Focus
on Asset Protection
Worldwide Product Protection
By Jeffrey A. Williams, CPP
While most corporate security directors
can effectively secure product at their own manufacturing
facility or warehouse, they exercise far less control
at overseas or contract sites and as product travels
from the plant to stores. To develop an effective security
program for product both in production and in transit,
the security professional must understand the threat,
the fundamental techniques used by thieves, the inherent
weaknesses of certain manufacturing or shipping strategies,
and the tools and solutions that can mitigate the risk.
As more companies
manufacture, distribute, and sell products globally,
it has become increasingly difficult to protect inventory
at the plant and in transit. Sophisticated thieves hiding
behind international boundaries have created a staggering
level of risk that was hardly imaginable only a few
years ago.
In
today's business world, for example, manufacturing processes
are completely or partially outsourced to companies
throughout the world, many of which may not have adequate
controls in place. Likewise, manufacturers must rely
on several different shipping contractors when transporting
product across international borders, leaving these
assets vulnerable to pilferage along the transit route
and making it more difficult to determine where a crime
occurred. To combat these threats, security teams must
implement strict security measures in the plant and
on the road.
IN
THE PLANT
Every plant should, of course, have basic physical security
and access controls. But security managers also need
to focus special policies and procedures on the most
common threats to manufacturing profitability: theft,
product diversion, and counterfeiting.
Theft.
Theft of assets from manufacturing facilities is often
the result of an insider working with vendors or other
employees. For example, crooked employees at a Taiwanese
microchip producer were recently bribed to collect microprocessors
that had been rejected during testing and divert them
to outside criminals. The chips were then falsely marked
as certified and sold to unsuspecting PC vendors and
individuals. Not only did the rejected chips cut into
sales of legitimate product, but the flawed chips also
tarnished the manufacturer's reputation as consumers
discovered that their components were defective.
The
problems didn't stop there. Other employees were smuggling
functional computer chips out of the plant and selling
them to distributors, further adding to the company's
losses. Because it lacked inventory controls and conducted
no audits of the manufacturing process, the manufacturer
was unaware of the extent of the thefts of defective
and legitimate chips until management was tipped off
by an employee who had learned about the activity.
Solutions.
Inventory controls should be implemented at the company
so that product is audited throughout the production
and shipping cycle. Internal auditors should be dispatched
to production areas to inventory all products and materials
as they are either prepared to be shipped out or as
they are logged in as a delivery. Auditors should also
record the movement of product within the facility,
such as when product is moved from a holding to a storage
area.
Security
officers should be trained to recognize the difference
between good products and rejects, and they should conduct
spot checks of product and material that is being shipped
out or delivered to the facility. During these surprise
inspections, officers should randomly compare the inventory
in some crates against inventory invoices.
Garbage
bins, which are often used to hide product that will
later be stolen, should also be inspected periodically.
To ensure that officers are doing their jobs, security
supervisors should conduct periodic tests of security
procedures. For example, the security manager can set
up a test crate (addressed to a phony customer) that
has product missing to determine whether officers would
detect the loss. (The crate would be intercepted by
the security supervisor before it left the facility.)
Materials
used in the production of high-value items should not
be kept in conventional storage rooms or on the plant
floor but rather in secure storage lockers with tight
access controls. When materials are needed, production
managers should be required to sign for a specific quantity
of the material, which should then be released to them
with a security officer witnessing the process.
These
measures helped a U.S. multinational manufacturer of
computers when it realized that it was losing computer
RAM chips at one of its German assembly facilities.
Under new security procedures, chips are kept in a secure
storage locker to which only senior security personnel
have access. When additional chips are needed for assembly,
a production manager must sign for a precisely inventoried
quantity and must document that each chip is used in
production. The strict inventory controls have reduced
chip theft to nearly zero.
When
using a contract security firm, the manufacturer should
request that the security force personnel be rotated
at least once every 12 months. This breaks down any
relationships that might develop between company employees
and security officers that could lead to corruption.
When officers are either being rotated out of the facility
or leaving their jobs, a senior manager outside the
security department should conduct an "exit interview"
under which the officers should be asked about their
impressions of the security operation, including potential
weaknesses, strengths, and suggested improvements. Many
employees feel more comfortable talking about these
issues when they are leaving a company.
Even
if a company outsources the manufacturing process to
an overseas facility, it should require that plants
implement the security measures mentioned. To ensure
enforcement, the manufacturing facility should be required
either to undergo surprise audits or to allow the company
to assign one of its security managers to watch over
the plant. In the latter case, the security manager
should be rotated in and out every six to 12 months.
The
layout of the facility can play a role in reducing employee
theft. For example, the manufacturing area should not
be near the employee changing rooms, where stolen product
can be hidden. If changing rooms are located far from
the manufacturing area, employees will be forced to
carry stolen items a longer distance, thus increasing
the chances of their getting caught.
It's
also important to have separate shipping and receiving
areas as the commingling of incoming materials and outgoing
product creates confusion and opportunity for theft.
Security should limit the access privileges of contractors,
such as delivery personnel and janitors to storage and
work areas.
Technology
can be used to audit material flow. Many companies,
for example, use software to analyze reject rates and
patterns to determine whether manufacturing problems
are present. This information, used primarily for quality
control and productivity evaluation purposes, is typically
not shared with security personnel and investigators.
If the security manager can review this data, however,
he or she might be able to discover a pattern of theft.
Diversion.
One of the biggest problems for companies selling internationally
is product diversion: the intentional or accidental
redirection of product to unintended destinations where
the product is then sold without the manufacturer's
authorization. This is typically a ploy to avoid regional
import restrictions or taxes that increase the price
of legitimate merchandise. It may also be a way to buy
goods cheaply, because manufacturers sometimes discount
goods to break into a new market.
Jeans,
sunglasses, athletic apparel, and cigarettes are among
the products most commonly diverted to Europe, while
upscale designer clothing, cosmetics, fragrances, and
electronics are commonly diverted to Asia. Because these
diverted products are typically sold for less than market
price, they undermine the sale of legitimate product.
According
to FBI estimates, about 80 percent of all stolen or
diverted merchandise re-enters legitimate retail channels.
In many cases, diverted and legitimate goods are sold
side by side on store shelves, and retailers are often
unaware of the situation.
Diversion
can take many forms. One involves the diversion of production
overruns. This scheme is common in China and Thailand,
where controls are lacking. At a contract apparel manufacturer
in Hong Kong, for example, the plant superintendent
was operating an unauthorized second shift unbeknownst
to the firm that had contracted with this production
facility to assemble a specific quantity of pants per
day. After the first shift went home, another set of
workers secretly entered the plant. They produced about
10,000 extra units each month. This was all legitimate
product in the sense that the clothing had all the physical
characteristics of the real thing, but they were sold
through illicit channels. This practice eroded the company's
market share and profitability.
Another
type of diversion involves misdirection of product marked
for destruction. For example, the Taiwanese semiconductor
producer mentioned earlier was also victimized by diversion.
In this case, the company had hired an outside firm
to collect scrap chips directly within the factory and
then haul the material off to another location for destruction.
The problem was that the chips weren't actually destroyed.
They were, instead, sold.
Solutions:
The problem at the semiconductor plant might have been
prevented had the manufacturer destroyed defective chips
on site under closely monitored conditions. Even when
hiring an outside firm to destroy old product, the manufacturer
should insist that the process be conducted on-site
before the material is carted away. This is especially
important when the items slated for destruction are
still in a usable state. For example, some companies
will stop manufacturing a certain electronic component
when a new technology is developed. The old components
may contain technology that is being phased out, but
they are still in working order and could be used by
counterfeiters or product diverters to hurt the manufacturer's
market share.
When
products are slated for destruction, internal auditors
should inventory all items that are being demolished
and watch as they move through the destruction process.
A second auditor, usually a supervisor, should then
inspect the product before having it hauled away to
ensure that it has, in fact, been thoroughly destroyed.
As
with theft, the best protection against diversion is
a series of checks and audits throughout the manufacturing
and distribution process. Before contracting with a
company to either destroy product rejects or to manufacture
clothing, the security manager should conduct a thorough
due diligence investigation that covers not only the
business history of the contract firm but also its owners
and officers. The background check should include a
financial analysis of the company and its principals.
The security manager should do civil, criminal, bankruptcy,
and reference checks.
Background
checks are not always easy in foreign countries. The
security manager should start with the country's department
of trade or industry or the national securities and
exchange commission. In Asia, there are also investigative
firms that have files of companies in the region that
include detailed information about past criminal behavior.
To
prevent intentional overruns, the parent company should
assign a representative to the contract firm to monitor
and document all production runs. The security manager
should rotate this position on a regular basis to ensure
that this individual is not being bribed to turn a blind
eye. Another option is to hire an intellectual property
investigations company to run undercover operations
in the contract facility to determine whether product
is being overproduced. Investigators can drop by the
manufacturing facility at night, on weekends, and during
holidays to ensure that machines are not operating.
In
addition, the parent company can work closely with a
country's customs agency to determine whether the company's
overseas shipments are above what they are supposed
to be.
Counterfeiting.
The development of counterfeit products that are hard
to distinguish from the real thing is a growing problem
that hurts manufacturers of a wide range of products,
including clothing, handbags, jewelry, watches, sports
gear, soap, software, CDs, cosmetics, beverages, and
pharmaceuticals. In some cases, as with drugs and auto
parts, counterfeit merchandise can be dangerous. Strict
laws in North America and Europe have heavily discouraged
counterfeiters, but Central and South America, Asia,
Russia, and India maintain a robust knock-off industry.
A
common scheme involves sophisticated counterfeiters
who reverse-engineer a product to replicate the manufacturing
process so that they can create a copy that's hardly
discernible from the original. Making matters worse,
legitimate printers and container manufacturers who
are under contract from major manufacturers have been
known to deliberately produce packaging overruns, which
are sold to counterfeiters to fill with bogus product.
In
1998, for example, a company in Pakistan began purchasing
scrap plastic bottles from a major soap manufacturer.
The containers were supposed to be recycled but instead
found their way into the marketplace filled with counterfeit
soap. Similar frauds have involved authentic candy containers,
software boxes, and other packaging.
Solutions.
Security has several options. First, due diligence must
be conducted on firms hired to make product containers
and packages. Before scrap packaging is hauled away
for recycling, each package should be inventoried and
damaged to prevent reuse. In the case of the soap manufacturer,
the bottles should have been crushed and punctured.
Hard-to-duplicate
holograms can be placed on packaging to help deter counterfeiting.
Holograms come in many forms, but they are primarily
stickers that attach to a product. Retailers are then
asked to check all product for holograms before putting
it on the shelf.
It
is difficult for a counterfeiter to duplicate holograms
because of the high degree of proprietary information
used in their manufacture. However, holograms can be
stolen by employees and sold to pirates for use on counterfeit
products. Therefore, the manufacturer should specify
that only a certain number of holograms be made; they
should then be inventoried and stored in a secure location.
Another
technique used by some manufacturers is to imbed a small
marker on the inside or underside of the product. In
some cases, the marks are visible only under UV light
or with a laser. These methods work well, but manufacturers
should change the location and design of the marks occasionally
to keep counterfeiters off-balance.
ON
THE ROAD
One
of the most difficult security challenges is safeguarding
components and products during transit between facilities
or countries at various points in the manufacturing,
assembly, and distribution process. The opportunity
for theft is exacerbated by the decentralized structure
of most companies' security programs. Typically, there's
a different security manager in charge of each facility,
country, or region. Although each pays close attention
to concerns within his or her area of responsibility,
there is often limited collaboration between regions.
For instance, a security manager in Europe is unlikely
to fly to Asia or Latin America to help his counterpart
investigate a reported loss that resulted from weaknesses
in the supply chain somewhere between the two continents.
Thieves recognize and exploit these communication breakdowns.
If
cooperation is lacking even among security professionals,
how likely is it that non-security managers will make
security a priority? There is, for example, little incentive
for a logistics manager to implement tighter controls.
Logistics and transportation managers are often evaluated
(and compensated) on the basis of how quickly and efficiently
they can move product between manufacturers, distributors,
and retailers. Even if goods are discovered missing
from the supply chain, the person responsible for overseeing
passage will generally not be reprimanded or questioned,
as long as the company's rudimentary security procedures
were followed.
In
addition, companies sometimes focus on the cost of a
contract without regard to the potential risks of an
arrangement. This attitude can cost a company dearly.
A manufacturer of disk drives in Malaysia, for example,
encouraged the freight forwarder to find the cheapest
route possible for transporting goods to California.
To reduce transport costs, the firm sent hard drives
destined for Los Angeles through Australia. As the shipment
passed through the hands of several companies, including
an airline, two pallets containing product worth $400,000
vanished. Because so many freight handlers were involved
and paperwork was inconsistent along the supply chain,
there was no way to know where the cargo was stolen.
To make matters worse, law enforcement agencies in Malaysia,
Australia, and the United States refused to investigate
because it wasn't clear which agency could assume jurisdiction.
Solutions.
As with any business relationship, companies should
check the credentials of shippers. It's also essential
to verify that those companies conduct criminal records
and reference checks on their employees.
When
conducting background checks on transportation companies,
the investigator should determine whether each transport
company is properly insured against documented losses.
This coverage allows the manufacturer to collect damages
from the insurance company should any product be stolen
or lost in transit. The transportation company should
also be asked to disclose the level of deductibles and
to demonstrate how the company would cover those costs.
In
addition, their audit and control procedures should
be examined to make sure that the distribution centers,
where product is usually stored for a brief time, are
properly secured. Inventory procedures should be checked
to ensure that the transport company documents all product
as it arrives and leaves the facility. Security should
also ensure that these centers have strong access control,
surveillance systems, and patrol officers.
High-security
cages should be used for high-value product, such as
computers. Audible alarms should be in place to alert
on-site security officers of a break-in.
Even
after hiring a transport company, it's advisable to
check distribution centers periodically. For example,
some manufacturers hire contract investigators to conduct
quarterly security surveys of distribution centers throughout
a transport company's nationwide network to ensure that
security measures and inventory controls are implemented
consistently.
The
manufacturing company's security manager should review
other security measures used by the transportation company.
For example, the manufacturing company should ensure
that the transportation contractor uses bar code scanners
to keep track of product as it moves. This technology
allows the company to check on the status of a shipment
as it goes from point A to point B and to verify that
all boxes contained in a shipment are present and accounted
for when they arrive at their final destination. Under
these systems, crates are labeled with a bar code and
scanned when they leave the manufacturing facility.
They are then scanned at every stop along the way, including
arrival and departure from all distribution centers
and at the final destination. The system records the
time, day, and location of a product when it is checked
in and logged out.
Security
should check to see whether the transport company uses
tamper-resistant seals and locks on cargo trucks. While
seals can deter cargo theft, they are largely useless
in an investigation unless careful records have been
kept that enable the investigator to pinpoint where
or when a breach occurred. Security should, therefore,
also examine the shipper's procedures.
The
transport company should have a supervisor install the
seal after the truck has been loaded, and the seal's
security number should be recorded in a log book. The
security number should then be sent to a supervisor
at the final destination either by e-mail, fax, or telephone.
When the shipment arrives, the supervisor at the final
destination should check and record the security number
on the seal, which will not have changed as long as
the truck has not been opened while in transit.
For
high-value items, security should use a transport company
that provides electronic tracking of all trucks in transit.
Using a Global Positioning System (GPS) transmitter
or similar technology, security personnel can track
a truck, a shipping container, or individual package
along its entire journey. Software at the transport
company's central monitoring station can alert security
personnel when product or vehicles are being diverted
from their intended course.
If
the transportation company does not provide this service,
the security manager can request it as a condition of
doing business. In addition, the manufacturing company
can purchase a tracking device for its own product (at
a cost of between $500 and $1,500) and attach it directly
to its shipment. It would then have to contract with
a third party monitoring facility to track the product
in transit, usually at a cost of approximately $30 a
month. In the latter case, the transportation company
should be told that the manufacturer's product will
be tracked.
Manufacturers
should also consider setting up a telephone hot line
(usually a toll free number) that can be used in the
event that a shipment is delayed in transit. For example,
a truck driver could call the hot line to report that
his or her vehicle has broken down. The shipper can
then dispatch security officers to the area to guard
the product until the truck is repaired. In addition,
some retail establishments will only accept shipments
by appointment. If the truck driver arrives too late,
the retailer will not accept the shipment until a new
appointment is made. In the past, the trucking company
dispatcher would be notified and a new appointment would
be set, usually for the following day. The truck driver
would then take the shipment to a rest stop for the
night, where it would be vulnerable to theft. With a
hot line, the delay can be reported directly to the
manufacturer, who can arrange to have security at the
rest stop with the shipment.
Manufacturers
should also look at new technology for sealing cartons,
such as tamper-resistant tape. Regular packaging tape
can be removed or cut by thieves and then replaced,
leaving little evidence that a carton has been tampered
with. Tamper-resistant tape, which is only marginally
more expensive than regular packaging tape, will change
colors or display wording like "Opened" when
it has been cut by thieves. (This is done through chemicals
contained in the tape that react to any break in the
tape.) With this product, truck drivers, security officers,
and other workers at distribution centers can be tipped
off quickly that a crime has occurred, giving investigators
a better chance of finding evidence to solve the crime.
Manufacturers
also need to implement internal tracking controls and
procedures. Sensitive documents must be secured, and
only personnel who are responsible for logging out shipments
and logging in deliveries should have access to invoices,
manifests, bills of lading, and delivery receipts. When
invoices and other documents are traveling with a shipment,
they should be secured in a tamper-resistant pouch or
envelope that is only opened when the shipment arrives
at its final destination. This procedure helps prevent
truck drivers and other employees from modifying forms
to hide a theft; it also prevents drivers and employees
from determining the commodity type and value contained
in the shipment.
The
manufacturer should restrict access to blank invoices
and documents, which could be stolen and forged to hide
a crime. Likewise, it's important to use secure log-on
procedures and firewall protection to prevent unauthorized
access to computerized inventory and shipping records.
When
thefts do occur, a thorough investigation should be
conducted. Whirlpool, for example, discovered last year
that its washing machines, refrigerators, and components
were disappearing when being transported by truck from
plants in Mexico to U.S. retailers. An investigator
followed a random shipment in his car, and found that
one of the trucks containing appliances pulled off the
road near Laredo, Texas, apparently a well-used drop
point. Thieves carefully removed the hinges from the
trailer doors so as not to disturb the door seals, offloaded
appliances, and then replaced the doors to hide the
crime.
After
interviewing the driver, investigators confirmed that
he had been bribed to repeatedly assist the thieves
by pulling off the road and permitting access to his
truck. When given this information, the police were
able to track the thieves and break up a well-organized
operation that was believed to have been responsible
for more than $1.5 million in missing merchandise.
One
way to deter this type of crime is for security to implement
periodic random investigations of trucks in transit.
Under this system, an investigator follows a truck as
its leaves the manufacturing area, ensuring that it
follows the predesignated route. The investigator also
notes whether the driver follows proper security procedures
during transit, such as locking down the truck when
stopping at rest areas.
Another
strategy gaining favor among consumer-products giants
such as Panasonic is to ship products in plain cartons
not labeled with the manufacturer's brand name. (Inner
boxes containing product bound for store shelves retain
logos and descriptions of contents.) Intel and Dell
were able to reduce their shipping losses by as much
as 80 percent by "plain wrapping" shipments
and shrink-wrapping entire pallets of product.
Companies
work hard to develop valuable products and to build
brand-name recognition that will increase customer loyalty
and profits. Managers must work equally hard to keep
those assets from being stolen or counterfeited, lest
the company's good name be tarnished and profits lose
their luster.
Note.
Jeffrey A. Williams, CPP, was the vice president of
Pinkerton Asia Ltd. from 1992 until he retired in 2001.
Jeffrey now enjoys a life as an independent consultant
(in the Philippines,) with more than 15 years experience
working investigative and security consulting matters,
Philippines-wide. Prior to joining Pinkerton, Williams
had a 23-year career with the U.S. Department of Defense
as a special agent with the U.S. Air Force Office of
Special Investigations. His last assignment was as the
counterintelligence and security officer to the deputy
commander in chief, U.S. Transportation Command. He
runs his own investigative firm in the Philippines,
Orion Support Incorporated (OSI), with website: www.osi-philippines.com,
and can be contacted at jwilliams@osi.com.ph.
|