The document discusses diversification strategies for companies looking to transition into the aerospace and defense industries. It outlines the typical timeline of 1-2 years for planning and preparation. UHY Advisors has experience helping various companies implement diversification plans, providing assistance with certifications, standards, and market analysis. They have partnerships to help clients with opportunities in aerospace and defense.
3. Diversification
[di-vur-suh-fi-key-shuh ] – “the act or practice of manufacturing a variety of products, investing in a variety of
securities, selling a variety of merchandise, etc., so that a failure in or an economic slump affecting one of them
will not be disastrous”.
Diversification is not an easy task; the timeline to a successful effort is typically one to two years of
planning, research, and preparation. Likewise, the process requires resources and a commitment to
achieve success. UHY Advisors, Inc. has been actively and aggressively involved in assisting our clients
in their diversification efforts.
Recent projects include:
• A Tooling/Fixture Design and Build company located in Romeo, Michigan. Provided Aerospace
OEM standards and AS9100 implementation assistance.
• A Design and Build Automotive Tooling Company located in Sterling Heights, Michigan. Provided
guidance and implementation assistance in ITAR compliance, AS9100, Process Mapping and
Supplier Qualification / Evaluation.
• A Global Distribution company with 500+ employees located in Lawrence, Pennsylvania. Providing
transition guidance and implementation assistance in the areas of Strategic Planning, AS9100,
Aerospace/Defense contract analysis and First Article Inspection.
• A CNC / Screw Machine Metal Fabrication company located in South Lyon, Michigan. Providing
aerospace diversification planning and AS9100 implementation guidance.
• A Metal Forming Design/Build Machinery company with operations in Ohio, China and Germany.
Providing aerospace and defense market analysis and diversification strategy planning, Profitability
/ Cost Management modeling, Tool Design Optimization and AS9100 implementation assistance.
• An FAA Repair Station located in Saline, Michigan. Provided training and guidance in the
implementation of AS9110, Lean Enterprise, Problem Solving and Process Mapping.
In addition to the deliverables highlighted in the above client projects, UHY Advisors has the expertise
to provide assistance in the areas of:
• Diversification strategic plan development
• Industry teaming partnerships/collaboration
• Implementation of aerospace OEM standards, such as Boeing’s DPD Procedures
• Awareness and preparation for defense-related requirements such as Federal Acquisition
Regulations, DCAA Audit Preparation / Accounting requirements, Risk Management, etc.
UHY has established a core set of industry partnerships to better serve our client base as they explore
diversification and implement strategic plans. We use the expertise in these partnerships to deliver
focused recommendations and project actions. Our partnerships include entities such as:
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
4.
5. o The TMLytle Group:
The TMLytle Group is headed by Col. Tom Lytle (Ret). Tom has 28 years of defense expertise and
is working with UHY and our clients to assist identifying and developing a strategic market
penetration plan. Tom provides tactical marketing guidance and has a well established DoD
buyer network of influencers and decision makers.
o JRG Associated, LTD:
JRG Associates is comprised of a team of specialists with multiple years of hands-on experience
working in the aviation industry. JRG Associates has a working relationship with aviation OEMs
such as Pratt & Whitney, Rolls-Royce, Hamilton Sundstrand and GE.
o Industrial Visions Company:
Industrial Visions Company is a market and business development resource that services small to
medium-sized, business-to-business manufacturers and service providers. UHY and IVC have
joined to assist companies in market planning and diversification business development
initiatives.
o Dusek Network:
The Dusek Network is headed by Rich Dusek. Rich has extensive experience in aerospace,
automotive and military land vehicle industries. Rich is the former director of an aerospace and
defense division of a large German-owned company.
o OEM Teaming:
Working relationships with OEM such as Raytheon, Boeing and Honeywell along with direct links
to organizations such as TARDEC and TACOM.
The attached chart details the typical actions and timeline associated with a diversification effort.
UHY’s assistance program begins with a preliminary review of your business operations. The next step is
a Diversification Assessment completed by a combined team of experts. If a mutual decision is made
to proceed, the UHY Diversification Team works with you and your management staff to develop a
Diversification Strategic Plan.
To support your diversification initiatives, UHY has worked to establish potential sources for matching
grants of $25,000 and $75,000. Please call me at (248) 204-9447 to discuss how we can assist you and
your organization in your diversification efforts.
Very truly yours,
UHY Advisors MI, Inc.
Alan K. Lund
Consulting Principal
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
6.
7. Industry Status - Aerospace
• 2009 Projections - Aerospace Profits . . . $20.9 billion
• 2008 Purchases:
– Civil Aircraft Sales . . . . . . . . . . . . . . . . . $80.8 billion
– Military Aircraft Sales . . . . . . . . . . . . . . $54.7 billion
– US Defense Spending . . . . . . . . . . . . . . $146.0 billion
– Missile Sales . . . . . . . . . . . . . . . . . . . . . . $13.2 billion
– Space Sales . . . . . . . . . . . . . . . . . . . . . . . $33.4 billion
• Backlog . . . . . Boeing and Airbus:
– 7,000+ Airliners
$404.5 billion
– 1,300+ Next Generation Aircraft
Industry Status - Defense
• Example – Northrop Grumman:
– US Air Force . . . 179 Tanker Aircraft
– Creates 48,000 Direct and Indirect jobs
– Involves 230 US suppliers in 49 states
• Example – Oshkosh Corporation – August 27, 2009:
– Awarded a $280.9 million contract by the U.S. Army Tank-
automotive and Armaments Command Life Cycle
Management Command (TACOM LCMC) for the U.S.
Army's Family of Medium Tactical Vehicles.
A ' F il f M di T ti l V hi l
• Example – Winona, Minnesota, September 10, 2009:
– Peerless Chain awarded two U.S. Department of Defense
contracts, together worth about $10 million to supply
cargo tie-down chains for military uses
8. Diversification Strategy
• Diversification . . . “the act or practice of manufacturing a
variety of p
y products, investing in a variety of securities, selling
, g y , g
a variety of merchandise, etc., so that a failure in or an
economic slump affecting one of them will not be disastrous”
• Option “A” . . . Go Vertical:
- Target a new market or industry, i.e., Defense
- Expand existing capabilities, skills, equipment, etc
- Position as far up the chain as possible
Issues:
- Time to enter the market and crack the market
- Increased risk due to lack of understanding
- New, unique, and stringent requirements
Client Diversification Strategy
• Option “B” . . . Go Horizontal:
- Understand and expand those processes that are your
“Economic Engine” . . . .Know where and how you make
money . . .Cost Center / Product Line / Business Unit
- Develop Near-Term and Long-Term strategies to address
your strategic direction
- Identify multiple new markets or industries that fit your
strategy and complement existing skills processes,
skills, processes
capabilities, etc.
Issues:
- Resources (time and dollars) needed to understand,
upgrade and/or implement new market requirements
9. Diversification Strategy
• Build on your Core Competencies . . .Remember:
Define your company by what you do . . .
Not by what you make
• Explore the market and determine the price of entry:
– Existing Financial System . . . . .OK? YES NO
– Existing Equipment . . . . . . . . . . OK? YES NO
– Understand Specialty Metals . . .OK? YES NO
Diversification Strategy
• Remember to question Conventional Wisdom. For
example:
– Processes designed for Automotive Production (i.e, low
setup time, high OEE rating). . . How cost-effective is this
equipment for low volume aerospace applications?
– Tooling designed for this equipment was also designed for
the same Automotive production purposes . . .can the cost
of re-tooling be justified?
• Expect a Learning Curve:
- Order Management - Specifications / Requirements
- Specialty metals - Composites
- Source Inspections - ?????
10. Client Diversification Strategy
Company
ABC
Aerospace Government Alternative
Medical
Commercial & Defense Energy
Boeing Dept. Commerce
Lockheed Dept. Transportation Our Objective:
Provide the expertise
P id th ti
Northrop Defense
to help a company
Army to be prepared to
Navy Transition and Position
Air Force
What Many Companies Think The Process Will Be Like . . .
11. Quite Often What The Process Turned Out To Be Like . . .
Recent Example – Check Fixtures Client
• Roll-Out Plan
– October 2007 . . . 100% Automotive
– October ’07 thru December ’08 - Initiated a project to
identify Aerospace opportunities
– January ’08 - Materials and presentations to Boeing
– January ’08 – Boeing On-Site Visit
– February thru June ’08 – System Development
– July ’08 – Boeing Approved
– S t b –B i O d
September Boeing Orders Received
R i d
– April ’09 – AS9100 Certification
• As of July ’09 . . . . Nearly 60% of business is
Aerospace
12. Recent Example – Machining Client
• Roll-Out Plan
– 100% Automotive
– December ’08 - Initiated a project to identify Aerospace
opportunities
– January ’08 - Materials and presentations to Honeywell
– January ’08 – Honeywell On-Site Visit
– February - March ’08 – RFQ’s Received and Reviewed
– April ’08 – Honeywell On-Site Review
– M ’08 – P j t Ended by the Company
May Project E d d b th C
• WHY??? – Level of commitment and resources
required plus low volumes, approved sources,
difficulty in quoting, regulations, and . . . .
Strategic Steps – Aerospace
• Develop a Roll-Out Strategy and Action Plan:
– Establish Management Action Team –
g
– Assign Responsibilities
– Decide your market position
– Identify potential / most-likely aerospace customers
– Prepare a company overview
• Management Team
• Capabilities
• Financial Strength . . . .Altman Z Score, Current Ratio
• Growth Potential
• Quality and Customer History / Scorecards
• Equipment, Tooling, Etc.
• Establish a Time-Based Action Plan
13. Strategic Steps – Aerospace
• Review the customer’s web site:
– Identify p
y potential p
products or services that fit your
y
capabilities . . .What do they need????
– Complete on-line Supplier Registration application if
available
– Conduct web searches for more company-specific data
and information
• Initiate contacts, provide the company overview
and request a site visit
• Launch internal program to test new processes,
learn about materials, gain new skills, etc.
Federal Government – What’s Involved?
• Dedication – time and effort
– Allocate resources
– Track website information – login / passwords
– Solicit questions and understanding
– Research, review
• Sign up with your Local PTAC Office:
(Procurement Technical Assistance Center)
– Utilize PTAC s experience and knowledge
PTAC’s
– Attend FREE training seminars
– Government and State Contracting 101
– How to Become a Government Contractor
– Counseling
– www.ptacsofmichigan.org/
14. Federal Government – What’s Involved?
• Gather your business information (Registration
Checklists available)
)
– Duns number, tax ID number
– Business start date
– Annual revenue
– Financial Institution, account and routing numbers
– Contact names
• Define your product / service by code:
– NAICS (North American Industry Classification System)
– SIC (Standard Industry Classification)
– FSC/PSC (Federal Supply Code / Product Service Code)
www.drms.dla.mil/asset/fsclist.html
– NSN (National Stock Numbers)
Federal Government – What’s Involved?
• Explore government contracting websites:
– Learn about Government processes
p
– What information is required
– Types of solicitations
– Contracting opportunities
– Electronic payments
• Responsive & Responsible:
– Remember – you’re working with the government
R b ’ ki ith th t
– Complete, accurate & timely – I’s dotted, T’s crossed
– What’s your outlook on success?
– Are you financially capable?
– Similar work and performance history
15. Registrations
• CCR Central Contractor Registration Database
www.ccr.gov
www ccr gov
• TPIN Trading Partner Identification Number
• DUNS Data Universal Numbering System
www.dnb.com/duns
• CAGE Commercial and Government Entity
Identifier
• FAR 52 Representations and Certifications
(52.213-3)
Registrations
• CAGE - Commercial and Government Entity
identifier
“The Defense Logistics Information Service (DLIS)
in Battle Creek, MI is the only authorized source of
CAGE Codes. “
• Facility ID Pre-Award Survey Bidder’s Lists
• Government use in various search systems
• Assigned as part of CCR process
16. Registrations
• CAGE - Commercial and Government Entity
identifier
“The Defense Logistics Information Service (DLIS)
in Battle Creek, MI is the only authorized source of
CAGE Codes. “
• Facility ID Pre-Award Survey Bidder’s Lists
Bidder s
• Government use in various search systems
• Assigned as part of CCR process
Registrations
17. Finding Opportunities
www.FBO.gov
• FedBizOps
• The Mother of All Listing
Sites
g
• No password or registration
required for searching
• Includes Navy, Army,
Air Force, Homeland
Security, other agencies
Where’s The Money?
• Federal Spending:
– FY 2006 - $423 Billion
– FY 2007 - $457 Billion
– FY 2008 – $518 Billion
– FY 2009 – Estimated about the same as 2007/2008
• 23% Allotted to Small Businesses
• Set-Aside Goals:
– Woman Owned – 5%
– Service-Disabled Veteran-Owned – 3%
– HUBZone – Historically Underutilized Business Zone – 3%
– Small Disadvantaged Business Certification – 5%
19. 396 HUBZone Companies Registered in Michigan!
Where’s The Money?
• SBA
– ARC Loan Program . . .Effective June 15, 2009:
• SBA’s America’s Recovery Capital Loan Program can
provide up to $35,000 in short-term relief.
www.sba.gov/recovery/arcloanprogram/index.html
– 7(a) Loan Guaranty Program . . .Loans of up to $2,000,000
– Certified Development Company (CDC), a 504 Loan
Program
• Provides long-term, fixed-rate financing to small
businesses to acquire real estate or machinery or
equipment for expansion or modernization.
20. Where’s The Money?
• SBA
– Microloan Program:
• Loans of up to $35,000 to qualified start-up, newly
established, or growing small business concerns.
• Loans are arranged through nonprofit community based
lenders (intermediaries).
– Good Web Sites:
• http://usgovinfo.about.com/od/smallbusiness/a/sbaloans.htm
• http://usgovinfo.about.com/od/smallbusiness/a/sbaloanlist.htm
Where’s The Money?
• Michigan Economic Development (MEDC):
– Michigan Supplier Diversification Program launched 5/20/2009
g pp g
– Participation with a lending organization required
– Provides maximum of $500,000
– Applications now being accepted
• Michigan Economic Development (MEDC):
– Aid 400 manufacturing firms in navigating the diversification
process . . . $10 000 per compan Match req ired
$10,000 company. required.
– Assist 100 firms in achieving quality systems certification in
four new markets
– Create an online matchmaking database to connect these
Michigan manufacturers to national OEMs
– http://www.michiganadvantage.org/Diversification/
21. UHY Deliverables
• AS9100 – Aerospace & Defense Standard
• Process Mapping / Cost Analysis
• DCAA (Defense Contract Audit Agency) Audit
Understanding and Preparation.
• FAR (Federal Acquisition Regulations)
Accounting Requirements . . .FAR 12 & 15
• ITAR (International Traffic in Arms Regulations)
Understanding and Implementation
AS9100 Certification
• AS9100:
– Intended for organizations that design, develop, and/or
produce aviation, space and defense products . . and
– By organizations providing post-delivery support, including
the provision of maintenance, spare parts, or materials
– Adopted and typically required by nearly every major
aerospace prime manufacturer in the world, including
• Boeing
g
• Lockheed
• General Electric
• Airbus, Embraer
• Bombardier
• Northrop
22.
23. UHY Advisors, Inc.
Diversification Roadmap
24.
25. Commercial Military
Preliminary Business Review:
Market Market Questionnaire:
- Current Market/Industry Status
Diversification
Preliminary Review - Capabilities / Strengths / Plans
Questionnaire - Financial Capabilities
- Business Objectives
- Diversification Potential
- Project Management Meet
No End Project
- Market Diversification Strategies Criteria?
- Product Mapping / Cost Analysis
- AS9100 Implementation / Certification
- FAR 15 and FAR 12 Accounting Elements
4-Hour On-Site Assessment:
- Understanding of Risks and Opportunities
- Team - UHY / TMLytle / Dusek Network /
i.e., . . . . Enterprise Risk Management YES
Industrial Visions
. . . . Foreign Corrupt Practices Act
- Items Reviewed:
- Lean Operations and Planning
* Business Strengths / Weaknesses
- DCMA / DCAA Audit Preparation
* Management Team Commitment
- DFAR – Overview & Understanding Pre-Assessment
* Core Business Capabilities
- ITAR Awareness and Requirements
* Market Diversification Potential
* Financial Strength
* Long Term Growth Strategies
TMLytle Group:
- Output - Preliminary Report with Project
- Product Review & Readiness
Proposal . . . .schedule and fees
* TRL – Technology Readiness Level
* MRL – Manufacturing Readiness Level
- Defense Market Development Proposal
No End Project
- Defense Introduction / Teaming OK?
Dusek Network:
- Engineering Development Process 2-Day On-Site Assessment:
- Lean Engineering & Product Development - Team - UHY / TMLytle / Dusek Network /
Industrial Visions
YES
JRG Associates, Ltd.: - Items Assessed:
- Aviation OEM Representation & Teaming * Business Strengths / Weaknesses
- Aviation Overhaul & Repair * Management Team Commitment
* Core Business Capabilities
Brad Barnard – Raytheon: Assessment * Market Diversification Potential
- Marketing/Industry Links and Teaming * Financial Strength
* Long Term Growth Strategies
Industrial Visions Company: - Output - Diversification Report:
- Market and Marketing Strategy * Project Schedule and Milestones
Development * Responsibilities
* Market Potential
* Market Strategies and Planning Steps
- Boeing
- Honeywell
- TARDEC Engagement
- TACOM Launch
12/12/09
26.
27. Diversification Implementation Curve Investment
$25,000 - $35,000
Investment
$35,000 - $45,000
Investment
$8,000 - $10,000
Investment
$6,000 - $8,000
Investment
$1,500
Preliminary Business Preliminary Diversification Program Industry Teaming
Review Assessment Market Analysis Development and Implementation and Program Support
Diversification Understanding & Implementation
- ½ Day - 2 to 3 Days - 3 to 5 Days - 4 to 6 Months - 4 to 6 months
- Diversification: * Capabilities * Market Potential - Deliverables: - Deliverables:
* Questionnaire * Financials * Diversification * Development and implementation of strategies to diversify * Based on Client’s Request / Needs
* Objectives * Processes Opportunities into alternative markets/industries * Teaming Opportunities
* Capabilities * Products * Market Barriers * New Business Opportunities
* Identification and development of potential diversification * Market Updates
* Personnel
strategic partnerships / opportunities * Industry Trends
* Recommendations and actions to address diversification
barriers
Output Output Output
* Assistance and actions to implement selected new market
- Diversification - Diversification - Diversification Strategies
strategies
Review and Potential - Schedule and Milestones
Recommendations
Typical Time Frame . . . . 10 to 12 Months As Needed
12/12/09
28.
29. UHY Advisors, Inc.
ITAR Overview
30.
31.
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
32.
33. ITAR – INTERNATIONAL TRAFFIC IN ARMS REGULATIONS
EAR – EXPORT ADMINISTRATION REGULATIONS
PRELIMINARY REVIEW CHECKLIST
PRODUCTS / SERVICES YES NO NA
1. Have customers communicated ITAR compliance is applicable to the products/services
provided?
2. Has the organization otherwise discovered its products or services require ITAR or EAR
compliance?
If yes, describe:
3. Has the U.S. Munitions List been reviewed to verify designated/restricted items to identify
the applicable products requiring ITAR/EAR control?
4. Has a process been established and implemented for the receipt, identification, classification
and tracking of ITAR/EAR controlled products/services?
4a. If question 4 is yes, does the company have the necessary data to correctly classify
restricted items?
5. Does the process include labeling/tagging ITAR/EAR controlled items to maintain
identification during processing?
6. Does the organization import or export, either permanently or temporarily, classified or
unclassified defense articles?
6a. If question 6 is yes, has approval been obtained from the DDTC?
7. Is the pertinent business confined to the production of unclassified technical data only?
7a. If question 7 is yes, are records maintained for each export including a description of the
technical data, name of the recipient end-user, date and time of export and method of
transportation?
8. Are any manufacturing or export activities licensed under the Atomic Energy Act of 1954?
9. Does the organization outsource any manufacturing, assembly or testing processes to a
foreign person/organization?
9a. If question 9 is yes, are the appropriate agreements/contracts in place?
10. Are products packaged for shipping identified as an ITAR/EAR controlled product?
11. Is the organization involved or assist in re-export or re-transfer of defense articles or
services?
11a. If question 11 is yes, have licenses or agreements been obtained by the appropriate
governmental agency?
12. Does the company have any known plans to merge with or acquire another company, or
subsidiary or division of another company?
Anticipated Date:
PERSONNEL / SCREENING YES NO NA
13. Has the organization established a process for verifying the status of its employees (i.e. U.S.
Citizen or non U.S. Citizen)?
14. Does the organization employ any foreign person(s)?
15. Does the organization maintain documentation to show evidence of employee verification
and status?
15a. If question 15 is yes, have any licenses or agreements been issued by the Government
authorizing access?
Page 1
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
34. 16. Has a process been established for screening customers, suppliers, carriers and/or countries
to verify Foreign Persons?
16a. If question 16 is yes, does the screening include sources for consulting, removal of scrap
materials and visitors in the plant?
16b. If question 16 is yes, does the policy define who will be screen and how often?
Frequency:
16c. If question 16 is yes, are the screening results documented (i.e. date, performed by, lists
and records screened, etc.)?
17. Does the organization periodically screen customers against the Denied Parties and
Prohibited Countries list?
18. Has someone been designated as roles as the Compliance Officer and/or an Empowered
Official?
List Person & Title Designated:
18a. If question 18 is yes, does the Compliance Officer have direct access to the President/CEO?
18b. If question 18 is yes, is this depicted on the organizational chart?
18c. If question 18 is yes, have backups been established for these roles?
List Backups:
TECHNICAL DATA & RECORD CONTROL YES NO NA
19. Has a process been established for the receipt, identification, classification and tracking of
ITAR/EAR controlled technical data (hardcopy & electronic)?
20. Has a process been established for the control, access and security of electronic and
hardcopy data?
21. Have access and security controls of electronic and hardcopy data been implemented?
22. Does the organization import or export, either permanently or temporarily, classified or
unclassified technical data?
22a. If question 22 is yes, has approval been obtained from the DDTC?
23. Does the company have a policy for handling outside requests for information regarding
products produced or data retained by the company?
24. Has a process been established and implemented for controlling and maintaining records?
24a. If question 24 is yes, does the records control policy include records relating to political
contributions, commissions and/or fees?
25. Are records maintained in a manner capable of being reproduced on paper exhibiting a high
degree of legibility and readability?
26. Are records stored in a manner to prevent alterations from its original recording?
26a. If question 26 is no, does the system include a provision for recording changes made, who
made them and when?
27. Does the company keep all records of its communications regarding ITAR and/or export
control to help prove due diligence?
28. Does the system define record retention of 5 years from the expiration of the license or
other approval?
COMPLIANCE / TRAINING YES NO NA
29. Have duties, responsibilities and authority been identified and documented for key personnel
responsible for the daily operations and compliance oversight?
30. Has a compliance program been developed, documented and implemented?
31. Has the organization established an employee training program to ensure awareness and
understanding of the ITAR/EAR regulations and laws?
31a. If question 31 is yes, have employees received training?
32. Does the program require training to be conducted annually?
Page 2
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
35. 33. Has someone been assigned the responsibility for maintaining the compliance registration
and/or licensing?
List Person & Title Designated:
INTERNAL AUDITS / MONITORING YES NO NA
34. Has an audit program been established and implemented to ensure continued compliance to
ITAR/EAR requirements applicable to the organization?
35. Is the information resulting from audits reviewed with management on at least an annual
basis?
36. Is there evidence the organization uses the information to measure the effectiveness of day-
to-day operations for ITAR/EAR control?
37. Does the company have a policy for reporting incidents and violations?
38. Does the company have a policy for handling outside requests for information about export
compliance?
APPROVALS / LICENSING YES NO NA
39. Has the organization registered with the Directorate of Defense Trade Controls?
39a. If question 39 is yes, is the organization aware re-registration is required annually at least
30 days prior to expiration?
40. Has the organization obtained a license for exporting products/services?
40a. If question 40 is yes, is the organization aware of the expiration of the license (e.g. by
quantity, dollar amount and/or term)?
Page 3
OAKLAND COUNTY 26200 American Drive Suite 500 P.O. Box 5004 Southfield, MI 48086-5004 (248) 355-1040 Fax (248) 355-1084
MACOMB COUNTY 12900 Hall Rd., Suite 500 Sterling Heights, MI 48313-1153 (586) 254-1040 Fax (586) 254-1805
www.uhy-us.com
36.
37. For More Information . . .
Alan Lund, Consulting Principal
UHY Advisors, Inc.
26200 American Drive, Suite 500
Southfield, Michigan 48034
S thfi ld Mi hi
alund@uhy-
alund@uhy-us.com
(248) 204-9447
204-
www.uhy-us.com
www.uhy-
h