Page 229 - MANUAL OF SOP

Manual of OP for Trade Remedy Investigations

maintain its production records based on a standard that may be different
from the product that is actually sold. For example, a chemical producer
may sell its product at a 90% concentration level, but maintain its records
on a 100% concentration level standard. Where such differences exist,
the investigating team should make sure that all reported factors are
appropriately and consistently adjusted, and discuss any inconsistencies in
the report. Similarly, as they examine both production and factor inputs,
team members should be sure that the respondents have reported, and
they are verifying, actual and not standard, production figures. If production
yield is relevant in the case, the team members will also verify the net yield
in this step.
Related parties or affiliations

(xlii) In the application/questionnaire responses, companies are required to report
related parties or affiliates involved in the production or sale of the PUC in
the investigation. The purpose of verifying affiliations is to confirm that
reported affiliations between companies through investment or interlocking
board members and officers are accurate and complete. Sometimes
applicant/respondents will limit this reporting to affiliated companies that
have a direct role in the production or sale of Product Under Consideration in
the investigation. In those instances, where there are affiliated companies,
team members must also consider the affiliate’s relationships with its
customers and suppliers. Verification of affiliations in large multinational
companies is much more difficult than for smaller companies. The process
can be greatly facilitated by pursuing the verification as below:
(a) Verification of the respondent’s shareholders can be accomplished
through a variety of documents. The notes to the financial report
will often list all, or at least the major, shareholders. Team members
can also verify using the ‘shareholders equity’ section of the balance
sheet. Other documents include shareholders’ reports, government
registration documents or published security reports of public
companies.

(b) Verification of company share holdings and investments is primarily
accomplished using the asset section of the balance sheet. Asset
accounts, such as ‘marketable securities’, ‘investment in securities’,
‘investment in subsidiaries and affiliates’, and ‘loans to affiliates’

206