The story of multinational lighting manufacturer OSRAM and compliance software leader AEB is a study in two companies coming together to optimize OSRAM's worldwide export control and trade compliance processes.
Since its founding in 1918, OSRAM has grown from regional
leader in the technologies of its day to a global high-tech player with 27 production
plants worldwide that sell products in 120 countries. From its stalwart incandescent
lamp to high-tech photonics products, OSRAM, like few other companies, has learned
to adapt to the changing markets around it in its more than 100-year history.
The high-tech group's portfolio now covers the entire
technological spectrum of visible and invisible light. This includes lighting
management systems, intelligent-networked lighting solutions and infrared and
laser light for sensors that serve as the basis for autonomous driving platforms
in cars or facial recognition systems in smartphones.
The perfect match
Considering its worldwide presence, the teaming of OSRAM, headquartered in Munich, Germany, and international compliance software provider AEB, based in Stuttgart, was a natural fit.
"Due to our global orientation, secure, efficient foreign trade processes and trade compliance are of great importance to OSRAM,’’ said Stefan Klingshirn, Export Control and Customs (ECC) specialist at OSRAM. ‘’For us, it is extremely important that on the one hand all legal requirements are complied with and on the other hand the operative business and its supply chain are not disturbed.’’
AEB and OSRAM worked together to create a new IT-based platform for its export control and trade compliance processes. This included a newly developed solution that gives the company convenient support during critical end-use testing.
Klingshirn is joined in ECC by Andrea Dites, Head of
Export Control Governance. The ECC unit and its employees are responsible for
the company’s customs and export control organization and ensuring that OSRAM implements
its compliance program and that it aligns with international export
OSRAM’s ECC team faced a major challenge in 2017. "The
provider of our former export control software had announced a version change
at the end of 2018," said Dites. "This would cause high costs and
administrative efforts that were comparable to the introduction of a new
At the same time, Dites said, the company realized that
the new release would not result in any improvements in maintenance costs or in
the quality of response and service in support.
In addition, the application was not integrated into the SAP® system, another
factor that made OSRAM want to look for a new compliance software solution.
"All in all,
there was great potential to make data exchange and our processes leaner and
more transparent through improved integration into our ERP systems and thus to
sustainably reduce the effort with new software," says Klingshirn.
"It was clear to us very quickly that we were now on the lookout for a new
High requirements, tight schedule
In the spring of 2017, OSRAM started selecting suppliers that could meet its very high requirements. The company was looking for a solution that would support sanctions list checks, export controls and the administration of export licenses. And not only for OSRAM’s European sites, but also internationally in more than 50 OSRAM companies worldwide.
"This meant that the software also had to support trade compliance checks for areas of law such as the USA, China, Mexico, Canada and Malaysia," says Dites, adding that a long list of criteria played a role in the ultimate selection.
"24/7 availability, technical and specialist support for our users and compatibility with the future SAP S/4HANA® system were also important for us," adds Klingshirn. "Due to an ambitious time schedule, we were also looking for a solution with low implementation effort that was easy to use and understand in order to keep the training effort as low as possible. After a conception phase at the end of 2017, the solution had to be implemented in the first half of 2018 and, after an integration and test phase, had to go live on October 1, 2018. ‘’
"What convinced us at AEB above all was that the
software could be deeply and seamlessly integrated into the five SAP® ERP
systems of our different regions and business units," explains Miroslaw
Kalinay, an IT project manager involved in the decision.
In addition, AEB was able to meet international
requirements and offer extensive options for sanctions list screening. In
addition, AEB software also covered the issue of sanctioned ownership, i.e.
checking whether an indirect provision ban exists. And the solutions from the
Stuttgart-based software company support OSRAM's IT strategy of moving away
from its own server landscape to applications from the cloud.
Sanction list review, export control and license management in use at OSRAM
Sanction list check: AEB software compares the addresses involved with the relevant prohibition lists within Finance (FI), Human Resources (HR), Materials Management (MM) and Sales (SD) in the respective OSRAM SAP® system. Only in the event of a hit do the employees notice the check activities. If one of the addresses can be found on one of the prohibition lists, the solution starts a predefined process, blocks the affected process, and sends an e-mail to the person responsible.
A special feature at OSRAM is that the company also checks indirect provision bans. These prohibit money or economic resources from flowing not to a company on a sanctions list itself, but to another company "controlled" by the listed company. In addition, the scope of the audit is enormous: OSRAM matches up to 1 million prohibition addresses due to its international presence.
Export control: With the Export Controls software, OSRAM checks the countries and goods involved in business transactions for existing bans and approval requirements. In addition to the legal areas DE/EU and US-EAR, this is also done for other legal areas such as Canada or Malaysia on the basis of so-called "manual restrictions": These also make it possible to store further worldwide as well as internal company-specific legal requirements along with different experts (e.g. value, country constellation, goods tariff number, coding, material number, customer etc.). These can be seamlessly integrated into the standard inspection, blocking and release process without programming effort.
Export licenses: OSRAM uses AEB's License Management software to check whether existing, deposited export licenses can be used for export control checks. If this is the case, the system automatically suggests a use. If licenses are subject to conditions, these conditions can also be managed in the AEB application. The advantage: You can configure approval types for all countries and industries yourself. And by recording the export licenses at a central point in the company, OSRAM keeps track of all existing licenses and license conditions to be complied with - for all locations and all legal areas.
All solutions are also implemented in the OSRAM SAP® systems. The integration is achieved exclusively through standard SAP® user exits and customer exits. This makes it easy to update both OSRAM's SAP® systems and the AEB software. All development objects created under ABAP® objects are generated in the AEB namespace. OSRAM also has the option of using Business Add-Ins (BAdI) to individually adapt your system. Central administration is also implemented. Users remain in the familiar SAP® software interface. Data is automatically transferred and, if required, stored in optical corporate archives via ArchiveLink.
Solutions in use worldwide
OSRAM and AEB drew up a plan for the international
introduction on the basis of the tight timetable.
the central logic of how processes run in a kind of copy template,"
explains Sebastian Rothe, project manager at AEB. "We developed and tested
these in the first months of 2018 and took them live at the beginning of April
for the OSRAM Opto Semiconductors division's first SAP® system."
As the implementation progressed, this template was rolled
out to a new region or area about every six weeks with only minor adjustments:
In June the SAP® systems for Europe and Asia were connected, in August it was
the turn of the NAFTA region and finally the central HR system.
This second project started in February 2018 and was
delivered for testing in August. Since the solution would not only be used by
OSRAM trade compliance experts worldwide, but also by many different employees,
both project partners paid great attention to user-friendliness during the new
"Information on the end use of our products is
usually only available to the local decentralized sales unit," explains
Dites. "Nevertheless, it is essential to ensure that we check the end-use
and use of our goods, document this check and ultimately act in compliance with
the law. That's why the software should be as easy and intuitive as possible to
use, both for us as a specialist department and, above all, for our colleagues
In order to achieve this, later users were already
involved in the development of the solution - especially when it came to
interface design. They tested numerous prototypes and gave feedback on the
designs, which were then corrected and refined until the final design of the
software was defined.
Compliance Screening from AEB
Automatically runs restricted party screening in the
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Warns before a business partner becomes a liability. Integrates with your
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"Although we put existing processes to the test in detail and made some adjustments to improve efficiency and effectiveness, we were able to keep to the tight schedule," says Klingshirn, with satisfaction.
In autumn 2018, the replacement of the existing solution and the switch to the AEB software took place on time. One reason why the tight schedule could be adhered to: The AEB project team was on site in Munich and thus close to OSRAM.
"This enabled us to always provide fast and direct project support," says AEB’s Rothe. The solution is now being used by experts at OSRAM's Munich headquarters as well as in the regional export control, customs and business unit teams.
What is the end-use and intended use check?
The statutory provisions stipulate that irrespective of the technical condition of the goods, i.e. also for non-listed goods, their final destination and intended use must be subject to export control. The provisions impose prohibitions on certain deliveries or, if corresponding knowledge/points of reference exist at the time of export, an obligation to obtain a permit.
"We have stored multilingual questionnaires in the software, which every sales employee worldwide must fill out for new customers or projects," said Dites, explaining how the solution works.
As a first step, the questionnaire contains the names and
addresses of the partners involved in a transaction. Based on this, an embargo
and sanctions list check is carried out directly. The sales representative then
has to answer a few brief questions, such as whether a possible delivery is
related to a military end-use. Depending on the countries involved, special
land notices may be added.
Immediately afterwards, the employee receives a risk
assessment; the completed questionnaires are stored centrally and can be retrieved
by the export control officers. If a warning is issued, a follow-up process is
triggered. An internal workflow ensures that the ECC makes an assessment and
later a release of the respective process.
In addition, the software helps to improve transparency by
making all checks available in a structured manner in one place and protecting
them from later changes. This also pays off in the case of external audits, for
example, when the necessary documents have to be made available.
A further advantage: The solution supports the approval process directly by making the completed questionnaires available as pdf
documents, which already have comment and approval fields.
"Risk Assessment is a great solution for me to
efficiently, transparently and securely manage end-use checking in export
control," says Dites, summarizing the benefits of the new software.
Millions of test procedures
Overall, the AEB solutions have also proven themselves at
OSRAM. They are now running completely in the private cloud of the ISO-27001-certified
AEB data center in Stuttgart. Redundant data storage and emergency plans ensure
the security of data and applications.
And the AEB data and content service ensures that OSRAM
has up-to-date, legally compliant software while at the same time requiring
little maintenance. If, for example, sanctions lists or embargo regulations
change, AEB automatically updates them in the corresponding solutions - without
the IT department at OSRAM having to worry about it.
"A special feature is certainly the size of the
installation and the volume at OSRAM," says AEB project manager Rothe.
"Every year, our solutions perform several million sanctions list and
export control checks. Despite these volumes, the software runs reliably and
with high performance, so that OSRAM benefits from greater transparency,
efficiency and security."
Klingshirn and Dites also draw a positive conclusion:
"It was a very entertaining project, which was a lot of fun thanks to its
dynamism, short decision paths, cooperation on an equal footing with partners
and the quickly coordinated team. In the end, with AEB, we now have the right
software support to meet our high trade compliance requirements.