Approved economic operator: definition of sensitive positions

The Certified Economic Operator Certification is divided into two components:OAS C (Customs Simplifications) and OAS S (Security and Security).

For the safety and security part, the operator mustdefine sensitive positionsof its organization:

• senior positions in the field of security, customs, recruitment and logistics;

• posts for the control of buildings and reception;

• the workstations concerned by incoming and outgoing goods and their storage.

The company must identify in its organizational chart the relevant posts to be applied to security investigations (prescribed by the Union Customs Code).

Sensitive positions are compulsory « Employees » Company; temporary staff and staff made available by external providers are therefore excluded. The latest evidence confirmed by Customs to ensure compliance with this criterion is as follows:

The conditions to be met at the time of application for certification may be:

• Incorporation of a provision for the provision of Bulletin No. 3 of the criminal record or of a declaration of honour of absence of conviction in Bulletin No. 3 of the criminal record when hiring in employment contracts intended to support future employment in a sensitive position;OR

• Modification of the hiring procedure for hiring up to the provision of a criminal record bulletin No. 3 or a declaration of honour of absence of conviction in Bulletin No. 3 of the criminal record;OR

• The conduct of an administrative survey of future employees in sensitive positions by virtue of their activity (R 114-2) or the places in which they work (R 114-4).

Monitoring conditions for people working on sensitive postsmay be:

• the delivery to the employer of Bulletin No 3 by employees in sensitive positions on the day of the audit; OR

• the voluntary signature of an amendment to the contract of employment, the purpose of which is to add a clause requiring the employee to report any criminal or criminal conviction to his employer that occurs during the period of performance of the contract of employment;OR

• the establishment of a procedure for the periodic verification of the history of staff in active employment in a sensitive position characterised by the regular renewal (from 1 to 3 years) of a criminal record bulletin No. 3;OR

• the certificate of honour of the absence of a conviction in Bulletin No. 3 of the criminal record, issued annually by the employee. If this option is chosen, the attestation must be sent by the employee to his employer or to the competent service designated by the employer;OR

• an administrative inquiry into employees in sensitive positions by virtue of their profession (R 114-2 of the Internal Security Code) or the places in which they work (R 114-4 of the same code).OR

To go further...

• Sales Administration (SDA) Subcontracting Export
• Import/export flow management (air & maritime)
• Diagnosis of international logistics flows

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