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REPORT ON SELF-POLICING
WITHIN THE STEAMSHIP CONFERENCE SYSTEM

VOLUME II

AN INDEPENDENT STUDY
by Harry C. deVenoge

MARCH 1977

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(A) Necessity for Standards
(B) Requirement for the Retention of Neutral Body

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(C) Definition of Terms

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(B) Implementation of Sophisticated

Investigative Approach
(1) Combined Investigator-Auditor Concept
(2) Strategy and Tactics of Investigator-

Auditor Approach to Shipping Malpractices

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(B) Standards for Evaluation of Self-Policing

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(4) Necessity for Review of Neutral Body Files

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(5) Procedures for Disapproval of Agreements
(6) Reporting Requirements

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VIII. INTRODUCTION TO FINAL REPORT

The first portion of this study was written to enable the Commission to consider and act upon initial recommendations prior to completion of my contract. With the concurrence of the Commissioners, the Report was distributed to those officials in the shipping industry who were instrumental in formulation of the recommendations. This distribution was made so that further input, could be obtained from the industry on how best to improve the self-policing system.

It was intended during the second portion of the study to analyze in depth and compare the investigative methods, procedures, and adjudication activities of the neutral bodies operating in the United States trades, at which time · possible ways of improving the self-policing system would be suggested. Oversight of self-policing by a party independent of the Commission was to be explored.

The initial report was also distributed to carriers in the U.s. trades so that they would have more of a basis to understand my mission and the necessity for review of investigative files. This was done because there had been reluctance in the Far East trades to allow a review of the files and investigative methods of Freight Conference Services. Unfortunately, the arguments propounded in the Report, and personal requests by the Chairman of the Commission, were not compelling enough to sway the conferences to waive the confidentiality clauses in their self-policing agreements. Consequently, a complete overview of self-policing could not be obtained. Tentative plans to have the study continue for another year or so had to be discarded.

Nevertheless, what should be considered practicable methods and procedures to be used by a neutral body in the routine policing of a conference have been formulated. In this regard, minimum standards of coverage are discussed and manpower guidelines are suggested for what would be considered the required coverage in the areas of inspection of cargo and documents as well as the routine investigation of carrier malpractices. In addition, recommendations are made on possible ways to implement a more sophisticated approach to self-policing and, in particular, the developing of cash rebates and other major malpractices. The recommendation here is that each agreement set forth minimum

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