SECURITY MANUAL - Ashton Apparels

GS Textile Industries Kenya EPZ.
, LTD
CTPAT HANDBOOK
Security Manual
18TH SEPTEMBER 2024

GS Textile Industries Kenya EPZ., LTD
CTPAT POLICIES, PROCEDURES & GUIDELINES
SECURITY MANUAL AND POLICY
1. Introduction & Scope:
In response to the events of September 11, 2001, US Customs

(now Customs and Border Protection [CBP] within the
Department of Homeland Security [DHS]) introduced an anti-
terrorism initiative named “Customs-Trade Partnership against
Terrorism” (CTPAT). The initiative is a cooperative partnering of
Customs and the trade community in the war against terrorism.
Customs developed recommendations applicable to the various
actors within the trade community that are designed to enhance
security at US borders.
The program is open to U.S. Importers and logistics services

providers, as well as a select group of foreign manufacturers.
Currently, the program is not open to any of FMG’s suppliers and
factories, but there are plans to expand the program to include
more foreign manufacturers in the future. FMG will make
suppliers aware of the opportunity to join CTPAT once it arises.
FMG strongly encourages its entire product and services
providers to join this important security initiative.
 A voluntary U.S. Government/private sector program to

increase the security of global supply chains
 Partners are required to implement minimum security
measures both in their own companies and with their
suppliers and transportation providers
 Currently only US importers, sea and land carriers, customs
brokers, consolidators and Mexican manufacturers are
allowed to become members
 It is believed that global supply chains could be the next
means used for a terrorist attack
 A terrorist attack at a port causing a temporary shutdown
could cost U.S. economy $58 billion dollars
 C-TPAT is increasing pressure on participant importers and
enforcing compliance of C-TPAT Standards
 This procedure covers all activities relating to Physical

Security, Procedural Security, Access Control, Training &
Awareness and internal audits.
HUMAN RESOURCES & COMPLIANCE

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Page 2 of 48 18TH SEPTEMBER 2024
2. Commitment:
GS Textile Industries Kenya EPZ., LTD is committed to

follow the policies, procedures and guidelines laid down
in its Security Policy and work on continuous
improvement on its day to day operations with respect to
the CTPAT procedures and requirements without any
deviation.
GS Textile Industries Kenya EPZ., LTD is also committed

to educate, train the employees on the CTPAT
requirements and also committed to train and equip the
employees concerned viz., Stores, Transport, Security,
Administration, Finishing, Packing, Loading and Shipping
personnel to understand and adhere to the CTPAT
Standards.
3. Definitions:
 Suspected Activities: The GS Textile Industries Kenya

EPZ., LTD defines suspicious activity to include any of the
following situations:
- Unidentified person(s) attempting to gain access to
property, equipment, or facilities.
- Any person (employee or otherwise) who appears
to be hiding something or is acting nervous,
anxious or secretive.
- Any employee, or contractor or visitor making
unusual or repeated requests for sensitive or
important company or information.
- Any person asking an employee, driver or
contractor to make an unauthorized movement
(pick up or delivery) for cash.
- Any person or group loitering (3 or more) outside/
inside a company facility or premises.
- Any person claiming to be a representative of a
utility (gas, water, electric) but cannot produce
valid company identification.
- Any person carrying a weapon such as gun, knife,
any explosive or flammable liquid.

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- At night, any vehicle driving by a company facility
with lights off.
- Any occupied vehicle parked outside/ inside the
company facility for a long period or after normal
working hours.
- An unfamiliar vehicle that appears to be abandoned
near a company building or parking.
- Unauthorized persons asking questions regarding
product, destination or routing or other trips
specifics.
- Whenever guard is suspicious in incoming and
outgoing materials in contrast to D.O / Gate pass,
report to Security Officer & Admin. Manager for
further actions.
- Shortages or Overages in shipments shall be
reported to Admin. & HR Manager, Shipping
Manager, Factory Manager or the Security Officer.
The above list is not all-inclusive. It is meant to provide possible

examples of suspicious activities. Once, and if, a suspicious activity is
identified, the next step is to act. Be sharp and vigilant.
C-TPAT security requirements cover the following areas:
• Physical Access Controls

• Personnel Security
• Container security
• Procedural Security
• Security Training and Threat Awareness
• Physical Security
• Information Technology
PHYSICAL SECURITY
4.1 Buildings
4.1.1 The factory buildings are constructed bricks cemented

together which resist unlawful and protect against outside
intrusion
4.1.2 Perimeter of the factory premises are surrounded by fence

of at least 6 feet high

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4.1.3 All factory gates/ doors, windows have working locks. And
keys control is maintained by the Security Guard.
4.1.4 The packing department, finished goods warehouse shall

be restricted to prevent theft or illegal insertion
4.1.5 Fence/ walls shall be inspected during enclosure checking

by the patrolling guard for the integrity and damage to
prevent concealment of intruders or packages
4.1.6 Building integrity, perimeter walls, fence integrity shall

have to be checked once in a month both by the Security
Guards during patrolling and by the Compliance Team once
in a month during internal Building interior and exterior
inspection.
4.2 Parking Areas
4.2.1 Parking areas for private vehicles and transportation

vehicles shall be separated from goods loading areas.
4.2.2 All employee shall park their cars at the designated

parking lot arranged for them
4.2.3 Company vehicles shall be parked at the designated areas.
4.2.4 Visitors shall park their vehicles at the VISITOR PARKING

AREA near the guard house.
4.3 Lighting
4.3.1 Adequate lighting is present all over the factory

 At the gate
 Along the boundary wall
 Near loading/ unloading area
 Container parking areas
 CCTV coverage areas
 Exterior of buildings
4.3.2 Any problems detected shall be noted in the Occurrence

Book (OB). And inform Administrator clerk about the
faults who shall immediately inform maintenance to repair.

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4.3.3 Patrolling guard shall check and lookout for the light
system outside the buildings.
4.3.4 Department heads shall be responsible for reporting faulty

lighting to the Administration department who in turn shall
inform the maintenance to repair.
4.4 Enclosure Check
4.4.1 Security guards patrol the factory compound every 4 hours

to verify the conditions of all enclosures. If any discrepancy
is observed the relevant security guard brings this in the
notice of the HR & Administration Manager or calling the
relevant party to report the incident. When security guard
will see any broken gate/window, he will verify whether any
person is hiding inside the section or not. If the answer is
YES then he will complete the following steps:
 He will call other guards to reach at that place
 Will get peoples evacuate from the near by places
 Will call the police
 Will surround the area until or unless police arrive and
the person would be caught
 This incident will be recorded in the INCIDENT
RECORD (OB) BOOK.
4.5 Communication
4.5.1 Internally security guards communicate through Walkie-

Talkie or intercoms (where applicable).
4.5.2 For external communication the security guard at guard

house have direct access.
4.5.3 Emergency Contacts Numbers are displayed at guard

house for easy communication.
4.6 Alarms
 We have the manual operated alarm system in all
section which can be rung at any time for relevant
reasons.

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4.6.1 Functionality of the fire alarm is regularly checks by the
Health & safety officer.
4.6.2 Any alarm out of order he contacts the service provider

and gets it repaired immediately.
4.7 Security guards

 All gates to the factory are manned and monitored.
Likewise our parking and cargo loading and unloading is
also manned and monitored. Security guards are under
supervision of a security officer.
 This security officer is reportable to the Administration

Manager and Financial Controller.
Roles and responsibilities of the Security

Security Guard at Gate
 Security guards are required to verify employees ID upon
entry and exit and check employees going out and coming in
thoroughly. Employees who need to leave the factory
premises during working hours under special circumstances
must have approved “Gate Pass issued by department
supervisor or Department Manager and the time of exit and
return must be logged by security guard in the gate pass.
 Security guard shall report to HR or Administration those who

did not present their employee pass after confirming the
employee’s identity with relevant department supervisor. This
should be allowed inside only with the permission from the
Management.
 When receiving visitors, ask them to present valid photo

identification for documentation purpose, and explain purpose
of visit and the facility contact person prior to entry. Upon the
approval and verification from the staff to visit, security
guards shall record details in “Visitors Log Book and issue
“Visitor Pass” to them. Security guards shall then escort
visitors to the relevant office. Visitor Passes are serially
numbered to verify the account of the same.
 Security will screen the mail & parcel by cutting a small part
of the mail or parcel to identify the content inside the factory

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viz., GS Textile Industries Kenya EPZ., LTD. Details are
recorded in the Incoming Mail / Parcel screening record.
 Security guards are required to check visitor’s luggage and

parcels but attention shall be given to the following aspects:
 Avoid contacting their body
 Mainly check if incoming visitors are
bringing hazardous goods or
unidentified articles into the factory
and check whether outgoing visitors
are taking factory property out the
factory, including corporate products,
materials, semi-finished products or
operating devices.
 Be polite and friendly when checking,
avoiding arousing misunderstanding
and explain the company security
measures when necessary.
 Security guards shall control and record vehicles’ access through

the gate, direct transport vehicles and container trucks to proper
parking berths and then have drivers stay at specified lounging
locations.
 Security Guards require to prepare and maintain Control Log for
incoming and outgoing vehicles, which includes Drivers Name,
Drivers License Number, Reason for Visit, Vehicle No., Security
on duty, place of origin and destination and other relevant
details on a daily basis. The log should have a minimum of 30
days’ details.
 Security guard will check the empty container arrived using

the 7 points system form.
4.7.1.1 Security Guard at Loading & Unloading Areas
 Security guard and store staff shall challenge and keep

unauthorized personnel out of store.
 When external vehicles enter store to unload goods, it is

required to check if they have Delivery Order, Invoice, verify
such sheets with store personnel and conduct onsite
supervision in the process of unloading.

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 When container trucks enters loading zone, it is required to
check if there are any abnormal goods in the loading zone,
open containers to see if everything is normal and forbid
unrelated personnel to access the loading zone. Incoming
goods shall also be checked and inspected at minimum 10%
of the delivery by the store personnel.
 When loading containers, check and maintain security at

Cargo Parking areas. During cargo loading process security
guards shall stay on site to closely oversee loading personnel
and all goods loaded onto containers. After loading is
complete, they shall oversee the container doors are closed
using seal for full cargo & pedal lock for lose cargo.
4.7.1.2 Security Guard at Packing Areas
 Security guard shall check employees coming in & out

thoroughly, challenge and report any unauthorized individuals
entering the Packing area.
 Security guard shall control access by maintaining record of

authorized individuals coming in and out from the packing
area and challenge and keep unauthorized personnel out of
the area.
4.7.1.3 Patrolling Security Guards
 Patrolling security guards shall tour the surrounding areas of

the factory to prevent hazardous articles from being thrown
into the factory premises.
 Patrolling Security guards should go around the entire factory
premises inside during the day time and inside and Exterior
peripheral Walls during the night time.
 Patrolling Security Guards should record the patrolling report
in the incident record or occurrence records with the exact
time of patrolling.
 Patrolling during the night should be once in two hours
without any deviation.
 Patrolling security guards shall check if personnel in factory
premises have ID cards. In case they find any personnel
without ID cards, they shall cross-examine them and report
the case to the HR & Administration Manager.
4.7.1.4 Handover of Security Guard Duties

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 All factory gates/ doors, windows have working locks. And

keys control is maintained by the Security Guard Supervisor
at the guard house (Key Control Log book)
 At the end of each shift duty, both the designated security

guard controlling the keys and keys record and the following
designated security guard on duty shall record the handover
and takeover of keys under their control into the record. (Key
handover record). Both security guards shall check and
ensure that the keys and key record tally.
 To inform of visitors who are still in the factory by showing the

visitor record book.
4.7.1.5 Key controls:
 When keys are given to employees, this act should be noted in a

key logbook
 Keys must be returned when an employee is terminated. If a key

is not returned, the locks must be changed.
 High-security keys (keys that cannot be duplicated) should be

used. The security personnel should be notified in case of any
loss of key with name, ID number and other relevant details.
 Besides the keys of individual workstations, the production

areas, the stores, the finished goods warehouse should be
maintained with a distinct locks, which should be controlled and
monitored on a daily basis
 The work areas and workstations should be kept opened with

sufficient security (if needed) during the business hours and non
operating hours the workstations and work areas should be kept
under lock and key
 The Administrator is overall in charge of the key control

measures and the systemic control
5. Access Control
5.1 Visitor

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 All visitors are required to present identification
document to the guard to record their entry. And will
have to explain their purpose of visit and the facility
contact person prior to entry into the factory premises
 After the visitor’s identity has been verified and

particulars filled in the visitor record book, the visitor
shall sign the Visitor record nook.
 The visitor is given a Visitor Pass
 The visitor shall be escort to the relevant department by

the security guard
 The visitor log book and visitor passes will be handover

to security guard at the end of each shift. Security
guard taking over the task will count the visitor passes
whether tally to the records in the visitor log book.
 If any visitor pass is found missing or cannot be

accounted for, security guard will inform the Security
Officer who will report to the Administration Manager
who will advice whether replacement or not
 All visitors should be escorted and monitored in the

restricted areas by authorized personnel or Top
Management such as Factory Manager, HR &
Administration Manager, General Manager, Director.
 Security guard shall record the time and collect back the
visitor pass at the time of departure. And at the same
time, checking whether the collected visitor pas number
tally to the earlier issued number, which is recorded in
the visitor pass book.
 The interior and boot of all vehicles shall be checked at

the gate.
5.2 Vehicle
 Drivers delivering cargo or drivers of garbage truck
must be identified by Security Guard before entry

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 Security guard shall inspect the vehicles/ truck upon
leaving the factory premises. And verified the exit pass
tally to the carriage
 Security guard shall supervise the filling of diesel into

the company tank
5.3 Employee
 All employees are to put on their Employee Pass upon

entry and exit the factory
 At all times, employees must have their employee pass

worn in the factory premises.
 All employees, belongings and vehicles shall be

inspected by the security guard at the house upon
entering and leaving factory
 Employees shall required to replace their employee

pass when the pass is damaged or lost within 2 working
days
 When an employee is not able to produce the

Employee Pass while entering the factory,
 Security guard shall take down all relevant particulars
and confirm the employee’s identification with the
relevant Supervisor by and report to HR or
Administration.
 The employee shall only be allowed inside with the
permission from Management.
5.3.1 Employee Access to Restricted Zones (Parking, Carton parking

and Finished Goods Warehouse) shall follow the process:
 Employees working in the packing and carton packing
department, their names are listed in the authorized
list.
 Employees are restricted from bringing in their
personal belonging into the restricted area – Airport
Section and Finished Goods Warehouse.

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 Any employee including management staff upon
entering the restricted areas for duty purpose shall fill
in their entrance and exit record in the Packing
department Entrance Log.
Key Control
 All factory gates / main doors have locks and key control is
maintained by security at the Security office.
 Each Department Manager shall be responsible for key

control of the production sections including keys of
alternative and emergency doors and the keys are kept at
the Factory Manager’s office.
 Designated personnel from each department / section

listed below shall check and ensure that all doors and
windows are properly locked at the end of each working
day. They shall also check that machinery / office
equipment, lights and air conditioners, etc. are turned off
before locking up.
 Production floor
 Store, carton stores, fabric stores
 HR & Administration building
 Order processing department
 Marker room & sample room
 Cutting department
 Purchasing department
 Accounts Department
 Others areas such as IT department, clinic, workshop
and canteen.
 Designated personnel of each department shall collect the

office key from the security office each morning and return
the key after work to the security office. The issue and
return of keys shall be logged in the (Keys Record
Control Log).
 At the end of each shift duty, both the designated security

guard controlling the keys and keys record and the
following designated security guard on duty shall record
the handover and takeover of keys under their control into
the (Key handover record).

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 Both security guards shall check and ensure that the keys
and key record tally.
 All keys to respective departments especially the main

door key to the production areas shall be controlled and
kept at the security office.
 All keys to the worker’s hostel premises shall be controlled

and kept at the security office.
 All keys to the clinic, wages office, boardroom, director’s

office and offices inside the HR & Administration building
shall be controlled by the HR & Administration staff and
kept at the HR & Administration office.
 All keys to the housing unit at the management staff

quarters and other company buildings outside the factory
shall be controlled by the HR & Administration staff and
kept at the HR & Administration office.
Procedures to collect & access control items, change password

upon staff / workers turnover
Whenever an employee resigns from the job,

 ID card is collected and posted in the guardhouse and discarded
2 weeks later.
 HR clerk will collect all company belongings via the checklist. E.g.
Room/ Locker keys. This checklist is kept for future ref.
 HR manager will inform Finance department.
 The ID is pasted at Guard House notice board for guard to ensure

this resigned/terminated employee cannot be accessing into the
factory compound.
 The HR manager informs the IT manager to change passwords of

the concerned computer in order to ensure the data and e-mails
integrity, inactive profile in HRMS & remove access in HRMS.

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5.3.2 Identifying and Challenging Unauthorized / Unidentified

Persons
 Employees shall be informed not to assume that a stranger

wandering in the premises of the factory is an employee.
Employees shall alert the Security guard and department
head or supervisor for identification clarification of any
Unidentified and Unauthorized person discovered in both the
premises or in restricted areas
 If the person does not wear GST CARD, the department head
or supervisor should immediately notify the Security or HR &
Administration Manager. The person shall be handed over to
the security for further investigation.
 All Security personnel, HR & Administration Manager and staff

are authorized to challenge any Unidentified or Unauthorized
person and request them to prove his/her identity.
 The Factory Manager can challenge any unauthorized,

unidentified person or unsupervised visitor for entering into
the production area.
CCTV:
 CCTV monitor is placed in the Factory Manager’s Cabin and any

suspicious activity, suspicious entry; intrusion would be
monitored throughout during the business hours.
 All key processes including the Gates, external and internal

boundaries, perimeter wall, security posts, loading, unloading,
packing, finished goods warehousing shall be monitored and
always and surveillance camera for 24/7
 CCTV records for a minimum period of 30 days shall be kept by

the Factory at any given point of time

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5.3.3 Unauthorized / Unidentified Persons Reporting
Procedures Flow Chart
Unidentified /
Unauthorized
Discovered? person / No ID Discovered?
Pass
Workers / Security Guard /

Supervisor Admin staff
Immediately notify
Yes Wear ID Pass / Yes

Identification Identification
Removal
clarification? clarification?
Immediately Immediately
notify No No notify
Production Immediately notify Security

Manager Head
Yes Yes
Investigation HR & Admin. Investigation
any threat? Manager any threat?
No No
Occurrence Further Occurrence
Report/Removal Investigation Report/Removal
Immediate report Immediate report
Law
Enforcement

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6. PROCEDURAL SECURITY
6.1 Receiving Incoming Material Procedures
 Our head office will inform us the cargo dispatched by our

suppliers or from head office. We will get BL and other
documents for clearance purpose from our head office.
 Cargo is required to be cleared from port and hand it over to
transporter. Intimation regarding cargo coming to the factory
is given by our employee in the port to shipping department.
Customer office escorts the cargo when it comes to the
factory.
 Security guards at guard house shall verify the identity of
drivers delivering cargo and check incoming material based
on the Delivery Order/ Packing list of Supplier before allowing
entry into the factory premises
 Store keeper shall verify all materials against Factory
Purchase order. The entire materials will be rejected if it does
not correspond with the details stated in the purchase order
to prevent entry of non-manifested materials
 For import incoming container, BILL OF LADING and PACKING
LIST shall be used to verify the container details and rejected
if details do not correspond to them.
 Store keeper will both quality and quantity checks on all
incoming materials. The quantity, shipping marks, quantity of
cartons and carton weight (to verify at least 10% of the
delivered and record in the INCOMING MATERIAL CHECKLIST,
shall be consistent with that specified in the Purchase order
and Delivery Order.
6.2 Handling Incoming Material Procedures
 All incoming cartons shall be physically counted to ensure

that the quantity tallies with the packing list/ delivery order
and the carton weight of at least 10% of the cartons received
shall be verified for consistency with that specified in
Purchase Order or Delivery Order
 If the carton quantity does not tally with the document on

first count, the cartons shall be recounted a second time. A
third count shall be conducted if the figure again does not
tally with the document. All incoming cartons shall be opened

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and the contents checked by the store supervisor if there is
surplus quantity to prevent the entry of non-manifested
materials or materials without Purchase Order or mix-up of
goods.
 In case shortages and other significant discrepancies, store

shall conduct investigation to find out whether there is any
loss of materials due to theft.
 Purchasing Department and Store should jointly track and

investigate material shortage and surplus, and conduct
investigation on material shortage, loss in production
process, loss and erroneous storage in circulation, damage
resulting from extended storage or expiring shelf life, and
unidentified loss.
 Investigation should be conducted for reasons resulting in

material surplus, including situations where ordered quantity
is excessively large, different types of materials are mixed
and erroneous release of materials orders or order
cancellation. The results of such checks should be recorded in
detail and submitted to the Merchandising Department.
 Store supervisor should probe into solutions based on

material surplus and shortage report; submit solutions, if any
to the Factory Manager for approval. Relevant departments
should handle materials according to such decisions.
 Where anomalies or illegal activities are detected or

suspected, Store personnel shall report to Factory Manager,
HR & Administration Manager or to the Police department.
 Merchandising department should communicate with

customers in a timely manner concerning material damage,
loss and backlog, and probe into solutions with them.
Handling out going cargo procedures (Non Manifested Cargo)
 When packed goods are ready to move into storage

warehouse, cartons should be numbered, weight and marked.
 Packing Supervisor must verify the shipping mark, PO
number, Sty number against with purchase order worksheet.

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 Packed garment from packing department are transferred to
Carton Packing department daily under supervision of
Packing Supervisor and maintain movement record.
 Packing department will send information slip with the
packed garment to CARTON PACKING department
 The Carton Supervisor records the number of quantity
received (P/O wise and COLOR wise) on Daily Entry Register.
Out going cargo procedures
 Outgoing materials (after loading) shall be checked against the

document listed in the OUTGOING CARGO DOCUMENTATION
CHECKLIST.
 Packed goods cartons shall count against the packing list and
random weight at least 10% of the total quantity upon loading
into the container, supervisor shall verify during the weighting
process. Shipping clerk should ensue that record is maintained
and it is signed by the authorized person.
Overages and shortages procedure
 If the carton quantity does not tally with the Packing List on
the first count, the cartons shall be recounted a second time. A
third count shall be conducted if the figure again does not tally
with the document. All outgoing cartons shall be opened and
the contents checked by the Finished Goods Store supervisor
(Carton Packing Manager) if there is surplus quantity to prevent
the entry of non-manifested materials or mix-up of goods into
outbound shipment.
 In case shortages and other significant discrepancies, the

Carton Packing dept. Manager shall conduct investigation or to
find out whether any cartons have been left out or whether
there is any loss due to theft.
 Where anomalies or illegal activities are detected or suspected,
the Carton Packing Dept. shall:
i. Immediately informs the security staff at EXT 133 to verify

the contents
ii. If after the security inspected the suspicious substance
is confirmed, then security guard immediately call
other guards to join him

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iii. Immediately evacuates everyone from adjacent facility
and Carton packing unit
iv. Calls Police or Bomb squad
v. The security keeps people away from the suspected
carton until or unless bomb squad arrives
vi. After appropriate action the incident is recorded in the
OCCURRENCE BOOK (OB).
 Merchandising department should communicate with customers

in a timely manner concerning any short shipment for
acceptance or concession
Outgoing’s shortage / overage flowchart
ST
AR
T
Loading Process
NO
Unload all cartons for recount
Expected
quantity tally?
YES Reload
YES
Tally? NO
Check for mixed up
YES
Tally?
N
O
Recheck packing list and
tally with other documents
YES
Tally?

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N
O
Expected Unload all cartons for recount
quantity
tally?
Seal container & Dispatch END!
6.5 Conveyance and Container / Trailer Security

 Conveyance integrity shall be maintained to protect against the
introduction of unauthorized personnel or material
6.5.1 Loading and Shipping Procedures
 The carton packing supervisor or store personnel shall inspect the

container for physical integrity and for structural serviceability by
using seven point inspection prior to loading as follows and criteria
listed:
6.5.1.1 Areas of Inspection (7 point of Container

inspection)
• Front wall
• Left side
• Right side
• Floor
• Ceiling/roof
• Inside/outside doors
• Outside/undercarriage
In addition, the reliability of the locking mechanisms of the door in the

container should have to be checked for its integrity
The trailer security without refrigeration unit, should also have to go

through 8 more additional points while inspecting. The points are
listed down as below:

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Trailer Inspection Points
1. Fifth wheel area

2. Exterior of trailer
(front and sides)
3. Rear
(bumper and doors)
4. Front wall
5. Left side of container
(external and internal)
6. Right side of container
(external and internal)
7. Interior flooring
8. Ceiling and roof
9. Inside and outside doors
10. External and undercarriage
The records pertaining to the 15 point check, which includes the 7

point check need to be documented for all the containers transported
through trailers.
6.5.1.2 Hidden Compartments
 Containers shall be checked for hidden compartments by :

vii. Checking for the odor of fresh paint, burnt wood or
body filler.
viii. Checking for signs of fresh paint, welding burns, and
variances in wall texture
6.5.1.3 Structural Serviceability
 Check for cracks in the front and rear corner posts
 Check to see if the panels are holed, cut, torn or cracked,

missing loose part of fasteners
 Check for light penetration through defects in door gaskets,

holes, damaged welds, damaged or separated floor boards,
and loose or missing fasteners. This inspection is done inside
the container closing the doors
6.5.2 Inspected result shall be recorded into the 7 Points

Container Inspection Checklist form.

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6.5.3 After container inspection, carton packing workers shall

load finished goods for shipment onto container
6.5.4 A security guard and Finished Goods warehouse Manager

(also the Carton packing Manager) must supervise the
loading of finished goods into the vehicle and the sealing of
containers.
6.5.5 The security guard and Finished Goods warehouse

Manager (also the Carton Packing Manager) may not help with
the loading; his sole duty must be to observe and supervise the
loading process.
6.5.6 Once loading is completed, Finished Goods warehouse

Manager, close container doors and check to make sure all
procedures are completed.
6.5.7 Immediately after loading, Finished Goods warehouse

Manager shall lock carriage doors using Customs seal (Given by
the Customs’ Officer and is recorded in the Internal Security
Seal Inventory– to prevent them from being unlocked in
transit.
6.5.8 The Customs seals shall be strictly controlled, kept, locked

and distributed by the Customs Officer.
6.5.9 The Shipping Manager shall control, keep and lock the
security seals for distribution to the Carton Packing Supervisor
on the day of loading. For every distribution, the shipping
manager shall record the serial number of the security seal and
the container number in the Container Seal Log.
6.5.10 Finished Goods warehouse Manager shall verify Cartons

loading against the Packing List.
 Shipping clerk shall issue Gate Pass, Commercial

Invoice, Custom form and Delivery Order, where
relevant to the transport driver
 Shipping clerk shall ensure all relevant documents are

issued and the required procedures completed by checking
against the Outgoing Cargo Document Checklist before

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passing the Gate Pass for authorization by the Shipping
Manager, Factory Manager or General Manager
 Security guard shall verify the Gate Pass (authorized by

General Manager, Shipping Manager or Financial
Controller), and test-pull the container seal to ensure that
it is intact before loaded trucks / containers are permitted
to leave the factory premises
 Security guard shall record the departure time of

container in the Container Out Tracking Form and
Container Movement Register.
Seal Procedure:
Procedures for affixing and verifying seals on containers,

trailers, and railcars
Container Security
We ensure that container and trailer integrity is maintained to protect
against the introduction of unauthorized material and/or persons.
a) At the point-of-stuffing, we will ensure the procedures are followed
to properly seal and maintain the integrity of the shipping containers
and trailers.
b) A high security seal (examples below) should be affixed to all loaded
containers and trailers bound for the U.S. and all seals must meet or
exceed the current PAS ISO 17712 standard

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Internal Trucks used to Transport to Consolidating base:
For outgoing cargo to the Consolidating base, GST, only closed trucks
with proper padlocks shall be used.
After the loading is done, the customs officer or customs office

representative will put their seal along with the padlock and local seal
of the GS Textile Industries Kenya EPZ., LTD
For incoming raw materials: The Factory verifies that the seal is
intact and that the seal number matches the number stated on the Bill
of Lading. If the seal has been broken, security has been breached. The
only exception would be if the seal had been broken for valid
inspection purposes (customs officials, police) and if the officials would
have noted this inspection on the
Bill of Lading.
For outgoing materials:
Full container Loads: For FMG approved factory loads follow the
sealing practices as prescribed by Buyer
For non-factory loads (freight being transported to the

consolidator for containerization): If your land carrier provides a

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hard-sided, hard-top or boxed truck (see picture), then proper sealing
procedures must be followed.
ABOVE: Hard-sided, Hard-top or boxed trucks
In case of factory loads, seals must be placed on the fully loaded

container. The seal number must be recorded onto the Bill of Lading.
The driver is to be provided with an additional seal. If the original seal
is broken in transit (by a government official), the authority (Police or
Customs) that demanded access to the container must note/mark this
on the Bill of Lading. The driver is then to apply the spare seal on the
container and record the new seal number on the Bill of Lading. In case
of transport of boxed trucks or vans the same procedures apply.
Reporting of Seal Anomalies Procedures for Container Loading:
 Shall any discrepancies, broken seal or missing seal found,

following procedures shall be carried out accordingly;
ix. The transporter company shall enquire the concerned

driver of finding’s time and place and any stopping
during the transit before the finding.
x. The forwarder as well the transporter shall notify GS
Textile Industries Kenya EPZ., LTD’ shipping
manager, who will also notify customs’ officer.
xi. The shipping Manager shall arrive at the happening
place to verify any tampered to the cargo
xii. The cargo shall be truck to forwarder for recounting by
GS Textile Industries Kenya EPZ., LTD shipping
manager with the help of customs’ officer and the
mean time checking every carton to ensure all cartons
are not tampered
xiii. Cargo shall only be released to truck to port after GS
Textile Industries Kenya EPZ., LTD shipping
manager confirmed cargo is ready and can be trucked.
At the same time, forwarder shall issue another seal to
this cargo and shall be locked in the witness of GS
Textile Industries Kenya EPZ., LTD shipping
manager. The new Seal number shall replace the old
seal number in the Bill of Lading (BL).
xiv. The shipping line shall be notified for this anomalies
through mail or fax by the forwarder

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xv. This anomalies shall be recorded in the INCIDENT
RECORD LOG once GS Textile Industries Kenya
EPZ., LTD shipping manager return to factory
Reporting of Seal Anomalies/Tampering of Padlocks Procedures
for Internal Truck Loading:
 Shall any discrepancies, broken seal or missing seal found

or the tampering of padlocks found, the following
procedures shall be carried out accordingly;
xvi. The shipping manager/Shipping executive shall enquire

the concerned driver of finding’s time and place and
any stopping during the transit before the finding.
xvii. The Factory Manager shall notify GS Textile
Industries Kenya EPZ., LTDs shipping manager and
the management, then it will also be notified to
customs’ officer. If in case he is not present during the
transit
xviii. The shipping Manager shall arrive at the happening
place to verify any tampering is done in the truck/cargo
xix. The cargo shall be trucked to consolidating base for
recounting by GS Textile Industries Kenya EPZ.,
LTD shipping manager with the help of customs’ officer
and the mean time checking every carton to ensure all
cartons are not tampered
xx. Cargo shall only be reloaded to the container to port
after GS Textile Industries Kenya EPZ., LTD
shipping manager confirmed cargo is ready and can be
trucked.
xxi. This anomalies shall be recorded in the INCIDENT
RECORD LOG once GS Textile Industries Kenya
EPZ., LTD shipping manager return to the
consolidating base.
Padlocking Empty, Partially Loaded and Fully Loaded

Containers at Factory Loading Area
xxii. All the empty containers must be padlocked by the

security once it reaches factory loading area after the 7
point of container inspection has been carried out and
done.
xxiii. Padlock keys shall be kept by the Security Guard for
security purpose.

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xxiv. All containers; whether it is empty, partially loaded or
fully loaded, must be padlocked; whenever the loading
work has been terminated. Containers must always be
locked unless loading is in process.
xxv. Padlock is to be replaced by the container seal before
leaving the factory loading area for exportation.
Loose Cargo Load (LCL) at Factory Loading Areas:
1) Closed truck will be used for LCL truck if any

2) Cable Seal and Padlock will be used for LCL Truck
3) Cable seals will be inspected by and recorded by shipping clerk
upon receipt and hand over to shipping supervisor for keeping
4) Cable seals will be kept in the drawer with lock
5) Shipping clerk will take photos of the partially load and fully
loaded truck
6) Security Guard and Shipping supervisor will seal the truck with
the cable seal and padlock if necessary
Reporting and Neutralizing Unauthorized Person’s Entry in the

Container Area:
 After container inspection the empty container will be secured

with padlock and parked at storage yard. If an unauthorized
person is found inside the container or inside the container
storage area it shall be immediately notified to HOD, HR
&ADMIN (No. +254796737909) . Precautions must be taken in
apprehending the intruder.
Reporting of Padlock Anomalies Procedures
 Shall any discrepancies, broken padlock or missing padlock

found, following procedures shall be carried out
accordingly:
- Security Guards on duty, Carton Packing Manager and

Shipping Manager must be informed immediately for
inspection and verification.

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- Should the anomalies happen to an empty container, 7
point container inspection must be carried out again before
such container is to be padlocked.
- Should the anomalies happen to a loaded container, cargo

shall be unloaded for recounting and at the meantime
checking every carton to ensure that all cartons are not
tampered before reloading the cargo into the container
again. 7 point container inspection must also be carried out
for such container after unloading has been done and
before reloading starts.
- These anomalies shall be recorded in the INCIDENT

RECORD LOG (OB) for further investigation and
references.
Container Seal Verification
xxvi. When the empty container arrive the factory, the

container and the seal (come along with the empty
container) will be paired and documented. This info
will then be provided to the forwarder. Forwarder
will then provide such info to the shipping
line/carrier for US 24-hour rule filing (AMS).
xxvii. On the other hand, such info will also be provided

to the forwarding agent who is required to key in
the info into the PSA port net system.
xxviii. When the physical container reaches the port, the

port authorities shall check whether the container
seal is intact and container no. and seal no. will be
verified by them as the next step. If it does not tally
with the facility documentation and with the
information in the port net system, container will be
held and rejected for entry. Forwarding agent will
inform shipper for such incident for verification and
investigation.
xxix. If the container no and seal no are matched and

tally with the info in the port net system, such
container will be allowed to gate into the port for
shipping.

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xxx. All container no and seal no are to be documented in
the ocean bill of lading.
6.6 Cargo Tracking
 In order, to enhance the safety or, to avoid any insertion during the
transit time from factory to port for shipment, following steps are
taken to keep track of the transit.
xxxi. Security guard will record the container number, and in
the same time departure date and time in a
CONTAINER TRACKING LOG
xxxii. Then this form is passed to the Shipping department
xxxiii. The shipping clerk will call the container driver’s mobile
phone 2 hours later after his departure to verify his
whereabouts and record his location, verifying person
name and time will be recorded accordingly to the
relevant container
xxxiv. Shipping clerk will record an estimation of transit time
from factory to port as a comparison to refer for
between the actual arriving time
xxxv. Any reasons for delay, if any, shall be recorded in the
container tracking log as well
xxxvi. Transporter driver shall be prohibited from picking up
other goods or passengers along the way and no
detour is permitted
Reporting of anomalistic in shipment
b. Shall any anomalies found in the shipment, the shipping line

shall informed the custom and the forwarder
c. The forwarder shall notify GS Textile Industries Kenya
EPZ., LTD ’S shipping manager whom will record the
anomalies in details in the INCIDENT RECORD LOG
d. GS Textile Industries Kenya EPZ., LTD ’S shipping
manager shall launch a local police report about the
anomalies.
6.7 Cargo Document Control
6.7.1 Incoming documentation processing

 Store personnel shall not receive or release goods until they
have received relevant mandatory documents and data,
including Delivery Order /Purchasing Order issued by supplier.

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 All documents have to be present for storekeeper to start
proceeding receiving process and the documents are recorded
in the INCOMING GOODS DOCUMENTS CHECKLIST.
 In this process, they should keep alert to prevent unauthorized
materials and non-manifested materials from entry.
 When it is found that quantity of products being unloaded does
not match the documents e.g. delivery order, etc, the source of
those products must be notified and the products shall not be
introduced into the store.
 Store personnel shall verify and sign receipt / release
documents after receipt or release. Store supervisor is required
to review such documents and submit original documents to
invoicing department.
 When any order is cancelled or production is complete, store
personnel are required to count relevant materials (customer
materials in particular) and report the quantity of balance
materials to Purchasing department for filing purposes.
6.7.2 Outgoing documentation processing
 Original documents such as receipt / delivery documents and

finished product consignment bills shall be submitted to
Accounts department supervisor the next day. Store shall keep
copies of transport documents for one month and submit
document copies to the relevant departments for filing at the
end of each month.
 Company transport documents, information on company and

customers’ systems shall be kept confidential and from
unauthorized access.
6.7.3 Access of Stores System on Computer:
 Access of store system in computer to edit, to amend or to

modify the details pertaining to incoming and outgoing
documents and information is restricted only to stores
supervisor.
6.8 Manifesting Procedures
 Shipping Executive shall ensure that all documents used in customs

clearing of export cartons are legible complete, accurate and
submitted in a timely manner. Such information shall also be
protected against the exchange, loss or introduction of erroneous

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information through the safeguarding of computer access and
information.
 Description such as style, quantity, no of cartons and

carton weight shall be included in the shipping
documents.
 Only the Shipping Executive or Factory Manager

have authority to make minor (than +/-5%) quantity
changes in shipping documents such as Delivery
Order and initial next to these changes.
6.9 Internal Security Audit
The Security Head/Compliance Assistant shall perform internal security

audit every quarterly and at least once in 12 months to ensure that all
established security measures in the following areas are effectively
implemented and maintained. All checks conducted shall be recorded
in the Internal C-TPAT Compliance Audit Report.
 Physical Access Controls

 Personnel Security
 Shipment Information Controls
 Storage & Distribution
 Procedural Security
 Export Logistics
 Security Training and Threat Awareness
 Physical Security
 Information Technology
 Contractor controls
The Administration Manager shall review security audit results /

findings for the appropriate remedial measures to be taken, if
necessary
6.10 Security Requirements of Business Partners:
a) Contractors/Carriers/Service providers should be required to

notify the facility management, shipping department and
compliance department if there is any breach of security
requirements as per the CTPAT requirements
b) Any business partner who is associated with the GS Textile
Industries Kenya EPZ., LTD Apparel shall adhere to the CTPAT
requirements laid down by the company.

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c) They shall also allow the Compliance Team/Shipping
department to do an onsite audit based on the CTPAT
norms/requirements/expectations laid down and communicated
by the company as and when the need arises.
d) The business partners shall adhere to GS Textile Industries Kenya
EPZ., LTD ’s Code of conduct/business ethics/Labor
Standards/legal compliance which includes human trafficking,
slavery and indentured labor if any
e) Business Partners shall require to do self assessment on the
CTPAT requirements and CTPAT norms laid down and
communicated by GS Textile Industries Kenya EPZ., LTD from
time to time.
f) Business partners shall also be required to do an audit by a third
party on Global Security Standards or equivalent standards at
regular intervals (once in a year)
7. PERSONNEL SECURITY
7.1 Factory shall conduct employment screening and

interviewing of prospective employees to include background
checks and application verifications.
7.2 Employee Interview

a. In the regards all employees are subjected to interviews before
allowing entry to the Factory.
b. During interview, HR executive / HR Manager verify all document

of the applicant.
c. After reviewing applicant’s documents, a second interview is

conducted by the relevant department head which job the
applicant is applying for.
d. Once clear the final interview, he submits the approval to the

HR Manager for the issuance of Employee Pass.
7.3 On going employees verification
e. Factory conducts annual background checks for existing staff

Security, drivers, IT, Accounts, Payroll, Packing, Carton
Packing & Shipping.
7.4 Re-screening of existing employees

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f. Factory will re-screen existing employees based on cause

and position e.g. who will work or would be transferred to
high risk or safety sensitive positions, i.e. Security, drivers,
IT, Accounts, packing, Carton packing and shipping staff.
g. For sensitive employees, back ground checks shall be

conducted annually.
h. For other employees, back ground checks shall be conducted

once every 3 years.
8. INFORMATION TECHNOLOGY SECURITY
8.1 Assigning computers, internet or e-mail access
IT Manager approves computer, internet or e-mail access to

particular section employee upon request from the
department head. And this employee to access with job
related use only. The IT Manager has list of computers with
him.
8.2 Passwords protection & periodic change of passwords
Password are a common means of validating a user’s identity

and thus to establish access rights to information. At GS
Textile Industries Kenya EPZ., LTD all computers and
servers are password protected. In the regards the IT
department has issued passwords to all computer users.
To ensure the access rights. Users are advised:
 All system-level passwords (e.g. root, Windows Admin,

NT Admin, Application Administration accounts, etc)
must be changed once in two months.
 All production system-level passwords must be part of
the Information Technology Administered global
password management database.
 All-user-level passwords (e.g. email, web, desktop
computer, etc) must be changed once in two months.
Screen saver will automatic lock after 5 minutes idle.
 User’s accounts that have system-level privileges
granted through group memberships must have a

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unique password from all other accounts held by that
user.
 Passwords must not be inserted into email messages or
other forms of electronic communication. (e.g. MSN,
Yahoo message, SKPE, etc)
 All user-level and system-level passwords must conform
to the guidelines described below.
Guidelines
General Password Construction Guidelines
Passwords are used for various purposes at GS Textile
Industries Kenya EPZ., LTD . Some of the more
common uses include: user level accounts, web
accounts, email accounts, screen saver protection,
voicemail password, and local router logins. Since very
few systems have support for one-time tokens, everyone
should be aware of how to select strong passwords.
Poor, weak passwords have the following characteristics:
 The password contains less than eight characters

 The password is a word found in a dictionary (English or
foreign)
 The password is a common usage word such as:
o Names of family, pets, friends, co-workers, fantasy

characters, etc.
o Computer terms and names, commands, sites,
companies, hardware, software.
o The words “GS Textile Industries Kenya EPZ., LTD
” or any derivation.
o Birthdays and other personal information such as
address and phone numbers.
o Word or number patterns like “aaabbb”, “QWERTY”,
“123321”, etc.
o Any of the above spelled backwards.
o Any of the above preceded or followed by a digit (e.g.
secret123)
Strong passwords have the following characteristics:
 Contain both upper and lower case characters (e.g. a-z,

A-Z)

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 Have digits and punctuation characters as well as letters
e.g. 0-9,!@#$%^&*()_+|~=\`{}[]:”;’<>?,./)
 Are at least eight alphanumeric characters long.
 Are not words in any language, slang, dialect, jargon, etc.
 Are not based on personal information, names of family,
etc.
 Passwords should never be written down or stored on-
line. Try to create passwords that can be easily
remembered. One way to do this is create a password
based on a song title, affirmation, or other phrase. For
example, the phrase might be: “Tomorrow never die” and
the password could be: “Tm@wn>d~” or some other
variation.
NOTE: Do not use either of these examples as passwords!
Information Access Controls:
1) The electronic information systems are provided to the

relevant functional personnel viz., HR, Accounts,
Compliance, Stores, Production & Shipping
Departments
2) The information access is restricted based on the job
profile of the personnel and the access of other
functional areas are strictly restricted
3) As all the systems are password protected, the
tampering of data or intruding other systems are
strictly prohibited and restricted
4) Any violation on access of irrelevant or compromised
data of other functional area is punishable to the
maximum of termination of employment in accordance
with the degree of intrusion
5) As effective intrusion notification system is installed,
the authorized IT personnel will monitor and control on
a regular basis.
6) HR – Payroll, Time Records, Statutory Benefits data
7) Accounts – All accounts and Finance related data
8) Production – Production, Quality, Output and efficiency
related data
9) Stores – Material movement, Stock and Inventory
Management
10) Compliance – Payroll, Time Records, Personal files,
employee data base etc.,

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11) Shipping Department – Shipping related data viz.
Cargo movement, High Security Seals, Export and
Import Documentation etc.,
All these above control measures are placed and effectively

functioning and any violation regarding the above will be near
to impossible.
Password Protection Standards:
Do not uses the same password for GS Textile

Industries Kenya EPZ., LTD accounts as for other non-
GS Textile Industries Kenya EPZ., LTD access (e.g.
personal email account, option trading, benefits, etc.).
Where possible, don’t use the same password for various
GS Textile Industries Kenya EPZ., LTD access needs.
For example select one password for the ERP systems
and a separate password for Information Technology
systems. Also select a separate password to be used for
a Windows Account.
Do not share GS Textile Industries Kenya EPZ., LTD

passwords with anyone, including administrative
assistants or secretaries. All passwords are to be treated
as sensitive, Confidential GS Textile Industries Kenya
EPZ., LTD information.
Hers is a list of “don’ts”:
 Don’t reveal a password over the phone to

ANYONE
 Don’t reveal a password in an email message
 Don’t reveal a password to the boss
 Don’t talk about a password in front of others
 Don’t hint at the format of a password (e.g. “my
family name”)
 Don’t reveal a password on questionnaires or
security forms
 Don’t share a password with family members
 Don’t reveal a password to co-workers while on
vacation

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If someone demands a password, refer them to this
document or have them call someone in the Information
Technology Department.
Do not use the “Remember Password” feature of

applications (e.g. Eudora, Outlook, and Netscape
Messenger).
Again, do not write password down and store them

anywhere in your office. Do not store password in a file
on ANY computer system without encryption. Change
passwords at least once in EVERY TWO MONTHS.
If an account or password is been suspected to have

being compromised, report the incident of Information
Technology and change all passwords.
Password cracking or guessing may be performed on a

periodic or random basis by Information Technology or its
delegates. If a password is guessed or cracked during
one of these scans, the user will be required to change it.
8.3 Regular back up of e-mail and data:
 IT department takes back copies of the essential business

information and software at regular intervals. This is to
ensure that al essential business information and software
can be recovered, following a disaster or media failure.
8.4 Individually assigned IT access accounts
Following steps have been taken to prevent unauthorized

access to information systems.
 Redundant user IDs and accounts are periodically checked
and remove (after every quarterly)
 Access rights of user who change jobs are immediately

removed
 User’s access rights are revised at regular intervals

(biannually)

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 The path from the user terminal to the servers are controlled
& secured. Users can work only on those paths or home
directories, which are allowed or have rights on servers.
 Access to multi-user information is controlled:

- Servers have unique user Ids
- Servers have unique home directories
8.5 Control IT abuse Method
 Install Firewall to control any IT abuse, Firewall providing anti-

spam, malware and intrusion prevention, and URL filtering
services.
 A firewall is a dedicated appliance, or software running on
another computer, which inspects network traffic passing
through it, and denies or permits passage based on a set of
rules.
 A firewall's basic task is to regulate some of the flow of traffic
between computer networks of different trust levels. Typical
examples are the Internet which is a zone with no trust and
an internal network which is a zone of higher trust. A zone
with an intermediate trust level, situated between the
Internet and a trusted internal network, is often referred to as
a "perimeter network" or Demilitarized zone (DMZ).
8.6 Procedure to train and brief IT security & abuse
 IT department shall conduct briefing for relevant employees

on company IT policy, company regulations and disciplinary
actions for violation of company regulations of IT abuse.
 Briefing and training shall be done by a competent person,

who is an IT expert with knowledge of CTPAT requirements
on Information Technology Safety
 Conducted as and when required to provide or update

relevant personnel on current information or changes, where
applicable.
 Users shall be trained to prevent unauthorized access to

computers and information with the use/ change of password,
password protection, screen saver, etc.

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 Users shall be trained to scan software, files, e-mails with
attachments, downloads from internet for any virus/
hazardous programming codes with anti virus before
processing/ opening.
 Users shall be train on proper handling of hardware.
 Employees shall be encouraged to report violation of IT

security/ company regulations of IT abuse to IT Manager.
8.7 Procedure for disciplining IT abusers
 Any unauthorized use of IT equipment by any employee

should be reported to senior management. Disciplinary action
will depend on extent of abuse. Minor abuse can be a warning
letter in writing and major abuse can be termination of
employee.
 Management will consider whether any change in policy or

procedure is required to stop such abuse
8.8 Procedure to change the passwords upon termination/

resignation of employees
 IT Manager provides the HR & Administration Manager an

updated list of IT service users at regular intervals.
 Whenever an employee resigned/ terminated from the job

(who is listed on service user list), the HR & Administration
Manager informs the IT Manager to change passwords of the
concerned computer in order to ensure the data and e-mails
integrity.
9. Education & Training Awareness
a. We do provide CTPAT security training to all our staff

including Security & Shipping.
9.1 SECURITY TRAINING & AWARENESS
9.1.1 Purpose

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The purpose of this procedure is to implement
effective Security Training & Awareness to ensure
the security and safety of company property and
employees.
9.1.2 Scope
These procedures are applicable to all activities
involved in Security Training & Awareness.
9.1.3 Responsibilities
 It shall be the responsibility of the HR and

Administration Department to arrange training
for new / all employees to enable employees to
establish an understanding of company policies
and systems on quality, environment, safety
and health, security, company regulations,
anti-terrorism measures as well as access
control protection, procedures for challenging
unauthorized / unidentified persons,
recognizing and reporting internal conspiracies,
personal safety and risk / threat awareness and
maintain the relevant records and files.

Administration Department to plan, organize
and supervise the implementation of the
training programs and maintain the relevant
records and files.

Administration Department to organize training
on health and safety such as fire safety /
control, first aid, personal safety, personal
protective equipment maintenance, chemical
spill handling and emergency evacuation and
maintain training records.
 Briefing and training shall be conducted as and

when required to provide or update all /
relevant employees on current information or
changes, where applicable.
9.1.4 Procedures

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Enhancement of Security and Threat

Awareness
 To protect company property and ensure employees’

personal safety, prevent delayed customs clearance
of goods and in response to C-TPAT anti-terrorist
program, following anti-terrorist training outlines
have been formulated to intensify security and threat
awareness of all employees.
 Establish a threat awareness program maintained by

security to foster awareness of threat posed by
terrorists at each point of the supply chain,
 Educate employees to enhance security awareness

and of company’s anti-terrorist reporting procedures,
the name list and telephone numbers to contact in
case of emergency,
 Post company’s Code of Conduct and Security

Guidelines in prominent locations in the factory,
 Explain to employees the importance of wearing the

valid Identification Pass when entering or leaving
through factory gate for the purpose of preventing
unauthorized personnel from entry into factory
premises,
 Conduct security checks on all articles carried by

personnel entering and leaving factory premises,
prevent and prohibit hazardous articles from entry,
and effectively prevent loss to company property,
 Encourage employees to actively participate in

security control by reporting to relevant department
supervisors / management immediately of any illegal
or suspicious activities / mail / packages detected or of
finding strangers without employee cards in factory
premises and acts against factory rules and
regulations.
 Inform and train employees on procedures for

handling and reporting unexpected events.

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 Provide training to employees on recognizing internal

conspiracies including conspiracy to steal company
materials or finished products; deliberate substitution
of finished products; failure to pack in compliance with
instructions; vicious input of prohibited articles or
chemicals in finished product cartons; use of materials
in a destructive or dangerous manner or any way that
is not consistent with approved manufacturing
procedures.
 Provide training to employees on recognizing external

collusion, suspected involvement of any employee in
unidentified organizations or with terrorist tendency.
 Intensify training for personnel at important posts,

particularly:
- Security training for security guards to protect

access control and maintain security,
o -Identifying and reporting shortages and
overages for store /loading personnel,
o -Prevention of entry of unauthorized
articles / non-manifested materials in
day-to-day production activities for store
personnel,
o -Maintenance of cargo integrity for store,
packing, loading and shipping personnel.
 Ensure store personnel are aware of the importance
of their posts, accept and release goods based on
documents, and assist security personnel in
supervising and controlling the entry of unauthorized
personnel into loading / unloading zones; report to
supervisors or security supervisor immediately upon
detection of suspicious activities or unidentified
goods / packages.
 Ensure store personnel and production clerks

maintain consistency between accounting and actual
quality / quantity of incoming / outgoing materials
and stocks.

VERSION 7
 Ensure store personnel conduct scheduled inventory
checks and report to supervisors immediately when
finding any damage, loss, shortage or surplus.
 Provide training on chemical / hazardous materials

safety to help employees establish an understanding
of the characteristics of the substances used through
issue of training materials, handling and storage
procedures as well as treatment of injuries.
 Prohibit employees from going around the factory

without authorization or entering restricted areas such
as finished product Store, loading / unloading zones,
parking areas, chemical storage zone, oil depot and
other zones with “Danger” and “No Entry” signs.
 Encourage employees to appreciate their jobs and

protect company property; operate and maintain tools
and machines in compliance with instructions and
report to supervisors when finding any anomaly or
damage; clear up work stations and close doors and
windows near to their work stations at the end of the
day.
9.1.5 Security Guard Training Procedures
 Security training shall focus on anti terrorist training

for security personnel probe into and formulate
security solutions in combination with the
characteristics and trends of terrorist activities.
 Security training shall emphasize security guards’

compliance with Security Post Responsibilities
and Duties.
 Security training should be offered to security guards

once every month for the purpose of intensifying
their security awareness and protection skills for
handling unexpected events.
 Security guards should strictly implement handover

and takeover systems, take detailed records for

VERSION 7
events occurring for the current shift and hand over
them for next shift to follow up.
 Security guards should improve their qualifications

and security protection skills.
 Security guards should be neatly dressed, well

postured, wear name tag and employee card while at
work.
 Security guards should observe good discipline and

work ethics, comply with regulations and rules. Be
polite and enthusiastic, and give detailed
explanations to possible inquiries.
 For security-related events occurring in individual

departments or areas, it is required to contact and
inform HR & Administration Department
immediately. In case such events required
immediate handling, relevant personnel may be
requested to stay on-site to provide assistance.
 If such events require further investigation, relevant

departments should coordinate with the HR &
Administration Department in investigation, probe
into handling proposals and submit such proposals
for security supervisor to implement.
9.1.6 Rewarding Employees reporting suspicious

activities, material and person
i. The management has formulated a policy to reward

those who share information about any of the following
issues. The below sequence of arrangement of issues is
related to amount of reward attached i.e if someone
reports – more than 1 he will get the highest reward
ii. Terrorist or criminal
iii. Serious threat to factory employees
iv. Reporting theft
v. Reporting person carrying ammunition
vi. Serious threat to factory buildings
vii. Reporting conspiracy

VERSION 7
Incentive scheme for identifying suspicious activities and movement of
personnel will range from Kshs. 1000 – Kshs. 5000.
10.1 INCOMING COURIER AND MAILS PROCEDURE
1. The courier/mails should be received by the security guards.

2. They will register and open the courier in the book writing AWB
no./date/the time received/checking the quantity and description
of goods.
3. The courier/mails and the register book will be passed on
reception.
4. To make copy of AWB and supporting documents for reference.
5. The receptionist will open the courier, confirm description and
the actual item tally. Handover the parcel to relevant person
and have it acknowledged on documents and register book by
signing(If they are more than one items and it has to be
delivered to more than one person than it should be
acknowledged by those person for the items they have received
separately).
6. To send the copy of AWB and supporting documents to store
and confirm that the store has received it by writing the date /
time and name of person who has confirmed it.
7. File the original AWB and copy of docs for office.
8. Official mails/letters are opened and dispatched to relevant
departments and individual mails/letters delivered to owners.
11.1 Security polices and procedures
 Security policy requires that all polices & procedures are

required to be maintained in writing. Security policy should
be reviewed periodically by senior management person.
Amendments to security polices and procedures should be in
writing and must be conveyed to all concerned.
12. Human Trafficking:
GS Textile Industries Kenya EPZ., LTD, as a company and any of its

affiliates, subcontractors, suppliers shall not engage in activities
related to human trafficking nor deploy trafficked persons to provide
services of any form for any period of time.
The procedures mentioned below are clearly depicting the guidelines

to be strictly taken into consideration while hire or deploy trafficked
workers in our factory in any form of labor or any defined or undefined

VERSION 7
period of service. Similarly, we ensure no anomalies pertaining to
human trafficking and slavery policies.
1) All the documents pertaining to the shipment of the relevant

merchandise, should be loaded under the supervision of the
shipping executive, customs officer and the security people
2) All the personnel involved in the shipment process shall be
trained on the cargo verification procedure to prevent un-
manifested cargo and /or illegal aliens from being loaded
3) If any such anomaly is noticed, the issue has to be notified to the
Top Management Personnel of the factory and the aftermath
procedures to be followed as mentioned in the clause no.3.
This shall also be notified to the local legal authorities and other
relevant authorities as the case may be.
b) We have a recruitment policy and procedure that prevents trafficked

victims from employment. Human Resource personnel are trained for
implementation of this policy.
d) In the event of any such case of trafficked persons working within
their facilities and/or of their subcontractors, we, as a company shall
immediately remediate the issue according to the requirements
stipulated in local laws and regulations. In countries where such laws
and regulations do not exist, the we, as a company should:
I. Ensure employees suspected of being trafficked to stop working

immediately.
II. Pay the trafficked employees’ wages including the current

month and any back payment owed to them.
III. Provide health examination and psychotherapy to trafficked

victims if the employees are found to be suffering psychological
trauma.
IV. Notify local authorities and ensure they are returned to their
home country according to law.
V. If trafficked victims were recruited through third parties, We

shall stop using their services.
VI. Conduct internal investigations within 5 business days to

discover if there are other trafficked persons deployed and
implement corrective actions.

VERSION 7
13. Security Risk Assessment:
 Security Officer must prepare and review the Security Risk

Assessment atleast once in a year and supposed to have
discussion with Management for further actions.

VERSION 7

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GS Textile Industries Kenya EPZ.

18TH SEPTEMBER 2024

1. Introduction & Scope:

In response to the events of September 11, 2001, US Customs

The program is open to U.S. Importers and logistics services

 A voluntary U.S. Government/private sector program to

 This procedure covers all activities relating to Physical

HUMAN RESOURCES & COMPLIANCE

GS Textile Industries Kenya EPZ., LTD is committed to

GS Textile Industries Kenya EPZ., LTD is also committed

 Suspected Activities: The GS Textile Industries Kenya

HUMAN RESOURCES & COMPLIANCE

The above list is not all-inclusive. It is meant to provide possible

C-TPAT security requirements cover the following areas:

• Physical Access Controls

4.1.1 The factory buildings are constructed bricks cemented

4.1.2 Perimeter of the factory premises are surrounded by fence

HUMAN RESOURCES & COMPLIANCE

4.1.4 The packing department, finished goods warehouse shall

4.1.5 Fence/ walls shall be inspected during enclosure checking

4.1.6 Building integrity, perimeter walls, fence integrity shall

4.2 Parking Areas

4.2.1 Parking areas for private vehicles and transportation

4.2.2 All employee shall park their cars at the designated

4.2.3 Company vehicles shall be parked at the designated areas.

4.2.4 Visitors shall park their vehicles at the VISITOR PARKING

4.3.1 Adequate lighting is present all over the factory

4.3.2 Any problems detected shall be noted in the Occurrence

HUMAN RESOURCES & COMPLIANCE

4.3.4 Department heads shall be responsible for reporting faulty

4.4 Enclosure Check

4.4.1 Security guards patrol the factory compound every 4 hours

4.5.1 Internally security guards communicate through Walkie-

4.5.2 For external communication the security guard at guard

4.5.3 Emergency Contacts Numbers are displayed at guard

HUMAN RESOURCES & COMPLIANCE

4.6.2 Any alarm out of order he contacts the service provider

4.7 Security guards

 This security officer is reportable to the Administration

Roles and responsibilities of the Security

 Security guard shall report to HR or Administration those who

 When receiving visitors, ask them to present valid photo

HUMAN RESOURCES & COMPLIANCE

 Security guards are required to check visitor’s luggage and

 Security guards shall control and record vehicles’ access through

 Security guard will check the empty container arrived using

4.7.1.1 Security Guard at Loading & Unloading Areas

 Security guard and store staff shall challenge and keep

 When external vehicles enter store to unload goods, it is

HUMAN RESOURCES & COMPLIANCE

 When loading containers, check and maintain security at

4.7.1.2 Security Guard at Packing Areas

 Security guard shall check employees coming in & out

 Security guard shall control access by maintaining record of

4.7.1.3 Patrolling Security Guards

 Patrolling security guards shall tour the surrounding areas of

4.7.1.4 Handover of Security Guard Duties

HUMAN RESOURCES & COMPLIANCE

 All factory gates/ doors, windows have working locks. And

 At the end of each shift duty, both the designated security