CUSA_Blank_1920_545

Crane Post Audit Policy

PURPOSE

To provide customer guidelines for post-audit deductions.

POST-AUDIT DEDUCTION DEFINITION

A deduction taken by a customer after a review by the customer’s internal audit department or a third-party auditing
firm.

COMMUNICATION POLICIES

  • All documentation requirements submitted to Crane USA will be subject to Crane USA audit team review in its
    reasonable satisfaction.
  • Crane will communicate with the post-auditor or customer on any issue as we deem appropriate to resolve a claim.
    Our communications will not be limited to the post-auditor.
  • A specific point of contact must be provided if we need to communicate with the post-auditor.

POST-AUDIT REVIEW SUBMISSIONS

  • All post audit claims shall be submitted through Crane’s audit review portal.
  • A service fee to help cover the cost of the accounting investigation will apply.
  • Failure to submit the claim through the Crane’s audit review portal will result in the claim being recorded as
    denied for lack of sufficient proof and deemed invalid. Crane USA Inc. shall have no obligation to respond
    thereto.

POST-AUDIT DEDUCTION TIMELINE REQUIREMENTS

  • Crane USA will honor post-audit deductions that are taken within the following specifications:
  • All documentation requirements submitted to Crane USA will be subject to Crane USA audit team review in
    its reasonable satisfaction.
  • The customer provides Crane USA with written notice and actual back-up documentation at least 90 days
    prior to taking the post-audit deduction, to allow ample time for research and validation. Examples will
    not be accepted.
  • Claims are submitted in writing within 1 year of the initial invoice or performance period and during
    Crane USA current fiscal year (4/1/XXX – 3/31/XXXX). Claims outside this period are considered invalid
    and require repayment by the customer. (Crane USA follows the GMA/FMI guidelines.)

PROMOTION-RELATED POST-AUDIT DEDUCTIONS

The customer documentation required for a promotion-related post-audit deduction includes, but is not limited
to, the following:

  • A customer contract or deal sheet signed by an authorized Crane USA representative. Deal sheet examples
    or those relating to other regions or dates will not be accepted.
  • Proof of performance (ad, billback, scan, display, temporary price reduction [TPR] tag, distributor
    invoice, etc).
  • Post-audit “back-up” documentation detailing the specific reason(s) for the deduction.

NON-PROMOTIONAL PRICING-RELATED POST-AUDIT DEDUCTIONS

The customer documentation required for a non-promotional pricing-related post-audit deduction (ie, pickup
allowance) includes, but is not limited to, the following:

  • Post audit “back-up” documentation or customer invoice detailing the specific reason(s) for each
    individual deduction.
  • Supporting pricing documentation.

DEFECTIVE ITEMS-RELATED POST-AUDIT DEDUCTIONS

Crane’s electronic products are regulated by the EPA Electronic Recycling and Reuse Act and considered hazardous
material. Disposal of such electronic products must be safely processed through official Recycle (salvage) or
Reuse (donation) reclamation providers. The customer documentation required for defective or consumer
return-related post-audit deduction includes, but is not limited to, the following:

  • Product information with Crane’s article number or customers SKU number.
  • Exact date of defective or consumer return by store and individual item. Bulk deductions are not
    acceptable.
  • Proof of disposal (Bill of Lading or Merchandise Receipt) by individual item from the recycle or reuse
    provider.

PRICE DIFFERENCE POST-AUDIT DEDUCTIONS

Crane’s applies best efforts and due diligence to verify all purchase orders for its correctness before
acceptance and fulfillment.

  • Purchase order price difference will only be credited from the date of notification by the customer on
    unpaid invoices.
  • Price differences on previously paid invoices will not be credited back.

SHORTAGE AND SHIPPING POST-AUDIT DEDUCTIONS

The documentation that must be provided by customers for post-audit shortage and shipping-related claims such as
inventory, quality issues or shipping allowances includes, but is not limited to, the following:

  • A signed proof of delivery showing the seal number and indication of the condition of the seal (intact
    at the time of delivery).
  • Written itemization of product Stock Keeping Units (SKUs), including quantity shipped over, short, or
    damaged on both:
  • The “back up” documentation supporting the deduction.
  • The proof of delivery or bill of lading (BOL) documentation.
  • All discrepancies must be clearly noted on the BOL at the time of delivery, while the driver is still
    present.

IMPORTANT:International Chamber of Commerce (ICC) regulations require that shipping claims
should be submitted to Crane USA within six months of the original order shipment date, to allow adequate time
for Crane USA to investigate and file a claim against a carrier if necessary. If deductions resulting in carrier
claims are taken more than six months after the order shipment date, they have passed the statute of limitations
and will be considered invalid by Crane USA.

COMPLIANCE CONFIDENTIALITY POLICY

Marketing and promotional plans, pricing, trade agreements and operational policies are confidential trade
secrets and shall not be shared with any other customer or third party. Crane will pursue any violations.

Post-audit deductions will not be accepted if the deduction is taken without allowing Crane USA at least 90 days
advance notice for preliminary investigation, and without proper documentation. Deductions without proper proof
or documentation are not in compliance with the Sarbanes–Oxley Act of 2002 (SOX), the company is not permitted
to accept undocumented charges.

“Back-up” is defined as a customer deal sheet signed by an authorized Crane USA representative and proof of
performance such as ad copy, billback/scanback data, etc. Examples will not be accepted.Historic claim
resolutions are not valid proof or reason for taking deductions without Crane’s approval.

Crane USA reserves the right to contact customers or the customer’s third-party auditing firm directly to
clarify the reasons for post-audit deductions. Resolution agreement will not be limited to discussing any
deduction with third party auditors.

Crane USA will pursue repayment of post-audit deductions under the following circumstances:
The customer is unable to provide appropriate supporting documentation.
The post-audit deduction is taken for claims that have not been submitted in writing within 1 year and Crane USA
current fiscal year (4/1/XXXX – 3/31/XXX) of the initial invoice or performance period.
If a deduction is deemed invalid after thorough research by the Crane USA Audit team, customers will be informed
in writing that repayment of the deduction is due within 30 days of the date of the chargeback letter.

Crane USA considers certain post-audit deductions invalid. These include, but are not limited to, the following:

  • Anticipation (deductions related to compensation for invoices paid prior to due date).
  • Promotional deals on dates other than previously agreed upon promotional periods.
  • Customer re-slotting warehouse fees
  • A duplicate deduction. Example: Crane USA gave off invoice allowance, and customer is deducting too.
  • Nuisance fees (such as documentation processing fees, late trucks or detention charges not related to a
    CPU, bad pallet charges, etc.).
  • Coupon-redemption charges (such as shipping, handling, foreign coupons, value shortage, expired coupons,
    variances in coupon count, process fees that exceed the clearing house authorized rate, etc.).
  • Shipping claims involving transportation documentation that is more than nine months old. (These must be
    filed within six months of order shipment.)

Note:Failure to follow Crane USA post-audit deduction policy may result in penalties including, but not limited
to:
Interrupted customer shipments, pending resolution.
Decrease in current promotional funding.
Decrease in future promotional funding.
Price increase.
Failure to comply with the policy could result in termination of the relationship.