliance errors or problems further downstream.
Periodic training also helps you discharge your all-important obligation as a U.S. importer or exporter to undertake “reasonable care” in your global business operations. Some CBP programs like C-TPAT require annual training to maintain the company’s C-TPAT Certification. If your company is the subject of a CBP Focused Assessment or a Bureau of Industry Security audit, as a part of your compliance improvement process you may be obligated to offer training.
So, what should we train on? Of course the answer to this question is dependent largely on your operation and your “customer”. In a retail setting that might likely be the Buyers, Merchants or Sourcing. If you’re a manufacturer, most likely you’ll need train the Engineers and Procurement. If you are an exporter it is likely that you’ll need to train Sales or Marketing and Finance. At a minimum, as you design your training you might consider some of these topics:
- Import or Export 101
- New initiatives
- Problematic situations
- Refresher courses
- Vendor/Supplier compliance requirements
- Record keeping requirements
- Denied Party Screening (for exports)
- New Vendor/Customer Onboarding (for imports or exports)
- New item set-up or tariff classification
Your ability to offer training may be limited by your company’s corporate culture; some C-Suites will only listen to outside experts; others will shrug it off. Training is a form of communication. It’s a critical skill in a business setting that frankly speaking, not too many companies are really good at. Larger companies may have internal training departments, but they are not qualified and they are not subject matter experts. While you can collaborate with them to prepare and in some cases deliver training, I would highly recommend that someone from the trade compliance department be in the room when the training is delivered. Corporate training areas are good at delivering “Business Writing Skills”, “Conflict Resolution” or “Diversity” classes; but in most cases I believe that they should not routinely be leveraged to perform trade compliance training. If you or your department leader is shy, find someone else to do your training for you. Topical or specific trade compliance training is something that can be easily outsourced. Trade Innovations offers a variety of corporate compliance training. Please contact us at [email protected] today to discuss your specific requirements or objectives.