Compliance & Operations Manual

Client Onboarding & Due Diligence

1. Capture legal name, registration number, TIN, physical address, digital address, and named contact with phone and email.
2. For companies, obtain the certificate of incorporation and confirm the contact's authority to commit the customer.
3. Screen the customer and its principals against OFAC and other applicable sanctions lists. Record the date and result.
4. Establish the nature of the business and the commercial rationale for the goods. An order that does not make commercial sense is a flag.
5. For payments over the AML reporting threshold, or where the source of funds is unclear, obtain an explanation and record it.
6. Issue the Company's standard terms and obtain written acceptance before quoting.
7. Create the customer record in the portal and file all documents under SOP-16.

Quotation & Landed Cost

1. Confirm the specification. For technical goods, verify ratings, compatibility and suitability before pricing. Where the customer's stated specification is wrong, say so in writing.
2. Obtain a current supplier price. Do not quote from a previous order's cost.
3. Determine the HS classification. Where uncertain, confirm with the clearing agent before quoting.
4. Obtain a current freight quotation for the actual weight and dimensions. Never estimate freight from memory.
5. Build the landed cost in the Company model: goods, freight, insurance, duty, levies, VAT, clearance, inland delivery, contingency.
6. Apply the target margin. Confirm the resulting price against market before issuing.
7. Issue the quotation showing the cost stack itemised, the duty rate applied, validity period and payment terms.
8. For used goods or benchmark-valued items, state the duty component as a range and disclose that final assessment rests with GRA.

Order Acceptance & Deposit

1. Obtain written acceptance of the quotation referencing the quotation number.
2. Issue the deposit invoice.
3. Confirm the deposit has cleared the Company's bank account. A payment advice, screenshot or transfer confirmation is not clearance.
4. Only once funds are cleared, move the order to committed status and release SOP-04.
5. Record the agreed delivery window, measured from clearance date.

Supplier Purchase

1. Purchase only from suppliers whose terms permit purchase for export.
2. Ship to the Company's designated consolidation address in a no-sales-tax state.
3. Verify on receipt: correct model and specification, quantity, physical condition, and that serial numbers are recorded.
4. Retain the invoice, packing slip and proof of payment. The commercial invoice presented to customs must reconcile to what was actually paid.
5. Photograph goods on receipt and before packing. This is the Company's evidence in any damage or shortage claim.
6. For technical goods, confirm certification marks and documentation are present before export.

Freight Booking & Consolidation

1. Obtain quotations from at least two forwarders or carriers. Never single-source freight.
2. Select mode against the customer's committed delivery window, not against the cheapest rate alone.
3. Consolidate where possible. Freight exceeding 20% of landed cost indicates a consignment too small to be efficient.
4. Arrange cargo insurance for the full CIF value. Uninsured shipments are not permitted.
5. Screen for restricted goods — particularly lithium batteries. Where present, ensure a compliant Dangerous Goods declaration is prepared.
6. Confirm the consignee is Nav-Davict Systems & Trading Ltd with the correct TIN and digital address on all transport documents.
7. Verify the Bill of Lading or Air Waybill on issue. Errors corrected before sailing cost nothing; after arrival they cost weeks.

United States Export Filing

1. Determine the Schedule B classification for each commodity.
2. Where the value of a single Schedule B commodity exceeds USD 2,500, file Electronic Export Information through AESDirect and obtain the Internal Transaction Number.
3. Screen the consignee and all parties against the Consolidated Screening List.
4. Consider EAR classification. Most commercial goods are EAR99, but encryption, thermal imaging and certain instruments require assessment.
5. Provide the ITN to the carrier or forwarder before departure.
6. Retain export records for five years.

Ghana Customs Clearance

1. Confirm the Company's Tax Clearance Certificate is current before arrival.
2. Submit the Import Declaration Form and upload supporting documents to ICUMS: commercial invoice, packing list, Bill of Lading or Air Waybill, certificate of origin, insurance certificate, and any regulatory permits.
3. Confirm the carrier has lodged the manifest.
4. Verify the declaration is filed under the Company's own ICUMS account. Obtain and read the declaration before duty is paid.
5. Review the GRA assessment. Where valuation or classification appears incorrect, query it formally before payment. Do not pay first and argue later.
6. Pay duties and charges through an authorised dealer bank. Obtain the official GRA receipt.
7. Attend or arrange representation for physical examination where required.
8. Obtain the GPHA waybill and pay terminal charges. Track the free-storage period and act before demurrage accrues.
9. Reconcile the agent's invoice line by line against official receipts. Query any unsupported item in writing.

Delivery & Order Closeout

1. Confirm the balance is received and cleared before release, unless credit terms were agreed in writing.
2. Inspect goods before dispatch to the customer. Photograph condition.
3. Deliver against a signed delivery note recording date, condition and receiving person.
4. Hand over warranty documentation, certificates and, for technical goods, commissioning records.
5. Close the order in the portal and file all documents.
6. Complete the post-shipment debrief: actual versus quoted landed cost, actual versus quoted transit time, and any friction encountered. Update the cost model with the real figures.

Vehicle Sourcing & Shipping

1. Confirm the current age-restriction position with GRA before every transaction. Enforcement of the over-age provision has varied. Record the date and source of the confirmation.
2. Verify title status before bidding. Obtain the title document or auction title designation in writing.
3. Run a vehicle history check. Record the VIN and retain the report.
4. Bid only through a licensed broker where the auction requires a dealer licence. Retain the broker agreement.
5. Provide the customer with a written estimate showing a duty range, and disclose in writing that Ghana Customs assesses on its own benchmark valuation, not the auction price.
6. Obtain full funding from the customer — purchase price, all fees, freight and estimated duty — before bidding. The Company bids as agent, never as principal.
7. Arrange collection, US transport to port, and RoRo or container booking.
8. File EEI per SOP-06. Vehicle exports have specific US documentation requirements including title presentation to CBP.
9. Clear per SOP-07. Budget for demurrage — vehicle clearance commonly takes longer than general cargo.
10. Deliver against signed acceptance. Provide all title and clearance documents for registration.

Electronics, Computers & Mobile Phones

1. Classify correctly. Computers and tablets fall in the capital-goods band; phones and monitors fall in the consumer band at a materially higher rate. Classification drives the quotation.
2. For mobile phones and wireless devices, determine whether the consignment is personal or commercial. Commercial consignments engage NCA type approval under Act 769.
3. Where type approval is required, obtain it before shipping — not after arrival.
4. Check the current status of IMEI registration requirements before any commercial handset consignment.
5. Verify whether the eco-levy under Act 917 is currently being collected and include it in the quotation where it applies.
6. Confirm whether GSA conformity assessment applies to the specific items.
7. Record serial numbers and IMEIs for every device. This is both a warranty record and a theft-dispute defence.
8. Source only from channels whose terms permit purchase for export. For volume, use trade and wholesale channels.
9. Screen for embedded lithium batteries and apply SOP-05 dangerous goods requirements.

Solar & Storage Projects

1. Establish the load before discussing equipment. Measure where possible; reconstruct from tariff records where not. Separate critical from deferrable load and characterise motor starting.
2. Agree the objective in writing — off-grid, outage ride-through, diesel displacement, or tariff optimisation. This determines architecture.
3. Size the array against irradiance and a justified derate factor. Size the inverter against peak and surge, not average. Size the battery against agreed autonomy and usable depth of discharge.
4. Verify string voltage against inverter MPPT window at record low and high ambient temperature.
5. Design protection: DC and AC isolation, overcurrent coordination, surge protection, earthing and bonding. Apply IEC 62305 lightning risk assessment.
6. Produce a single-line diagram, cable schedule and bill of materials. Issue the design to the client for approval before procurement.
7. Confirm Energy Commission licensing requirements for the installation scope and the installer.
8. For grid-tied or hybrid systems, confirm ECG or NEDCo connection requirements and any net-metering process before committing to an architecture.
9. Procure per SOP-04. Verify IEC certification of modules, inverters and batteries. Obtain UN 38.3 documentation for lithium.
10. Commission to IEC 62446: string I-V measurement, insulation resistance, polarity, inverter parameter verification, battery capacity and BMS configuration.
11. Issue the handover pack with as-built drawings, commissioning results, a performance baseline, warranty documents and an O&M schedule.

Personal Effects & Household Shipping

1. Obtain an itemised packing list with honest values. Explain to the customer that Ghana Customs may assess on benchmark values.
2. Explain the duty position before collection, not on arrival. Provide a written estimate.
3. Screen for prohibited and restricted items, including loose lithium batteries, aerosols and pharmaceuticals.
4. Photograph contents at packing. Seal and number each carton or barrel.
5. Where the customer is unaware that duty will exceed the value of the goods, advise them not to ship. A refused order is cheaper than a dispute and buys a reputation.
6. Provide the recipient's full name, Ghana Post digital address and mobile number on all documentation.
7. Clear per SOP-07 and deliver against signature.

Clearing Agent Appointment & Management

Knockout criteria — failure on any one disqualifies

1. Holds a valid GRA customs house agent licence. Verify the licence number independently.
2. Agrees in writing to file under the Company's ICUMS account, not their own.
3. Agrees to provide the ICUMS declaration and official GRA receipt for every consignment.
4. Accepts the Company's anti-bribery policy in writing and never proposes under-declaration.

Appointment

1. Score candidates against the Company scorecard. Obtain references from current importers.
2. Agree a flat fee per declaration. Percentage-of-value fees misalign incentives and are not accepted.
3. Trial the top two candidates on small consignments before concentrating volume.
4. Retain a second appointed agent at all times.

Ongoing

1. Reconcile every invoice to official receipts. Query unsupported items in writing.
2. Track clearance days, cost variance and document completeness per consignment.
3. Review quarterly against the alternate agent.

Financial Controls & Working Capital

1. Deposits are cleared before commitment. See SOP-03.
2. Payments above USD 5,000 require both directors' recorded confirmation.
3. Bank statements are reviewed monthly by both directors.
4. Foreign exchange exposure is recognised: duties are assessed and paid in Cedi while revenue may be contracted in Dollars. Quotation validity is limited to 14 days for this reason.
5. Capital available must cover peak exposure across all concurrent deals plus a 25% reserve. Where it does not, fewer concurrent deals are run.
6. The Company does not borrow to bridge a first order with a new customer.
7. Credit is not extended without a documented assessment and director approval.
8. Cash payments are avoided. All disbursements are traceable and receipted.

Complaints, Claims & Disputes

1. Acknowledge in writing within one working day. Record in the complaints register.
2. Establish the facts from the file — photographs, delivery note, declaration, correspondence — before responding on substance.
3. Where the Company is at fault, say so plainly and propose a remedy. Partial admissions and delay damage more than the original error.
4. Where a cargo insurance claim applies, notify the insurer within the policy notification period. Late notice voids cover.
5. Where the dispute concerns customs valuation, provide the ICUMS declaration and GRA receipt. Transparency ends most of these disputes immediately.
6. Escalate unresolved matters to the Managing Director within five working days.
7. Record root cause and any process change in the debrief under SOP-08.

Records, Retention & Data Protection

Retained per transaction

• Quotation, customer acceptance and issued terms
• Supplier invoice and proof of payment
• Commercial invoice, packing list, certificate of origin
• Bill of Lading or Air Waybill, insurance certificate
• US export filing record and ITN
• ICUMS declaration and official GRA duty receipt
• Agent invoice and reconciliation
• Signed delivery note, serial and IMEI records
• Photographs at receipt, packing and delivery
• Post-shipment debrief

Retention & protection

1. Commercial and customs records: retain a minimum of six years.
2. US export records: retain five years per the Foreign Trade Regulations.
3. Statutory corporate records: retain permanently.
4. Personal data is processed lawfully under the Data Protection Act, 2012 (Act 843). Register as a data controller where required.
5. Records are held in the Company system with access limited to directors. Backups are maintained separately.
6. Maintain an incident register covering bribery solicitations, seizures, sanctions matches and near misses — including incidents where nothing was paid and no loss occurred.